Issue Submission

The AAPC encourages the submission of Federal accounting and auditing issues. Matters can be referred to the AAPC by its members, OMB, GAO, Treasury, FASAB Board members, Federal agency CFOs, IGs, or other interested parties. The goal of the AAPC is to provide guidance in a timely manner. The AAPC has authority to provide guidance related to existing Federal accounting and auditing standards. AAPC may not amend existing standards or promulgate new standards.

The AAPC encourages entities to submit issues as soon as practicable after they arise and become unresolvable at the entity level. However, the AAPC is not intended to serve as a mediator for preparers, program managers, and/or auditors. Issues related to the Statements of Federal Financial Accounting Standards (SFFASs), OMB’s Form and Content Bulletin, and audit requirements should be submitted when (1) there is more than one credible accounting or auditing solution or (2) entities are aware of diversity in practice.


The submission, or referral, of an issue to the AAPC should be addressed to the AAPC Chairperson, Ms. Wendy M. Payne at:

Accounting and Auditing Policy Committee
c/o Federal Accounting Standards Advisory Board
441 G Street, NW
Room 6814
Mail Stop 6H19
Washington, DC 20548

In addition to mailing the materials, an electronic submission would be very helpful. email can be sent to


The referral must be in writing and clearly describe the issue requiring attention. The issue statement should include a brief title and a clear question(s) regarding the issue being raised. For example, “Accounting for the Cost of Removing Asbestos from Existing Buildings” is the title for the following sample issue “Should the cost of removing asbestos be capitalized or expensed?”

The referral should reference relevant accounting or auditing literature and indicate what options have been considered for resolving the issue. Differing views should be thoroughly described. If applicable, current or past practice(s) should be described and excerpts from any entity accounting or auditing manuals should be provided. The provision of this background information will help to ensure that the AAPC accomplishes its mission to provide timely guidance by facilitating our research and deliberations.

In addition, the referral should discuss, to the extent practicable, which Federal entities would be faced with similar issues and any practices currently being applied by entities other than the referring entity. One of the AAPC objectives is to minimize diversity of practice. To that end, it would be very helpful to identify impacted entities early in the deliberative process.

Point of contact

Each submission should include a point of contact within the organization, including a phone number. If possible, please provide the name(s) and phone number(s) of anyone in the organization that could serve on a task force if necessary. In addition, points of contact for any other parties to the issue (e.g., auditors) should be provided if available.

Illustrative Issue Submission

(attached to a cover letter from the submitting entity)TITLE.
Accounting for the Cost of Removing Asbestos from Existing Buildings

Should the cost of removing asbestos be capitalized or expensed?

Statement of Federal Financial Accounting Standards Nos. 6, Accounting for Property, Plant, and Equipment, paragraphs 17-20 and 26
Emerging Issues Task Force, Issue No. 89-13

Our current practice with regard to these costs is to … Attached is an excerpt from our accounting manual describing the accounting practice. The issue arose during audit of our FY96 statements and our auditor believes….

In attempting to resolve the issue ourselves, we considered the following options and the support for each option.

Expense these costs — discussion of reasons to expense the costs; for example, the costs do not seem to meet the definition of capitalizable costs as presented in SFFAS No. 6.

Capitalize these costs — discussion of reasons to capitalize the costs; for example, the costs extend the useful life of the asset.

We believe that the majority of Federal reporting entities face this issue. We have informally inquired with XX other entities and determined that XX of those entities expense asbestos removal costs and XX of those entities capitalize these costs.

Please contact Jane Smith, Director of Financial Accounting Policy, at (XXX) XXX-XXXX with any questions regarding this request. Ms. Smith would be willing to serve on a task force if necessary.

Our auditors are ________________ and the point of contact in their office is John Jones. Mr. Jones can be reached at (XXX) XXX-XXXX.

In addition, a list of the individuals from other entities that we contacted is presented below: