See the FY 2025 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 and 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 focus areas.

Federal entities should submit to Fiscal Service their POC information for internal representatives who are considered technical experts for financial reporting, restatements, legal counsel responses, MRL, Summary of Uncorrected Misstatements (SUM), and significant disclosures for key focus areas (key focus areas are listed in the FY 2025 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 to notify Treasury of new disclosures or significant changes that have been made to their programs. Comparative interim financial statements are limited to the Balance Sheet, SNC, and SCNP. Please reference the FY 2025 TFM Year-end Closing Bulletin for guidance on transmission of applicable documents.

4730.10b-Significant Disclosures of Key Focus Areas

Fiscal Service will also require significant entities’ assistance with completing the analysis of ‘key” focus areas that present a greater risk of failing to meet the prescribed disclosure requirements and that are relatively new to the Financial Report. “Key focus areas” 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” focus areas, 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. Please reference the FY 2025 TFM Year-end Closing Bulletin for guidance on transmission of applicable documents.

See the FY 2025 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 and IGT Scorecards for the current FY.

Key Focus Areas for FY 2025:

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

4730.20a-Year-End Financial Statements, Notes, and Variance Analysis

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, Please reference Section 4735 for additional financial reporting requirements. Please reference the FY 2025 TFM Year-end Closing Bulletin for guidance on the transmission of applicable documents and all the due dates.

4730.20b-Significant Disclosures of Key Focus Areas

Significant entities should be aware the significant disclosure Key focus areas 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. See the FY 2025 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 and IGT Scorecards.

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 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:

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. CFO Representation Form requirements are stated in Section 4750.60 as well as TFM 2-4700, Appendix 4.

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:

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:

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:

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:

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.

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:

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) Accounting/Reporting Error—This intra-governmental difference occurs when the reporting entity has incorrectly reported activity either by RC, trading partner, or amount. The total of these amounts must be identified and explained. If the entity is in error, then provide the adjustment amount as well as the corrective action (journal entry, etc.), and when the error will be corrected.

(2) Communication/Current-year Timing Difference—This intra-governmental difference occurs when the reporting entity has not effectively reported to its trading partner or when the reporting entity has reported activity in a different quarter than the trading partner reported the activity in the current-year. The total of these amounts must be identified. Also, explain what adjustment should be made. 

(3) Prior-Year Timing Difference—This intra-governmental 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 total of these amounts must be identified. Also, explain whether an adjustment should be made.

(4) Accounting Methodology Difference—This intra-governmental difference occurs when the reporting entity uses a different accounting method than their trading partner to account for activity. The method of accounting must be identified and explained as well as an attempt made to provide the dollar amount of the difference caused by the differing methodologies.

(5) Entity Verified—This intra-governmental difference category is 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. 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.” These balances will be reviewed by Fiscal Service with the other entity.

(6) Judicial/Legislative—These intra-governmental differences occur because the Judicial and Legislative federal entities are not required to report. Federal entities included are: 0000 – Congress; 0100 – Architect of the Capitol; 0200 – U.S. Capitol Police; 0300 – Library of Congress; 0800 – Congressional Budget Office; 0900 – Other Legislative Federal entities ; 0902 - Comm. on Security & Cooperation – Europe; 0904 – John C. Stennis Center; 0905 – U.S. Capital Preservation Commission; 0907 – Office of Compliance; 0908 – Open World Leadership Center Funds; 0912 – Senate Preservation Fund; 0915 - Medicaid and CHIP Payment and Access Commission; 1000 – The Judiciary; 2300 – U.S. Tax Court. 

(7) Entity System Issues—These intra-governmental differences occur because one or both federal entities state that they have some sort of system issue that prevents them from reporting correctly.

(8) FICA-Federal Employers Share—These intra-governmental differences occur because there is no reciprocating activity for employers share of Federal Insurance Contributions Act (FICA) to be reported by a trading partner.
(9) Shared TAS—These intra-governmental differences occur due to a shared TAS, which cannot be reported by both federal entities in GTAS.

(10) Other—This intra-governmental difference category occurs when none of the other intra-governmental difference categories apply. Entities must describe the situation that has led to the intra-governmental difference.
 

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.

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:

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).

Direct inquiries and deliver documents required by this chapter to:

Department of the Treasury 
Bureau of the Fiscal Service 
Financial Reports Division 
financial.reports@fiscal.treasury.gov

Also, deliver documents required by this chapter to:

Carolyn Voltz, CPA 
Government Accountability Office 
USCFS@gao.gov

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

Scott Bell, Senior Staff Accountant 
Department of the Treasury 
Office of the Fiscal Assistant Secretary 
robert.bell@treasury.gov

Legal Counsel Responses:

Department of Justice 
Legal.Letters@usdoj.gov