Quarterly Reporting Requirements

Financial Report Reporting and Submission Dates

Section 4730—Financial Report Reporting and Submission Dates

See the FY 2024 TFM Year-end Closing Bulletin for all the Financial Report reporting and submission dates regarding, but not limited to, GTAS, intra-governmental transactions/balances, legal counsel responses, Management Representation Letters (MRLs), and subsequent events.

Federal entity participation in the third quarter and/or year-end Financial Report reporting submission and collaboration initiatives will be measured on the entity’s year-end Financial Report (FR) and Intra-governmental Transactions (IGT) Scorecards for the current FY. Entity performance measures include 1) timeliness; 2) timely/complete; 3) reconciliation of differences; 4) consistency and integrity; and 5) Significant Disclosures on key notes.

Federal entities should submit to Fiscal Service their POC information for internal representatives who are considered technical experts for financial reporting, restatements, budget deficit reconciliation, legal letters, MRL, Summary of Uncorrected Misstatements (SUM), and significant disclosures for key subject matter areas (key subject matter areas are listed in the FY 2024 TFM Year-end Closing Bulletin). These individuals will be the POC for close collaboration throughout interim analysis and year-end preparation of the Financial Report according to section 4710 above. Contact information must include name, phone number, email address, and area(s) of expertise and be submitted to Fiscal Service at financial.reports@fiscal.treasury.gov.

4730.10—Third Quarter Reporting (Unaudited Financial Statements and Notes)

The purpose of these submissions is to enable Fiscal Service to conduct preliminary analysis on federal entity data to facilitate preparation of the Financial Report.

4730.10a-Interim Financial Statements and Notes

Significant entities must submit unaudited interim financial statements and notes, as of June 30, in accordance with OMB Circular No. A-136. Comparative interim financial statements are limited to the Balance Sheet, SNC, and SCNP. Please reference the FY 2024 TFM Year-end Closing Bulletin for guidance on transmission of applicable documents.

4730.10b-Significant Disclosures of Key Subject Matters

Fiscal Service will also require significant entities’ assistance with completing the analysis of ‘key” subject matters that present a greater risk of failing to meet the prescribed disclosure requirements and that are relatively new to the Financial Report. “Key subject matters” are notes, Required Supplementary Information (RSI), or Other Information (OI) identified as being affected by new or updated FASAB/FASB standards and notes, RSI, and OI that include topics that are prevalent in the current socioeconomic climate.

For “key” subject matters, Fiscal Service will provide the Significant Disclosures questionnaire on the GTAS website (Resources section). Federal entity technical experts are required to provide feedback on the Significant Disclosures questionnaire on items of significance that occurred during the FY that should be considered by Fiscal Service for disclosure in the Financial Report during its analysis and compilation process. Questions are to be submitted to Fiscal Service. Fiscal Service will also include a link to the prior year published Financial Report and any applicable auditor comments with the questionnaire.

See the FY 2024 TFM Year-end Closing Bulletin for the dates the questionnaire will be available on the GTAS website and dates the completed questionnaires are to be returned to Fiscal Service. Federal entity participation in the third quarter collaboration initiative will be measured on the entity’s year-end Financial Report (FR) and Intra-governmental Transactions (IGT) Scorecards for the current FY.

Key Subject Matters for FY 2024:

  • Note 1,
  • Land,
  • Cryptocurrency (Inventory),
  • Federal Employee and Veteran Benefits Payable,
  • Commitments, and
  • Leases.

4730.20—Year-End Reporting (Audited Financial Statements and Notes)

4730.20a-Year-End Financial Statements, Notes, Variance Analysis, and Budget Deficit Reconciliation Template

All federal entities (significant and other) must submit audited financial statements and notes in accordance with OMB Circular No. A-136. Significant entities must submit a variance analysis in accordance with OMB Circular No. A-136, Section III.2, and a completed Budget Deficit Reconciliation template in accordance with Section 4735.10 of this chapter (see the FY 2024 TFM Year-end Closing Bulletin for all due dates). Please reference the FY 2024 TFM Year-end Closing Bulletin for guidance on the transmission of applicable documents.

4730.20b-Significant Disclosures of Key Subject Matters

Significant entities should be aware the significant disclosure Key Subject matters collaboration process is also a requirement at year-end. Fiscal Service will provide the year-end Significant Disclosures questionnaire on the GTAS website. Federal entity technical experts must provide feedback on the Significant Disclosures questionnaire for items of significance that should be considered by Fiscal Service for disclosure in the Financial Report during the analysis and compilation process, along with the location of the disclosure in the entities’ financial statements. Responses are also required for the Immaterial Correction of Errors and Reclassified Financial Statements Adjustments. See the FY 2024 TFM Year-end Closing Bulletin for the dates the questionnaire will be available on the GTAS website as well as the dates the completed questionnaires are to be returned to Fiscal Service. Participation in this collaboration process will also be measured on federal entities’ year-end Financial Report (FR) and Intra-governmental Transactions (IGT) Scorecards.

Section 4750—Intra-governmental Quarterly and Year-end Requirements

4750.10—Intra-governmental Transactions/Balances

Intra-governmental transactions result from business activities conducted between two federal government entities, called trading partners. Accounting differences occur in government-wide financial reporting when trading partners record differing amounts for transactions that should eliminate or net to zero. All differences should be resolved by year-end. Trading partners must reconcile and resolve these differences on a periodic basis with their trading partners. The Intra-governmental Transaction (IGT) Guide (Appendix 5) contains the business rules and processes to properly record, report, and reconcile intra-governmental transactions, including the processes for dispute resolution. See the following appendices for guidance on specific types of intra-governmental transactions:

  • Appendix 6—Investments and Borrowings
  • Appendix 7—Benefits
  • Appendix 8—Buy/Sell
  • Appendix 9—Transfers
  • Appendix 10—Custodial and Non-entity Transactions
  • Appendix 11—General Fund of the U.S. Government

Note: The Federal Reserve System, which includes the Board of Governors, is not considered a consolidated entity in government-wide reporting entity under federal accounting standards (please note the Board of Governors is considered federal for tax purposes, however, for government-wide reporting, they are considered non-federal). Therefore, payments made to or collections received from the Federal Reserve System would be reported in the financial statements of the federal government and its component reporting entities. All activity with the Board of Governors of the Federal Reserve System and all of the Federal Reserve System must be reported as non-federal “N” activity.

Federal Executive Boards are not considered a consolidated entity in government-wide reporting under federal accounting standards and all activity with Federal Executive Boards must be reported as non-federal “N” activity for financial reporting purposes. Please refer to Appendix 1b for a list of Disclosure Entities, SFFAS No. 47.

4750.20—Additional Intra-governmental Reconciliation Requirements

The intra-governmental transactions reconciliation and resolution requirements are stated in OMB Circular No. A-136, revised.

4750.30—Federal Intra-governmental Transactions Accounting Scenarios

To aid in the reconciliation of intra-governmental differences, federal entities should follow the accounting scenarios found on the USSGL website. The scenarios provide posting logic for accounting transactions of select events occurring throughout the federal government and are made available as a source of guidance.

4750.30a—Non-fiduciary Transactions

For non-fiduciary transactions, OMB requires reporting entities to reconcile and confirm intra-governmental activity as well as balances quarterly for the following reciprocal groupings:

  • Services provided and reimbursables. Examples include, but are not limited to, legal, consulting, investigative, financial management, grants management, technology, reimbursables, and other similar services.
  • Cost of products sold. Examples include, but are not limited to, supplies, manufactured items, inventory, office space, and equipment/vehicle rentals.
  • Transfers, appropriations used, and collections for others, as well as unusual assets and liabilities related to appropriations. Examples include, but are not limited to, transfers between federal entities based on agreements or legislative authority, expended appropriations, taxes and fees collected, collections for others, receivables from appropriations, transfers payable, and custodial revenue.

The above listings of examples are not exhaustive; additional examples in each category may qualify as non-fiduciary transactions.

4750.30b—Related to Capitalized Purchases and Assisted Acquisitions

Federal entities that purchase capitalized assets, or previously capitalized assets/inventory from other federal entities must follow the Capital Asset scenario located in Intra-governmental Capital Asset and Inventory Buy/Sell Transactions Guidance.

Federal entities that participate in Assisted Acquisitions must follow the Assisted Acquisition scenario located in Assisted Acquisition Guidance.

4750.40—Intra-governmental Transactions Reconciliation and Resolution Process

Federal entities must use three-digit trading partner AID and a four-digit trading main account for all intra-governmental transactions. When federal entities report “appropriations transfers” within their departments, they must use their three-digit trading partner code. Federal entities should work with their federal trading partner to ensure the Trading Partner Agency Identifier and Trading Partner Main Account are valid as well as applicable to the activity being monitored.

4750.40a—Fiscal Service Intra-governmental Activity

Federal entities are expected to communicate and work with their respective trading partners before IGTs occur. Federal entities are expected to work with each trading partner before brokering intra-governmental activity to ensure strong controls are in place to effectively manage these transactions, which would lead to better reconciliation processes and fewer intra-governmental differences to reconcile and resolve. Federal entities are expected to minimize intra-governmental differences before they occur.

If after early and ongoing communication between trading partners, an intra-governmental difference exists, federal entities must reconcile and resolve these differences. Appendix 5 discusses the reconciliation and resolution process which includes the Intra-governmental Root Cause, Corrective Action Plan (CAP), and dispute resolution processes.

In preparation for the year-end submission, federal entities should validate and reconcile their data monthly to resolve intra-governmental differences in certain RCs, prior to their data submissions in GTAS.

An example of reconciling data includes the reconciliation of intra-governmental GTAS edits including:

  • RC 07, Appropriation of Unavailable Trust or Special Fund Receipts (represented by GTAS Edit 33-UCAD Reciprocal Category 7 Transferred-In and Edit 34-UCAD Reciprocal Category 7 Transferred-Out),
  • RC 08, Non-expenditure Transfers of Unexpended Appropriations and Financing Sources (represented by GTAS Edit 35-UCAD Reciprocal Category 8 Transferred-In and Edit 36-UCAD Reciprocal Category 8 Transferred-Out),
  • RC 11, Non-expenditure Transfers of Financing Sources–Capital Transfers (represented by GTAS Edit 40-UCAD Reciprocal Category 11 Capital Transfers-In and Edit 41-UCAD Reciprocal Category 11 Capital Transfers-Out), Appropriations Received as Adjusted (represented by GTAS Edit 50-Normal Warrants Edit-Proprietary), and
  • RC 40, Fund Balance with Treasury (represented by GTAS Edit 1-Fund Balance with Treasury).

Significant entities and selected other entities (as designated by “**” in Appendix 1a) are required to explain and certify all Material Differences Reports (MDR) Parts I, II, and III for Quarter 1, Quarter 2, Quarter 3, and Year-end. Federal entities will use the Intra-governmental Module in GTAS to view and explain as well as certify their Material Differences.

The Material Differences Window, which is used to explain and certify differences will open after the GTAS Bulk File Submission Window closes. These dates are set by Fiscal Service. The intra-governmental key dates as well as the GTAS reporting window schedule can be found on the GTAS website.

Federal entities must provide detailed explanations for MDRs Parts I, II, and III. Detailed explanations should include but are not limited to the following:

  • The reason the difference exists,
  • What is being done to reconcile the difference, and
  • The expected completion date of eliminating the difference.

Federal entities may obtain the IGT Raw Data File from GTAS to be used for the research of differences. If a federal entity is not able to provide the detailed information listed above, Fiscal Service may follow up for a response. Fiscal Service will use its own discretion when analyzing explanations and follow up for clarification, if needed.

Federal entities will also be able to obtain the following quarterly reports from GTAS:

  • MDR Part I (if applicable). This report displays differences equal to or greater than $100 million in all reciprocal categories (except RC 29, which is included in Part III). Federal entities will use subsection 4750.40b as guidance to select the explanation and the detailed information that must be provided.
  • MDR Part II (if applicable). This report displays differences equal to or greater than $10 million and less than $100 million in all RCs (except RC 29) with the following Financial Report Entities that are encouraged to report for inclusion in the FR:

    • 0000 (Congress: House and Senate),
    • 0100 (Architect of the Capitol),
    • 0200 (U.S. Capitol Police),
    • 0300 (Library of Congress),
    • 0800 (Congressional Budget Office),
    • 0900 (Other Legislative Branches),
    • 1000 (The Judiciary),
    • 2300 (U.S. Tax Court), and
    • 9999 (Unknown Trading Partners/Unidentified).

While a type of difference like those listed in subsection 4750.40b is not required for MDR Part II, a detailed explanation of the difference is expected. Federal entities must select “Part II Differences” as the type of difference when explaining these differences in the Intra-governmental Module of GTAS.

  • MDR Part III. This report displays amounts reported in RC 29 with the federal/non-federal domain value of Z for non-reciprocating intra-governmental activity. While a type of difference, like the types listed in subsection 4750.40b, is not required for MDR Part III, federal entities must select “Part III Differences” as the type of the difference and must provide Fiscal Service with an explanation of why this non-reciprocating intra-governmental activity is reported. An explanation of “non-reciprocating activity” is not considered acceptable. Federal entities must provide Fiscal Service with the specific type of activity being captured in each USSGL. Fiscal Service may follow up for clarification to ensure the non-reciprocating intra-governmental activity reported is used for the appropriate purpose.
  • Comparative Status of Disposition Report. This is available after all of Part I Material Differences are certified and the Material Differences Window is closed. It contains comparative MDR Part I reporting between the federal entity and its trading partners by RC. CFOs use this report to address and resolve inconsistencies in amounts and explanations between the federal entity and its trading partners.

With federal entities explaining and certifying material differences, the assurance for Fiscal Service that entities comply during the IGT reconciliation and resolution process is established using three functions:

  • Obtaining sufficient explanations and corrective actions, as applicable, to resolve the out-of-balance condition,
  • Obtaining assurance that federal entities are performing quarterly intra-governmental reconciliations and resolutions in accordance with OMB Circular No. A-136, revised, and Appendix 5, and
  • Ensuring federal entities are mutually completing the Intra-governmental Material Differences/Status of Disposition Certification Report for the same trading partner/RC material difference instances.

Note: Recurring differences should be limited to those situations that have been confirmed by the Fiscal Service.

4750.40b—Reporting Entity’s Explanation of Reporting in Material Differences Reports Part I

An explanation for Material Difference Part I reporting should be based on each identified difference in terms of the following categories:

(1) Reporting error—occurs when the reporting entity has incorrectly reported activity either by RC, trading partner, or amount. The entity that reported the error should use this explanation. The entity must identify and explain the total amounts and provide the adjustment amount, the corrective action (journal entry, etc.), and when the error will be corrected.

(2) Current-year timing difference—occurs when the reporting entity has reported activity in a different quarter than the trading partner reported the activity in the current-year. The reporting entity must identify the total of these amounts and explain whether an adjustment should be made.

(3) Prior-year timing difference—occurs when a reporting entity has reported activity in a prior FY and the trading partner reported the activity in the current FY. The reporting entity must identify the total of these amounts and explain whether an adjustment should be made.

(4) Accounting methodology difference—occurs when the reporting entity uses a different method than their trading partner to account for activity. The reporting entity must identify and explain its method of accounting and attempt to provide the dollar amount of the difference caused by the differing methodologies.

(5) Accrual methodology difference—occurs when the reporting entity uses a different accrual method than their trading partner to account for activity. The reporting entity must identify and explain its method of accrual and attempt to provide the dollar amount of the difference caused by the differing methodologies.

(6) Entity Verified—intended to indicate that a federal entity has verified its reported amounts and that the entity’s documents are in agreement with its quarterly source documentation; and the federal entity has confirmed that the policy and guidance related to transactions and balances have been followed. It also indicates the federal entity has reconciled this amount with its trading partner and knows why the difference, if any, exists. Selecting "Entity Verified" indicates that the trading partner accepts the onus for adjusting its amount to clear any difference going forward and the trading partner will use the category of “Reporting Error.” Both federal entities cannot have "Entity Verified" where a difference exists. Federal entities should provide amounts and a detailed explanation to support the selection of "Entity Verified."

(7) Unidentified—occurs when the reporting entity cannot validate the amount of the difference or the trading partner at the time of reporting. The total amounts must be identified and explained as to why they are classified as unidentified.

Note: Unidentified also can include instances where differences are due to existing guidance that is currently under review in order to ensure elimination at the government-wide level between trading partners when applied correctly.

4750.40c—Intra-governmental Transactions Metrics and Scorecards

Fiscal Service has implemented scorecards and metrics to track reporting differences government-wide by federal entity. Scorecards will be updated quarterly and disseminated to significant entities and other entities as determined by Fiscal Service. The purpose of the metrics is to monitor progress on resolving or explaining material intra-governmental differences. Refer to Appendix 5, subsection 2.4, for further information on the timeline for these scorecards and metrics as well as related federal entity requirements.

4750.50—Year-end Intra-governmental Reconciliation Process Related to GTAS

In accordance with OMB Circular No. A-136, significant entities and other entities should reconcile their intra-governmental balances with their trading partners and resolve all resulting differences prior to submitting their final GTAS ATB. Note that at year-end, federal entities should leverage the pre-year-end report that is provided prior to the close of GTAS reporting window, and tools within GTAS (such as the Intra-governmental module and Raw Data File), to determine what outstanding IGT differences exist. Since IGT differences should be resolved prior to the close of the GTAS Reporting Window; it is imperative that, entities work directly with their trading partners to reconcile intra-governmental balances and resolve resulting differences. Additionally, significant entities and their auditors should review the prior year-end scorecard to determine if a prior-year journal voucher was processed. If so, then the significant entity should identify the reason for the journal voucher as well as how to prevent the adjustment in the current year.

Reconciling data (reported as Business Event Type Code (BETC) in CARS against Entity Reported ATB Data (reported in GTAS) can be done two ways. They are listed below.

  • In GTAS, navigate to the MY ATB STATUS module and click on the Failed Edits Tab, click on View Details. This view defaults to Failed Fatal Edits (for example, Edit 1). Click on Proposed Analytical to review any Failed Proposed Analytical Edits.
  • Navigate to Run Reports Module, select Validations/Edits for Report Type, select either Failed Edits Detail or Failed Edits Summary (depending on needs), select the applicable reporting period information, run the report by Either User ID or Specified TAS, scroll down past Fatal Edits to find Proposed Analytical Edit Failures.

If no Failed Edits or Proposed Analytical Edits appear after GTAS ATB upload, then the data and ATB Data are reconciled, and no further action is necessary.

4750.60—Year-end CFO Procedures for Intra-governmental Transactions/Balances

Significant entities must comply with the following instructions using the comparative, audited consolidated and entity financial statements:

  • Provide responses to the representations outlined in the detailed “CFO Representation” instructions found in Appendix 4 for each intra-governmental issue, and
  • Ensure the data in the Intra-governmental Year-end Material Differences Reports are consistent with the information reported in the federal program entity’s financial statements.

Fiscal Service provides the CFO Representations Form for Intra-governmental Activity and Balances (including instructions) on the GTAS website.

Provide an electronic file of the CFO’s Representations for Intra-governmental Transactions and Balances along with any supporting documentation to the federal entity's IG, Fiscal Service, and GAO (see the FY 2024 TFM Year-end Closing Bulletin for due dates).

Contact Us: Bureau of the Fiscal Service

Detailed Contacts

Direct inquiries and deliver documents required by this chapter to:

Department of the Treasury 
Bureau of the Fiscal Service 
Financial Reports Division 

Also, deliver documents required by this chapter to:

Carolyn Voltz, CPA 
Government Accountability Office 

Carol S. Johnson, Policy Analyst 
Office of Management and Budget 
Office of Federal Financial Management 
 
MAX.gov

Scott Bell, Senior Staff Accountant 
Department of the Treasury 
Office of the Fiscal Assistant Secretary 

Legal Counsel Responses:

Department of Justice