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Reporting Entity Guidance
To provide the Federal Accounting Standards Advisory Board’s (FASAB) Statements of Federal Financial Accounting Standards (SFFAS) No. 47, Reporting Entity determinations received by the federal entities, reviewed by the Working Group, and approved by the SFFAS No. 47 Steering Committee. The determinations are listed in Appendix 1b (Consolidation Entities, Disclosure Entities, and Related Parties).
An initial questionnaire was designed for implementation by compiling the key deciding factors throughout FASAB Standard No. 47 with the corresponding paragraphs in SFFAS No. 47 with each question. The questionnaire asked for the component reporting entity to be identified. Upon completion of the survey, the entity was led to a reporting determination of consolidation entity, disclosure entity, related party, or not required to report. For FY 2020, consistent with Appendix C of SFFAS No. 47, the survey now requires component entities to document the rationale for their determinations as to other entities for each entity considered. It also requires entities to specify whether any other entities are component thereof (i.e., consolidation or disclosure), a related party or do not meet the criteria of SFFAS No. 47.
The survey supported the following determinations*:
Component Reporting Entity—is used broadly to refer to a reporting entity within a larger reporting entity. Examples of component reporting entities include organizations such as executive departments, independent entities, government corporations, legislative entities, and federal courts. Component reporting entities would also include sub-components (those components included in the financial statements of a larger component reporting entity) that may themselves prepare financial statements. An example would be a bureau that is within a larger department that prepares its own stand-alone financial statements.
Consolidation Entity—is an organization that should be consolidated in the financial statements based on the assessment of whether it: “(a) is financed through taxes and other non-exchange revenues, (b) is governed by the Congress and/or the President, (c) imposes or may impose risks and rewards to the federal government, and (d) provides goods and services on a non-market basis.” It also includes organizations that, if excluded would, result in misleading or incomplete financial statements.
Disclosure Entity—is an organization with a greater degree of autonomy within the federal government than a consolidation entity.
Related Party—Organizations are considered to be a related party in the financial statements if the existing relationship or one party to the existing relationship has the ability to exercise significant influence over the other party’s policy decisions. It is noted that failing to note the relationship would be misleading (such as relationships considered for inclusion under consolidation/disclosure, but which have been determined not to meet the inclusion principles).
*See SFFAS No. 47, Reporting Entity for more detail.
The top down approach was used to identify potential entities that meet the criteria of SFFAS No. 47 from a government-wide perspective. To ensure completeness, the component should perform a bottom up assessment to identify entities that may not have been identified through the top down approach. Each component entity should perform an entity review annually to validate proper reporting at the entity level. For assistance in an entity level review, please contact Fiscal Service at GTAS.Team@fiscal.treasury.gov to receive the SFFAS No. 47 Entity Analysis Excel workbook. Notify Fiscal Service immediately if an entity analysis results in a determination(s) that differs from those outlined in Appendix 1b, and include the basis for determination.
Component entities must notify Fiscal Service of any discrepancies between the auditor and the component entity as to the component entity’s reporting entity status determination. In addition, questions concerning which component entity a federal entity needs to be consolidated into must be discussed with Fiscal Service. Final reporting entity determinations must be agreed upon by Treasury and OMB.
Federal entities must report information based on the SFFAS No. 47 determination. The determinations are available in Appendix 1b and will be used to report Appendix A: Reporting Entity of the Financial Report of the United States Government. An entity with the determination of consolidation will submit an ATB in GTAS. This data will flow to the face of the government-wide statements presented in the FR. SFFAS No. 34 recognizes that some federal reporting entities prepare and publish financial reports pursuant to the accounting and reporting standards issued by the Financial Accounting Standards Board (FASB). SFFAS No. 34 provides that certain entities' financial statements prepared in conformity with accounting standards issued by the FASB may be regarded as in conformity with generally accepted accounting principles (GAAP). Consolidation entities (that is, the consolidated government-wide reporting entity or a consolidated component reporting entity) may consolidate component or sub-component reporting entity financial statements prepared in accordance with SFFAS No. 34 without conversion for any differences in accounting policies among the organizations.
Entities with a determination of disclosure or related party (see Appendix 1b) will continue to report Treasury Account Symbols (TAS), if applicable, but when utilizing the disclosure or related party, TAS transactions must be processed as non-federal (N). This information is reported by the consolidation entities and not a direct report by the disclosure or related party. Therefore, if the entity has a relationship with a disclosure entity included in the government-wide financial statements or related party, make sure to report the federal or non-federal designation as non-federal.
Section 405 of the Government Management Reform Act of 1994 [31 U.S.C. 331(e)(1)] requires that the Secretary of the Treasury annually prepare and submit to the President and the Congress an audited financial statement for the preceding FY. This statement must cover all accounts and associated activities of the executive branch of the federal government. Section 114(a) of the Budget and Accounting Procedures Act of 1950 [31 U.S.C. 3513(a)] requires each executive branch agency to furnish financial and operational information as the Secretary of the Treasury may stipulate.
Treasury and OMB consolidate the legislative and judicial branches in the consolidated financial statements as well. To ensure that all material amounts across the three branches of government are accounted for, Fiscal Service uses the data submitted in GTAS plus records supported journal vouchers based on audited financial statements, as well as the authoritative data from the Central Accounting Reporting System (CARS).
FR Reporting and Submission Dates
See Figure 2 for the FR reporting and submission dates regarding GTAS, intra-governmental transactions/balances, legal representation letters, Management Representation Letters (MRLs), and subsequent events.
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 FR.
Federal entities must submit unaudited interim financial statements 21 business days after the end of third quarter. Comparative interim financial statements are limited to the Balance Sheet, SNC, and SCNP. Along with the three financial statements, federal entities must submit a variance analysis in accordance with OMB Circular No. A-136, Section IV.2. In addition, federal entities must submit a completed Budget Deficit Reconciliation template. The above deliverables, along with unaudited notes must be submitted 45 business days after the end of third quarter (see Figure 2 for all due dates). All applicable documents are to be transmitted through MAX.gov, but may also be transmitted directly to Fiscal Service in accordance with Fiscal Service requests. Fiscal Service will also require federal entities’ assistance with completing the analysis of notes that present a greater risk of failing to meet the prescribed disclosure requirements. Examples of these notes are:
Cash and Other Monetary Assets,
Loans Receivable and Loan Guarantee Liabilities, Net,
Federal Debt Securities Held by the Public and Accrued Interest,
Federal Employee and Veteran Benefits Payable,
Property, Plant, and Equipment, Net,
Disclosure Entities and Related Parties,
Insurance and Guarantee Program Liabilities,
Debt and Equity Securities,
Environmental and Disposal Liabilities,
Public-Private Partnerships, and
Funds from Dedicated Collections.
Federal entities should submit to Fiscal Service their contact information for internal representatives who are considered technical experts in the subject matter areas listed above, and will be the point of contact for close collaboration throughout interim analysis and preparation of the FR. Contact information (name, phone number, email address, and subject matter area(s) of expertise) should be submitted to Fiscal Service at email@example.com no later than 21 business days after the end of the third quarter. Fiscal Service will provide the federal entity technical experts, as identified by the federal entity, the Significant Disclosures template, a copy of the final published version of the above listed note(s) from the prior-year FR (Word document), as well as auditor comments on each note (if applicable) received throughout the prior-year FR preparation process. Federal entity technical experts are required to provide feedback on the Significant Disclosures template on items of significance that occurred during the FY that should be considered by Fiscal Service for disclosure in the FR during its analysis and compilation process. With SFFAS No. 57 in effect for FY 2020 reporting, the Significant Disclosure template will include questions about Stewardship Investments. In addition, federal entities are required to provide current-year updates, e.g., changes to existing wording, addition of new material information, etc., to the prior-year notes using Word documents with the Track Changes feature in Microsoft Word. This must also include any changes to the MD&A for Stewardship Investments. Auditor comments received on the above notes listed during the prior-year FR preparation process are provided to the federal entity technical experts to use as a guide for understanding auditor perspectives and expectations during review of the FR. The intention is to use this understanding to resolve in advance any issues for the current FY that can be anticipated based on auditor feedback on prior-year disclosures in the FR. Federal entity participation in this collaboration initiative will be measured on the entity’s year-end scorecards for the current FY. Federal entities should be aware that Fiscal Service will resend the Significant Disclosures template and draft copies of third quarter updates to the above listed notes (Word document) as a follow up within one week of the entities' financial statements due date, and the requirements will be the same as the third quarter collaboration process. Federal entity technical experts must provide feedback on the Significant Disclosures template for items of significance that occurred from third quarter to the fiscal year-end that should be considered by Fiscal Service for disclosure in the FR during its analysis and compilation process. In addition, federal entities are required to provide year-end updates, e.g., changes to existing wording, addition of new material information, etc., to the draft notes Word documents using the Track Changes feature in Microsoft Word. Participation in this collaboration process will also be measured on federal entities’ year-end scorecards.
FR Data Requirements
Significant entities must:
Submit a GTAS ATB. GTAS will crosswalk the ATB data to populate a Balance Sheet, Reclassified SNC, and Reclassified SCNP by reporting entity using the USSGL Reclassified Crosswalk. These reclassified financial statements need to be verified by federal entities in GTAS and used in Note 44: Reclassification Adjustments of AFR Due to FR Compilation in OMB Circular No. A-136. Reference the Reclassified Crosswalks on the USSGL website for additional guidance.
Submit an interim and year-end variance analysis in MAX.gov as required in OMB Circular No. A-136 Section IV.2.
Provide Fiscal Service with an electronic copy of the interim unaudited financial statements (the third-quarter financial statements), notes, RSI, and OI, if the information is not available on OMB’s MAX federal community website. Notify Fiscal Service of any additional updates to the financial statements as they are made available on MAX.gov website (see subsection 4704.10).
Comply with the intra-governmental requirements that can be found in Section 4708.
Review (with their auditors) the 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.
Contact Fiscal Service to determine the reporting procedures for any adjustments to the GTAS data and AFR/PAR after their publication, which is normally November 15. For contact information, see the GTAS Contacts page.
Federal Financial Management Standards
- Functions and Activities
Financial Performance and Operational Reporting (FFM.110.040)
Provide general ledger information for agency-specific financial reports;
Verify required financial reports can be traced to general ledger account balances; Includes providing financial performance and operational information to agency program offices
- Federal Financial Management System Requirements
Providing GL Information (1.3.1)
Provide GL information for consolidated government-wide reporting as specified in the TFM and consistent with guidelines in the FASAB Handbook as well as OMB Circular No. A-136.
Provide GL information for agency-specific financial reports consistent with OMB Circular No. A-136 and FASAB Handbook.
Defining Federal Funding Attributes to Align Financial Management Information with Performance Goals (1.4.1)
Provide federal funding attributes (for example, program, activity, and cost object) that align funding requests, funding allocations, fund obligations, fund expenditures, and costs with agency performance goals, as required by the Chief Financial Officer (CFO Act) as well as the Government Performance and Results Act and consistent with the FASAB Handbook, OMB Circular No. A-11, and OMB Circular No. A-136.
Reporting on Payments (2.2.3)
Agencies for which Treasury does not disburse: Provide disbursement summary and detail data as specified in the TFM.
Agencies for which Treasury disburses: Provide payment transaction information at the required account classification level (for example, appropriation, fund, and receipt) and subclass code as specified in the TFM.
Provide improper payment information as specified in OMB Circular No. A-123 and the TFM.
Verifying Traceability (2.3.2)
Verify that GL account balances can be traced to aggregated or discrete transactions in agency programmatic systems and that the aggregated or discrete transactions can be traced to the point of entry and source documents consistent with the TFM.
Verify that financial statements and other required financial and budget reports can be traced to GL account balances as required by OMB Circular No. A-123 and as specified in the TFM.
- Use Cases
Record to Report
- Treasury Financial Manual (TFM)
TFM Volume I, Part 2, Chapter 4700; Federal Entity Reporting Requirements for the Financial Report of the United States Government
This page was last updated on May 11, 2021.