ACCOUNTING AND AUDITING POLICY COMMITTEE
MEETING
FINAL MINUTES
July
13, 2000
The
meeting was convened at 1:32 p.m. in room 4N30 of the GAO Building, 441 G St.,
N.W., Washington, D.C.
Administrative Matters
· Attendance
Present: Ms. Payne, Mr. Fred Doggett (for Mr.
Friedman), Mr. Eisenhart, Ms. Kim Grier (for Mr. Zavada), Ms. Jordan, Ms. Janet
Krell (for Mr. Dacey), Mr. Allan Lund (for Mr. Stout), Messrs. Pugh and
Ritchie.
Absent:
Messrs. Dacey, Friedman, Lane, Stout, and Zavada.
· Minutes
The
minutes of May 11, 2000 were previously approved as final, having been
circulated by e-mail to members.
· AAPC Member Vacancy
Ms. Payne noted the retirement of Mr. Frank Sullivan from the Department of Veteran
Affairs has left a vacancy on the Committee.
The CFO Council has plans to name a replacement for Mr. Sullivan.
· AACP Revised Charter and Operating
Procedures
Ms. Payne noted that the AAPC Charter and
Operating Procedures were being revised due to the AICPA Rule 203 status gained
by the FASAB. The FASAB Steering
Committee is currently reviewing the revisions. Final changes from the Steering Committee are expected in August.
Agenda Status
· Open Project Updates
Issue #21 Liabilities Covered and Not
Covered by Budgetary Resources
Ms.
Geier noted that OMB plans to address this issue in the new Form & Content
Bulletin, which will be applicable for Fiscal Years (FY) beginning 2001. This ongoing project of the AAPC deals with
disclosure of liabilities as either “liabilities covered by budgetary
resources” or “liabilities not
covered by budgetary resources,” in accordance with SFFAS 1, Accounting for Selected Assets and
Liabilities.
Issue #11 Inter-entity Costs
The
Inter-Entity Costs survey has been revised to include more general questions,
that will be followed-up by specific questions. The survey is made up of a series of questions directed to
inter-entity costs that are not fully reimbursed by the receiving entity or are
not reimbursed at all. The survey will assist the AAPC in identifying specific
inter-entity costs that are being incurred by agencies, study their nature, and
determine whether they meet the recognition criteria specified in SFFAS 4.
OMB
also plans to incorporate its Memorandum on Technical
Guidance for the Implementation of Managerial Cost Accounting Standards for the
Federal Government (dated April 6, 1998) in the new Form & Content
Bulletin for financial statements covering FY 2000.
Issue
#24 Supplemental Guidance to SFFAS 10, “Accounting for Internal Use Software”
The
Chief Financial Officers Council (CFOC) requested that the AAPC consider
issuance of an implementation guide, SFFAS
10 Implementation Topics/Issues, developed by a CFO Council task force which provides supplemental guidance to
agencies implementing SFFAS 10.
The
AAPC task force, chaired by Frank Sullivan, met to review the guidance provided
by the Council. The group reviewed the
22 guidance topics and categorized them into the following groups as
recommendations to the Committee:
n Refer
issue to FASAB -- (2 issues)
n The
issue is a non-issue or not within the scope of the AAPC or FASAB -- (12
issues)
n The
issue is adequately covered in the current FASAB standards -- (2 issues)
n The
issue should be addressed by the AAPC -- (6 issues)
The
two issues referred to the FASAB dealt with allowing Federal entities to
retroactively capitalize systems in progress before 9/30/2000, the effective
date for SFFAS 10. The FASAB discussed
this subject at its June 8, 2000 meeting.
A proposal to amend the standard to permit retroactive capitalization
was voted on by the Board and defeated by a narrow margin. A letter was sent to the CFOC noting the
Board’s action.
Mr.
Eisenhart suggested that the CFO Council publish a “Question & Answer”
article to present its views on those guidance topics noted as “a non-issue,
not within the scope, or adequately covered” by the AAPC task force. Ms. Payne noted that this article could be
viewed as “Other Accounting Literature” in the Federal GAAP Hierarchy outlined
in AICPA SAS 91, as long as the information in the article does not conflict
with any “Established Accounting Principles.” Ms. Jordan suggested that the Committee consider
sponsoring a forum on implementing
SFFAS 10.
With
respect to the classification of the issues proposed by the task force, none of
the committee members offered suggestions to change the categorization. The task force plans to meet again before
the next AAPC meeting to make its final recommendations to the Committee on
those guidance topics accepted for review.
AAPC
member Bill Pugh agreed to take over the position of task force chair since the
retirement of Mr. Sullivan. AAPC
members Larry Eisenhart and De Ritchie also serve on the task force.
Issue #25 Federal Aviation Administration’s
request for guidance on Grant Accounting
At
the May AAPC meeting, the Committee agreed to accept a grant accounting issue
from the Federal Aviation Administration (FAA). The FAA requested policy guidance on a grant accounting issue
that deals with the liability recognition by FAA (the grantor) for expenses
incurred by a grantee when the grantee incurs costs after a letter of intent
has been issued by the FAA but prior to the execution of the grant agreement.
AAPC
member Luise Jordan is chairing the task force and AAPC members Bob Dacey and
Jay Lane will also serve on the task force.
The
task force met in late June to discuss the issues raised by FAA. The task force agreed that the issues
(primarily the recognition of the liability for letters of intent) merited
further research and discussion. Ms. Jordan also obtained additional
information from the FAA and DOT audited financial statements and through
discussions with DOT OIG in their role as the financial statement
auditors. The task force also plans to hold discussions with the CFO Council Grant Accounting
Committee to gather information as to the extent of letters of intent at other
agencies and how they are accounting for such agreements. The task force has also made arrangements to
meet with other DOT and FAA officials to learn more about the events
surrounding this issue, as well as other letter of intent issues being
addressed by other component organizations within DOT (for example, the Federal
Highway Trust Fund).
It was noted that on May 1, 2000, Ms. Payne received a letter from
FAA’s Acting Director of Financial Management stating that, “FAA had obtained
verbal understanding with the Office of Inspector General (OIG) on what would
be considered appropriate accounting treatment for expenses that a grantee
incurs in one year, pursuant to FAA’s letter of intent, but are billed in a
subsequent fiscal year following the related executed agreement.” The agreement reached by FAA and OIG is to
disclose total commitments made under letters of intent, the amount recognized
under executed grants, and the amount of letter of intent financing unobligated
as of year end. In addition, FAA will recognize
a liability for the executed and obligated grant amounts billed by the grantee
and provide an estimated liability for those executed grant amounts incurred by
the grantee but not yet billed to FAA.
In light of the agreement reached by FAA and the OIG, FAA believes that
this matter is important enough to warrant AAPC’s consideration and
guidance. FAA also requested that their
original question be broadened to include the proper accounting treatment for
similar expenses incurred on an executed agreement, i.e., a grantee incurs
expenses in one fiscal year, pursuant to a duly executed grant agreement, but
submits the related invoices in a subsequent fiscal year. The question is, should these expenses be
treated as prior year expenses in the year that the invoices are submitted and
paid, or as current year expenses?
The task force plans to report back to the full Committee in
September on its progress of its work.
· History of Issues
Mr.
Pugh, chair of the Agenda Committee, provided the members with an updated
history of AAPC issues addressed since its inception. The report numbered each of the issues brought to the AAPC and
provided an explanation of how the AAPC addressed each issue.
Next Meeting
The
next meeting will be on Thursday, September 14, 2000. Ms. Payne noted that the 2001 schedule of AAPC meetings would be
available soon.
Adjournment
The meeting was adjourned at 2:45 p.m.