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United States Government Accountability Office: 
GAO: 

Testimony: 

Before the Subcommittee on Federal Financial Management, Government 
Information, Federal Services, and International Security, Committee 
on Homeland Security and Governmental Affairs, U.S. Senate: 

For Release on Delivery: 
Expected at 2:30 p.m. EDT:
Thursday, September 15, 2011: 

DOD Financial Management: 

Ongoing Challenges in Implementing the Financial Improvement and Audit 
Readiness Plan: 

Statement of Asif A. Khan, Director:
Financial Management and Assurance: 

GAO-11-932T: 

GAO Highlights: 

Highlights of GAO-11-932T, a testimony before the Subcommittee on 
Federal Financial Management, Government Information, Federal 
Services, and International Security, Committee on Homeland Security 
and Governmental Affairs, U.S. Senate. 

Why GAO Did This Study: 

The Department of Defense (DOD) has initiated several efforts over the 
years to address its long-standing financial management weaknesses and 
ultimately achieve unqualified (clean) opinions on its financial 
statements. In 2005, the DOD Comptroller first issued the Financial 
Improvement and Audit Readiness (FIAR) Plan for improving financial 
management and reporting. In May 2010, the DOD Comptroller issued the 
FIAR Guidance to provide standardized guidance to DOD components for 
developing Financial Improvement Plans (FIP) to implement the FIAR 
Plan. 

GAO’s testimony focuses on (1) progress made by the DOD Comptroller in 
developing and issuing the FIAR Guidance, (2) challenges faced by DOD 
components in implementing the FIAR Guidance, and (3) improvements 
needed in DOD’s oversight and monitoring of FIAR implementation 
efforts. 

This statement is based on four audits that were undertaken at the 
request of this subcommittee and other congressional requesters to 
evaluate the progress DOD is making in implementing its FIAR Plan and 
FIAR Guidance. GAO addresses findings and recommendations from two 
reports being issued this week (GAO-11-830 and GAO-11-851) and 
preliminary information from two ongoing audits. Each audit 
demonstrates some of the challenges DOD faces in improving its 
financial management and achieving the goal of auditable financial 
statements by 2017. 

What GAO Found: 

In a report issued this week, GAO concluded that the FIAR Guidance 
provides a reasonable methodology for the DOD components to follow in 
developing and implementing their FIPs. It details the roles and 
responsibilities of the DOD components, and prescribes a standard, 
systematic process components should follow to assess processes, 
controls, and systems, and identify and correct weaknesses in order to 
achieve auditability. The FIAR Guidance also requires the components 
to prepare and implement corrective action plans for resolving the 
deficiencies identified during testing and to document the results, 
which is consistent with federal internal control standards and 
related guidance. 

DOD’s ability to achieve audit readiness is dependent on the components’
ability to effectively develop and implement FIPs in compliance with 
the FIAR Guidance. However, GAO’s review of various DOD component 
efforts to achieve audit readiness found that the components 
experienced challenges in implementing the FIAR Guidance. Specifically: 

* The Navy and the Air Force had not adequately developed the two FIPs 
that GAO reviewed in accordance with the FIAR Guidance. As a result, 
they did not conduct sufficient control and substantive testing, and 
reached conclusions that were not supported by the testing results. 

* Auditors of the Marine Corps’ Statement of Budgetary Resources (SBR) 
issued a disclaimer of opinion because the Marine Corps did not 
provide timely and relevant supporting documentation for accounting 
transactions and also reported that internal control weaknesses should 
be addressed. 

* GAO’s preliminary work on the Navy’s and Marine Corps’ Fund Balance 
with Treasury (FBWT) reconciliation processes identified issues with 
their ability to reconcile FBWT—a key step in preparing the SBR. 

* Based on preliminary results, GAO identified issues in the 
implementation of two enterprise resource planning (ERP) systems by 
the Army and the Air Force. DOD has acknowledged that effective 
implementation of integrated systems is crucial to achieving 
departmentwide audit readiness. 

Although DOD and its military components had established 
organizational structures for monitoring and oversight of audit 
readiness efforts, GAO found that oversight responsibilities were not 
effectively carried out, resulting in the ineffective implementation 
of FIPs and unsupported conclusions of audit readiness. For the two 
FIPs that GAO reviewed, neither the designated officials nor the 
executive committees took sufficient action to ensure that the FIPs 
complied with the FIAR Guidance. Effective oversight would also help 
ensure that lessons learned from recent efforts would be disseminated 
throughout the department so that others could avoid similar problems. 
For example, the Marine Corps’ SBR audit effort provide valuable 
lessons that, if effectively communicated and implemented, can provide 
a roadmap to help other DOD components achieve audit readiness. GAO 
recommends actions for components to comply with the FIAR Guidance, 
for the Marine Corps to develop appropriate corrective action plans, 
and for DOD to ensure that the services consider lessons learned. DOD 
concurred with GAO’s recommendations related to implementing the 
component FIPs and with three of four recommendations related to the 
Marine Corps SBR. Further details on DOD’s comments can be found in 
GAO’s reports. 

View [hyperlink, http://www.gao.gov/products/GAO-11-932T]. For more 
information, contact Asif A. Khan at (202) 512-9869 or khana@gao.gov. 

[End of section] 

Chairman Carper, Ranking Member Brown, and Members of the Subcommittee: 

It is a pleasure to be here today to discuss the status of the 
Department of Defense's (DOD) efforts to implement its Financial 
Improvement and Audit Readiness (FIAR) Plan to improve its financial 
management operations. Given the federal government's fiscal 
challenges, there is a significant need for transparency and for the 
Congress, the administration, and federal managers to have reliable, 
useful, and timely financial and performance information, particularly 
for the government's largest department. For more than a decade, DOD 
has been on GAO's list of federal programs and operations at high risk 
of being vulnerable to fraud, waste, and abuse.[Footnote 1] Despite 
several reform initiatives, DOD's financial management remains on 
GAO's high-risk list today. Long-standing and pervasive weaknesses in 
DOD's financial management and related business processes and systems 
have (1) resulted in a lack of reliable information needed to make 
sound decisions and report on the financial status and cost of DOD 
activities to Congress and DOD decision makers; (2) adversely affected 
its operational efficiency and mission performance in areas of major 
weapons system support and logistics; and (3) left the department 
vulnerable to fraud, waste, and abuse. In addition, these long-
standing financial management weaknesses have precluded DOD from being 
able to successfully undergo the scrutiny of a financial statement 
audit.[Footnote 2] The National Defense Authorization Act (NDAA) for 
Fiscal Year 2010 mandated that DOD be prepared to validate (certify) 
that its consolidated financial statements are ready for audit by 
September 30, 2017.[Footnote 3] 

In 2005, the DOD Comptroller established the DOD Financial Improvement 
and Audit Readiness (FIAR) Directorate to develop, manage, and 
implement a strategic approach for addressing the department's 
financial management weaknesses and for achieving auditability, and to 
integrate those efforts with other improvement activities, such as the 
department's business system modernization efforts. Also in 2005, the 
DOD Comptroller first issued the FIAR Plan for improving financial 
management and reporting. The NDAA for Fiscal Year 2010 mandated that 
the FIAR Plan include the specific actions to be taken to correct the 
financial management deficiencies that impair the department's ability 
to prepare timely, reliable, and complete financial management 
information. In May 2010, the DOD Comptroller issued the FIAR Guidance 
to provide standardized guidance to DOD components for developing 
Financial Improvement Plans (FIP) to implement the FIAR Plan. In 
September 2010, we reported that the department needed to focus on 
implementing its FIAR Plan and that the key to successful 
implementation would be the efforts of the DOD military components and 
the quality of their individual FIPs.[Footnote 4] 

My testimony today will focus on three key issues: 

(1)progress made by the DOD Comptroller in developing and issuing the 
FIAR Guidance to assist DOD components in implementing the FIAR Plan; 

(2)challenges in the implementation of the FIAR Guidance at the Navy, 
Air Force, and Marine Corps; and: 

(3)improvements needed in DOD's oversight and monitoring of FIAR 
implementation efforts. 

My statement is based on four audits that we have undertaken at the 
request of this subcommittee and other congressional requesters to 
evaluate the progress DOD is making in implementing its FIAR Plan and 
related Guidance. Two of the reports have been issued this week, 
[Footnote 5] and we are addressing preliminary findings for the other 
two reports, which are in process. Each report demonstrates some of 
the challenges DOD faces in improving its financial management, 
including its ability to achieve the goal of reliable financial 
information and auditable financial statements by 2017: 

* The first report discusses the methodology reflected in DOD's FIAR 
Guidance, whether selected military component FIPs adhered to the FIAR 
Guidance, and DOD's oversight and monitoring of the FIP process. 
[Footnote 6] The published report includes details on the scope and 
methodology for this review. 

* The second report addresses why auditors were unable to complete an 
audit of one of DOD's financial statements, the Statement of Budgetary 
Resources (SBR), for one military service, the U.S. Marine Corps. 
[Footnote 7] This report also includes details on the scope and 
methodology for this review. 

* The remaining two ongoing audits address (1) a key process for DOD's 
components--the Fund Balance with Treasury (FBWT) reconciliation-- 
which illustrates one of many of the department's challenges and (2) 
the implementation of comprehensive, integrated business systems 
called Enterprise Resource Planning (ERP) systems,[Footnote 8] which 
DOD considers a key element to improving financial management and 
achieving auditability. We discussed with DOD officials the 
preliminary findings from these two ongoing audits that are included 
in this testimony and considered their comments in this statement. We 
plan to issue these reports in October 2011. 

For our work on the FBWT reconciliation, we analyzed Navy and Marine 
Corps policies and procedures covering the various FBWT reconciliation 
steps, and met with Navy, Marine Corps, and Defense Finance and 
Accounting Service (DFAS) officials, and performed walkthroughs of the 
Navy and Marine Corps FBWT processes. For our work on ERP systems, we 
focused on the status of two systems by reviewing the Army and Air 
Force Test and Evaluation Commands' reports on the systems and 
interviewing various DOD officials, including system users at DFAS. 

Our work was conducted in accordance with generally accepted 
government auditing standards. Those standards require that we plan 
and perform the audit to obtain sufficient, appropriate evidence to 
provide a reasonable basis for our findings and conclusions based on 
our audit objectives. We believe the evidence obtained provides a 
reasonable basis for our findings and conclusions based on our audit 
objectives. 

Background: 

Over the years, DOD has initiated several broad-based reform efforts 
to address its long-standing financial management weaknesses. However, 
as we have reported, those efforts did not achieve their intended 
purpose of improving the department's financial management 
operations.[Footnote 9] The FIAR Plan, which was first prepared in 
2005, is DOD's strategic plan and management tool for guiding, 
monitoring, and reporting on the department's financial management 
improvement efforts. As such, the plan contains an incremental 
approach for addressing the department's financial management 
weaknesses and achieving financial statement auditability. The plan 
focuses on three goals: (1) achieve and sustain assurance on the 
effectiveness of internal controls, (2) develop and implement 
financial management systems that support effective financial 
management, and (3) achieve and sustain financial statement audit 
readiness. 

In August 2009, the DOD Comptroller sought to focus efforts of the 
department and components, in order to achieve certain short-and long- 
term results, by giving priority to improving processes and controls 
that support the financial information most often used to manage the 
department. Accordingly, DOD revised its FIAR strategy and methodology 
to focus on the DOD Comptroller's two priorities--budgetary 
information and asset accountability. The first priority is to 
strengthen processes, controls, and systems that produce DOD's 
budgetary information and the department's SBRs. The second priority 
is to improve the accuracy and reliability of management information 
pertaining to the department's mission-critical assets, including 
military equipment, real property, and general equipment. The DOD 
Comptroller directed the DOD components--including the Departments of 
the Army, Navy, and Air Force and the Defense Logistics Agency--to use 
a standard process to implement the FIAR Plan and aggressively modify 
their activities to support and emphasize achievement of the 
priorities. 

In May 2010, DOD issued a revised FIAR Plan in which it introduced a 
new phased approach toward achieving financial statement auditability. 
This approach consists of five waves (or phases) of concerted 
improvement activities. The first two waves involve budgetary 
information--appropriations received[Footnote 10] and the SBR. 
According to DOD, the components' implementation of the methodology 
described in the May 2010 FIAR Plan is essential to the success of the 
department's efforts to ultimately achieve full financial statement 
auditability.[Footnote 11] 

DOD's FIAR Guidance Provides a Reasonable Methodology: 

Consistent with prior GAO recommendations[Footnote 12] and the NDAA 
for Fiscal Year 2010, DOD issued the FIAR Guidance in May 2010, which 
details the methodology for components to follow in order to achieve 
financial management improvements and auditability. The FIAR Guidance 
requires components to identify and prioritize their processes into 
assessable units.[Footnote 13] For each assessable unit, a component 
is required to prepare a FIP in accordance with the steps outlined in 
the FIAR Guidance. For example, civilian and military pay are two 
assessable units for which each DOD component, such as the Army, Navy, 
and Air Force, must develop and implement plans in accordance with the 
FIAR Guidance to ensure that their civilian and military pay can be 
audited. The steps required for these plans include assessing 
processes, controls, and systems; identifying and correcting 
weaknesses; assessing, validating, and sustaining corrective actions; 
and ultimately achieving audit readiness. After a component completes 
its evaluation of the effectiveness of corrective actions for each 
assessable unit, it must determine whether each assessable unit is 
ready for audit. For example, the Air Force, based on its 
implementation of the FIAR Guidance and its FIP, planned to conclude 
during fiscal year 2011 whether or not its FBWT Reconciliation is 
reliable and ready for audit. Once a component's management determines 
that an assessable unit is ready for audit, the DOD Comptroller and 
DOD Inspector General (IG) must review the related FIP documentation 
to determine if they agree with management's conclusion of audit 
readiness. 

In our report issued this week, we concluded that the FIAR Guidance 
provides a reasonable methodology for the DOD components to follow in 
developing and implementing their FIPs.[Footnote 14] However, as 
described later in this statement, we found that implementation of the 
FIAR Guidance for the two assessable units we reviewed was not 
effective. The FIAR Guidance details the roles and responsibilities of 
the DOD components, and prescribes a standard, systematic process that 
components should follow to assess processes, controls, and systems, 
and identify and correct weaknesses in order to achieve auditability 
for each of their assessable units. Overall, the procedures required 
by the FIAR Guidance are consistent with selected procedures for 
conducting financial statement audits, which include the following: 

* Conducting internal control and substantive testing. Internal 
control testing focuses on assessing the effectiveness of controls 
that would prevent or detect potential misstatements in the financial 
statements. Substantive tests are performed to obtain evidence on 
whether amounts reported on the financial statements are reliable. 

* Reconciling the population of transactions to be tested. To conduct 
internal control and substantive testing, a sample of the data 
transactions is typically selected for testing. An organization must 
be able to identify the complete population of transactions so that a 
sample can be selected and tested. 

* Conducting tests of information systems controls. The components are 
required to identify, document, and test both general and application 
controls for key systems that process transactions. General controls 
[Footnote 15] are the policies and procedures that apply to all or a 
large segment of an entity's information systems and help ensure their 
proper operation. Application controls, sometimes referred to as 
business controls, are incorporated directly into computer 
applications to help ensure the validity, completeness, accuracy, and 
confidentiality of data during application processing and reporting. 

The FIAR Guidance also requires the components to prepare and 
implement corrective action plans for resolving the deficiencies 
identified during testing and to document the results, which is 
consistent with federal internal control standards and Office of 
Management and Budget (OMB) guidance.[Footnote 16] 

Challenges for DOD Components' Implementation of FIAR Guidance: 

Although the FIAR Guidance provides a reasonable methodology for 
improving financial management within the department, DOD's ability to 
achieve audit readiness is highly dependent on the components' ability 
to effectively develop and implement FIPs in compliance with the FIAR 
Guidance. Our reviews of various DOD component efforts to achieve 
audit readiness found that the components faced challenges in 
effectively implementing the FIAR Guidance, resulting in unsupported 
conclusions of audit readiness for Navy Civilian Pay, Air Force 
Military Equipment, and the Marine Corps SBR. Our preliminary work 
also found that a key element of basic financial management--
reconciling the FBWT account--was not being done properly on a regular 
basis and the weaknesses were not properly identified or corrected by 
the Navy or the Marine Corps. Finally, to achieve fundamental 
improvements in financial management, DOD recognizes the importance of 
transforming its business operations through the implementation of 
Enterprise Resource Planning (ERP) systems. Our preliminary work on 
two key ERPs that have been partially deployed found significant 
issues in both systems. 

FIPs for Navy Civilian Pay and Air Force Military Equipment Were 
Incomplete and Ineffective: 

Our review of the FIPs for Navy Civilian Pay and Air Force Military 
Equipment found that neither FIP complied with the FIAR Guidance and 
contained unsupportable conclusions.[Footnote 17] We found similar 
deficiencies in both FIPs, which included the following: 

* The Navy and Air Force did not conduct sufficient control and 
substantive testing, and contained unsupportable conclusions that the 
amounts being reported for Navy Civilian Pay and Air Force Military 
Equipment were reliable. 

* The Navy and Air Force did not complete reconciliations of the 
population of transactions. As a result, the components could not 
ensure that their testing results could be projected to the 
populations of Navy civilian pay transactions and Air Force military 
equipment. 

* The Navy and Air Force did not fully test information systems 
controls. The Navy's system testing did not include essential areas 
such as periodic reviews of user access authorizations and logs of 
changes to security access authorizations. The Air Force's FIP did not 
include any documentation of control testing for the two systems that 
maintain its military equipment data. 

* The Navy and Air Force did not fully develop and implement 
corrective action plans to address deficiencies they identified during 
testing. The Navy had not developed any corrective action plans at the 
time that it incorrectly concluded that its civilian pay was ready for 
audit. The Air Force had developed some plans related to its military 
equipment weaknesses but not for all deficiencies identified, and 
moreover, it had not implemented any of the corrective actions at the 
time that it stated that its military equipment was ready for audit. 
Both components stated that they planned to complete corrective 
actions in the future. 

Because of the deficiencies we identified, neither FIP that we 
reviewed provided sufficient support for the components' conclusions 
that the balances for Navy civilian pay and Air Force military 
equipment were ready for audit. Our report includes recommendations 
for DOD to ensure that components' FIPs comply with the FIAR Guidance. 
Navy officials stated that they were taking action to address the 
issues identified and planned to submit a revised FIP by March 2012. 
Air Force officials also indicated that they were taking action to 
address the issues identified. 

Marine Corps Statement of Budgetary Resources Was Not Auditable: 

After DOD established budgetary information as a priority in its FIAR 
Plan, the Marine Corps was identified as the pilot military service 
for an audit of the SBR. The SBR is designed to provide information on 
authorized budgeted spending authority and links to the Budget of the 
United States Government (President's Budget), including budgetary 
resources, availability of budgetary resources, and how obligated 
resources have been used.[Footnote 18] Because the Marine Corps is a 
military service within the Department of the Navy, its success in 
achieving audit readiness is intended to pave the way for the Navy to 
undergo an SBR audit. However, the DOD IG issued a disclaimer of 
opinion[Footnote 19] on the Marine Corps' fiscal year 2010 SBR because 
the Marine Corps did not provide timely and relevant supporting 
documentation for accounting transactions and disbursements in key 
areas, which prevented the auditors from completing the audit by the 
November 15, 2010, reporting deadline. In addition, the auditors 
reported that ineffective internal control and ineffective controls in 
key financial systems should be addressed to ensure the reliability of 
reported financial information.[Footnote 20] The auditors identified 
70 findings and made 139 recommendations to address the issues. 
Examples of the problems identified include the following: 

* The DFAS location in Cleveland, Ohio, (DFAS-CL)--which performs 
accounting, disbursing, and financial reporting services for the 
Marine Corps--did not have effective procedures in place to ensure 
that supporting documentation for transactions was complete and 
readily available to pass basic audit transaction testing. For 
example, the auditors found that DFAS staff had only retained selected 
pages of the documents supporting payment vouchers, such as the 
voucher cover sheet, and did not have the purchase order, receiving 
report, and the invoice to support payments made. 

* The Marine Corps did not have effective controls in place to support 
estimated obligations, referred to as "bulk obligations," to record a 
payment liability, and, as a result, was not able to reconcile the 
related payment transactions to the estimates. The Marine Corps 
estimates obligations in a bulk amount to record payment liabilities 
where it does not have a mechanism to identify authorizing 
documentation as a basis for recording the obligations. 

* The auditors found ineffective controls over three major information 
technology (IT) systems used by the Marine Corps and reported numerous 
problems that required resolution.[Footnote 22] For example, the 
auditors identified a lack of controls over interfaces between systems 
to ensure completeness of the data being transferred. System interface 
controls are critical for ensuring the completeness and accuracy of 
data transferred between systems. 

Further, in addressing the 70 audit findings and related 139 
recommendations, we found that the Marine Corps did not develop an 
effective overall corrective action plan that identified risks, 
prioritized actions, and identified required resources in order to 
help ensure that actions adequately respond to recommendations. 
[Footnote 21] Instead, its approach to addressing auditor findings and 
recommendations for its prior and current audit efforts focuses on 
short-term corrective actions necessary to support heroic efforts to 
produce reliable financial reporting at year-end. Such efforts may not 
result in sustained improvements over the long term that would help 
ensure that the Marine Corps could routinely produce sound data on a 
timely basis for decision making. While the Marine Corps has 
implemented an extensive SBR remediation effort that is focused on 
individual initiatives to address the 70 audit findings and 139 
related recommendations, such an approach could result in 
inefficiencies and ineffectiveness. As of July 18, 2011, the Marine 
Corps reported that actions on 88 of the 139 recommendations, 
including weaknesses related to accounting and financial reporting and 
IT systems, were fully implemented. However, the completeness and 
effectiveness of the Marine Corps' actions have not yet been tested. 
DOD IG auditors told us that tests performed during the Marine Corps' 
fiscal year 2011 SBR audit effort will determine whether and to what 
extent the problems identified during the fiscal year 2010 SBR audit 
effort have been resolved. They also confirmed that as of August 25, 
2011, the Marine Corps had remediated the problems on 11 of the IT 
audit recommendations. 

Furthermore, as described in our report being released this week, we 
found that the design of many of the Marine Corps actions relied on 
monitoring, a detective control; high-level initial fixes that did not 
address root causes; and other actions that were not consistent with 
the related auditors' recommendations.[Footnote 23] For example: 

* Marine Corps remediation actions for 22 of the 56 accounting and 
financial reporting recommendations rely on issuing guidance, 
monitoring, or both, in an attempt to quickly address identified 
weaknesses. However, correcting underlying causes requires process 
improvements and in some cases, system changes. 

* Remediation actions for 20 of the 139 recommendations were not 
consistent with the related recommendations. For example, the auditors 
identified unliquidated obligations on old contracts for which 
performance was substantially complete. The auditors found that the 
Marine Corps did not have an effective process for reviewing 
undelivered orders and unliquidated obligations, and recommended that 
they strengthen these controls, whose weaknesses were the root cause 
of the finding. In response, Marine Corps officials stated that they 
had implemented a robust review process for validating obligations. 
However, the auditors reported that the Marine Corps developed 
effective written procedures but found problems with the 
implementation of those procedures. Thus, the Marine Corps did not 
fully address the recommendation or root cause of the problem. 

* The Marine Corps disagreed with six auditor recommendations to 
strengthen SABRS system controls over information processing. For 
example, for three recommendations related to password and log-on 
controls, the Marine Corps action states that the Defense Information 
System Agency (DISA) and not DFAS is responsible for the actions. 
However, Marine Corps officials told us they had not contacted DISA 
officials to ensure that they would address the recommendations. 

Our report includes recommendations to the Secretary of the Navy to 
direct the Marine Corps to develop a comprehensive, risk-based 
corrective action plan, confirm that corrective actions fully address 
auditor findings, and work more closely with service providers, such 
as DFAS, to clarify their roles and responsibilities on corrective 
actions that require cross-component work. In commenting on our 
report, the Navy said that it is working to address the auditor-
identified deficiencies. Further details on the Navy's comments and 
our evaluation of them can be found in our report. 

Issues with Navy and Marine Corps Processes for Reconciling Fund 
Balance with Treasury (FBWT): 

Reconciling the FBWT account is a key financial management control. 
FBWT is an asset account that reflects the available budget spending 
authority of federal agencies. Reconciling a FBWT account with 
Treasury records is a process similar in concept to reconciling a 
check book with a bank statement. However, within the large, complex 
DOD environment, the FBWT reconciliation involves reconciliations 
between several different systems, such as the DOD components' general 
ledgers, the DOD-wide general ledger, DOD's cash accountability 
system, and Treasury records. FBWT reconciliations are a key internal 
control for ensuring that all receipt and disbursement transactions 
have been properly recorded in federal agency accounting records. 
Effective fund balance reconciliations serve as a detective control 
for identifying unauthorized and unrecorded transactions at a federal 
agency or at the U.S. Treasury. 

A successful audit of the SBR is dependent on an auditable FBWT, which 
includes the ability to reconcile the FBWT account with the Treasury 
records. However, our preliminary work has identified issues with the 
Navy and Marine Corps' implementation of effective processes for 
reconciling their FBWT, including issues related to financial 
management systems and certain policies and procedures, training, and 
supervisory review and approval. For example: 

* DOD has not tested application controls over the Defense Cash 
Accountability System (DCAS)--the department's system of record for 
all cash activity. Navy, Marine Corps, and DFAS officials stated that 
they have identified over 650 system deficiencies that affect DCAS 
data reliability, and that over 200 of the identified deficiencies 
affect audit readiness. They identified the top 20 deficiencies that 
require immediate attention; however, they stated that a time frame 
for addressing these top 20 issues had not yet been established. 

* DFAS did not maintain adequate documentation for the sample of items 
we tested to enable an independent evaluation of its efforts to 
research and resolve differences. 

* Navy and DFAS policies and procedures did not contain detailed 
information on the roles and responsibilities of organizations and 
personnel and the process for identifying, researching, and resolving 
discrepancies, including maintaining required supporting 
documentation. The policies and procedures also did not require 
supervisory review and approval of reconciliation efforts and results. 

Navy, Marine Corps, and DFAS officials acknowledged that existing 
policies and procedures are inadequate. They also stated that the base 
realignment and closure changes in 2006 through 2008 resulted in a 
loss of experienced DFAS-CL personnel and that the remaining staff 
have not received the needed training. Navy officials stated that they 
are currently developing a Plan of Actions and Milestones (POAM) to 
address weaknesses that affect the Navy and Marine Corps' audit 
readiness, including reconciling FBWT records. 

We will report more fully on these issues, including actions DOD is 
taking to address them, in our forthcoming report. 

Issues with Implementation of Two of DOD's Enterprise Resource 
Planning (ERP) Systems: 

The implementation of an integrated, audit-ready systems environment 
through the deployment of ERP systems underlies all of DOD's financial 
improvement efforts and is crucial to achieving departmentwide audit 
readiness. According to DOD, the successful implementation of the ERPs 
is not only critical for addressing long-standing weaknesses in 
financial management, but equally important for helping to resolve 
weaknesses in other high-risk areas such as business transformation, 
business system modernization, and supply chain management. Successful 
implementation will support DOD by standardizing and streamlining its 
financial management and accounting systems, integrating multiple 
logistics systems and finance processes, providing asset visibility 
for accountable items, and integrating personnel and pay systems. 
Previously, we reported that delays in the successful implementation 
of ERPs have extended the use of existing duplicative, stovepiped 
systems, and have continued the funding of these systems longer than 
anticipated.[Footnote 24] To the degree that these business systems do 
not provide the intended capabilities, DOD's goal of departmentwide 
audit readiness by the end of fiscal year 2017 could be jeopardized. 

Over the years, we have reported that DOD has not effectively employed 
management controls to ensure that the development and implementation 
of ERPs deliver the promised capabilities on time and within budget. 
As we reported in October 2010, DOD has identified 10 ERPs--1 of which 
had been fully implemented--as essential to its efforts to transform 
its business operations.[Footnote 25] We are currently reviewing the 
status of two of these ERPs--the Army's General Fund Enterprise 
Business System (GFEBS) and the Air Force's Defense Enterprise 
Accounting and Management System (DEAMS). GFEBS is intended to support 
the Army's standardized financial management and accounting practices 
for the Army's general fund, except for funds related to the Army 
Corps of Engineers. The Army estimates that GFEBS will be used to 
control and account for approximately $140 billion in annual spending. 
DEAMS is intended to provide the Air Force with the entire spectrum of 
financial management capabilities and is expected to maintain control 
and accountability for approximately $160 billion. GFEBS is expected 
to be fully deployed during fiscal year 2012, is currently operational 
at 154 locations, including DFAS, and is being used by approximately 
35,000 users. DEAMS is expected to be fully deployed during fiscal 
year 2016, is currently operational at Scott Air Force Base and DFAS, 
and is being used by about 1,100 individuals. 

Our preliminary results identified issues related to GFEBS and DEAMS 
providing DFAS users with the expected capabilities in accounting, 
management information, and decision support. To compensate, DFAS 
users have devised manual workarounds and several applications to 
obtain the information they need to perform their day-to-day tasks. 
The Army and Air Force have stated that they have plans to address 
these issues, and the Army has plans to validate the audit readiness 
of GFEBS in a series of independent auditor examinations over the next 
several fiscal years. For DEAMS, the DOD Milestone Decision Authority 
[Footnote 26] (MDA) has directed that the system is not to be deployed 
beyond Scott Air Force Base until the known system weaknesses have 
been corrected and the system has been independently tested to ensure 
that it is operating as intended. Examples of the issues in these 
systems that DFAS users have identified include the following: 

GFEBS: 

* The backlog of unresolved GFEBS trouble tickets has continued to 
increase from about 250 in September 2010 to approximately 400 in May 
2011. Trouble tickets represent user questions and issues with 
transactions or system performance that have not been resolved. 
According to Army officials, this increase in tickets was not 
unexpected since the number of users and the number of transactions 
being processed by the system has increased, and the Army and DFAS are 
taking steps to address issues raised by DFAS. 

* Approximately two-thirds of invoice and receipt data must be 
manually entered into GFEBS from the invoicing and receiving system 
(i.e., Wide Area Work Flow).[Footnote 27] DFAS personnel stated that 
manual data entry will eventually become infeasible due to increased 
quantities of data that will have to be manually entered as GFEBS is 
deployed to additional locations. Army officials acknowledged that 
there is a problem with the Wide Area Work Flow and GFEBS interface 
and that this problem reduced the effectiveness of GFEBS, and that 
they are working with DOD to resolve the problem. 

* GFEBS lacks the ability to run ad hoc queries or search for data in 
the system to resolve problems or answer questions.[Footnote 28] The 
Army has recognized this limitation and is currently developing a 
system enhancement that they expect will better support the users' 
needs. 

DEAMS: 

* Manual workarounds are needed to process certain accounts receivable 
transactions such as travel debts. DFAS personnel stated that the 
problem is the result of the data not being properly converted from 
the legacy systems to DEAMS. 

* DFAS officials indicated that they were experiencing difficulty with 
some of the DEAMS system interfaces.[Footnote 29] For example, the 
interface problem with the Standard Procurement System has become so 
severe that the interface has been turned off, and the data must be 
manually entered into DEAMS. 

* DFAS officials stated that DEAMS does not provide the capability-- 
which existed in the legacy systems--to produce ad hoc reports that 
can be used to perform the data analysis need to perform daily 
operations.[Footnote 30] They also noted that when some reports are 
produced, the accuracy of those reports is questionable. 

DFAS users also told us that the training they received focused more 
on how GFEBS and DEAMS were supposed to operate, rather than providing 
DFAS personnel training about how to use these systems to perform 
their day-to-day operations. The Army acknowledged that from a DFAS 
perspective, the training should have shown DFAS how they could use 
GFEBS to perform task such as the reconciliation of accounts. To help 
address this training issue, DFAS is in the process of developing 
courses and desk guides suitable for DFAS employees who use GFEBS and 
DEAMS on a day-to-day basis. 

We will report more fully on these issues, including DOD's actions to 
address them, in our forthcoming report. 

Improved Monitoring and Oversight of Component Financial Improvement 
Plans (FIP) Are Needed: 

In one report we issued this week, we found that weaknesses in the 
Navy and Air Force FIAR Plan implementation efforts indicate that the 
monitoring and oversight of such efforts have not been effective. 
[Footnote 31] Although we found that DOD and its military components 
had established appropriate organizational structures for monitoring 
and oversight of audit readiness efforts, oversight responsibilities 
were not always effectively carried out. Both DOD and the components 
have established senior executive committees as well as designated 
officials at the appropriate levels to monitor and oversee their 
financial improvement efforts. These committees and individuals have 
also generally been assigned appropriate roles and responsibilities. 
However, we found that component officials as well as the oversight 
committees at both the component and DOD levels did not effectively 
carry out their monitoring responsibilities for the Navy Civilian Pay 
and Air Force Military Equipment FIPs. Specifically, for these two 
FIPs that we reviewed, neither individual officials nor the executive 
committees took sufficient action to ensure that the FIPs were 
accurate or complied with the FIAR Guidance. As a result, the Navy 
concluded that its Civilian Pay was ready for audit, as did the Air 
Force with respect to its Military Equipment, even though they did not 
have sufficient support to assert audit readiness. 

On the other hand, once the Navy and Air Force submitted the FIPs to 
DOD in support of their audit readiness assertions, both the DOD 
Office of the IG and the DOD Comptroller carried out their 
responsibilities for reviewing the FIPs. In their reviews, both 
organizations identified issues with the FIPs that were similar to 
those we had identified. The DOD Comptroller, who makes the final 
determination as to whether an assessable unit is ready for audit, 
concluded that neither of these FIPs supported audit readiness. 

Effective oversight and monitoring would also help ensure that lessons 
learned from recent efforts would be sufficiently disseminated 
throughout the department and applied to other financial improvement 
efforts. In commenting on our report about the FIPs, the DOD 
Comptroller stated that it is critical that the department continues 
to look at how effectively it applies lessons learned. For example, 
the results of the Marine Corps' SBR audit effort provide valuable 
lessons on preparing for a first-time financial statement audit. As we 
recently testified, lessons learned from this audit effort can provide 
a roadmap to help other DOD components achieve audit readiness. 
[Footnote 32] While this audit effort provided numerous issues for the 
other military services to consider in their audit readiness efforts, 
we identified and reported on five overall lessons that are critical 
to success.[Footnote 33] Specifically, the Marine Corps' SBR 
experience demonstrated that prior to asserting financial statement 
audit readiness, DOD components must be able to perform the following 
procedures; 

* Confirm completeness of populations of transactions and address any 
abnormal transactions and balances. The Marine Corps SBR auditors made 
multiple requests for transaction-level detail for key SBR accounts. 
Navy officials told us that they identified problems with the way 
transactions map to general ledger accounts, which makes it difficult 
to identify transaction populations. Navy officials noted that these 
problems impeded the Marine Corps SBR audit effort and also prevent 
the reconciliation of Unadjusted to Adjusted Trial Balances, FBWT 
reconciliations, and overall funds control. 

* Test beginning balances. A first-year SBR audit requires substantial 
testing to confirm beginning balances. Navy officials noted that 
earlier audit readiness efforts were not sufficient to confirm 
beginning balances, and problems identified with the assignment of 
general ledger account numbers and mapping of transactions to the 
proper accounts will need to be resolved to ensure the auditability of 
beginning balances. 

* Perform key reconciliations. The Marine Corps did not have processes 
in place to reconcile key accounts such as FBWT. In addition, although 
it made repeated attempts to reconcile the Unadjusted Trial Balance to 
the Adjusted Trial Balance, it was not able to do so. This 
reconciliation is an important step to verify that the SBR is accurate. 

* Provide timely and complete response to audit documentation 
requests. The auditors reported that the Marine Corps, through its 
service provider, DFAS, did not consistently provide timely and 
accurate audit documentation. Without such documentation, the auditors 
were unable to determine whether a given transaction was authorized, 
whether the goods or services were received, whether the invoice was 
approved for payment, or whether the funds disbursed were correct. 

* Verify that key IT systems are compliant and auditable.[Footnote 34] 
The auditors informed the Marine Corps of numerous control weaknesses 
they identified in key systems, including some DOD-wide systems, which 
affected auditability. The auditability of key systems, including 
military payroll systems, accounting systems, and financial reporting 
systems, is essential to achieving and sustaining an audit opinion. 

These five critical lessons from the Marine Corps SBR audit effort are 
all addressed in the FIAR Guidance as procedures that must be 
performed before an assessable unit can be considered ready for audit. 
As the Army, Navy, and Air Force move forward in developing and 
implementing their FIPs, in our report we recommend that they take 
into account the lessons learned during the course of pilot audit 
efforts, such as the Marine Corps SBR. Navy financial management 
officials indicated that they are aware of the Marine Corps lessons 
and that they are updating their audit readiness plan to address all 
five critical lessons. Army and Air Force officials indicated their 
awareness of some of these findings but only provided information on 
their efforts regarding FBWT reconciliations and ERP implementations. 
As noted above, DOD generally agreed with the need to effectively 
communicate lessons learned among its components. Our report more 
fully describes DOD's comments and our evaluation of them. 

Concluding Observations: 

With the FIAR Plan and related FIAR Guidance, DOD has established a 
reasonable strategy and methodology for improving its financial 
management. However, it faces considerable implementation challenges 
and has much work to do if it is to meet the goal of audit readiness 
by the end of fiscal year 2017. These challenges, as we have 
previously testified, include (1) maintaining committed and sustained 
leadership; (2) developing and implementing an effective plan to 
correct internal control weaknesses; (3) establishing accountability 
and effective oversight to monitor progress; and (4) successfully 
implementing ERP systems consistent with an effective corporate 
enterprise architecture.[Footnote 35] It is critical that DOD's 
current initiatives be continued and provided with sufficient 
resources. Oversight and monitoring will also play a key role in 
ensuring that DOD's plans are implemented as intended and that lessons 
learned are identified and effectively disseminated. Absent continued 
momentum and necessary future investments, the current initiatives may 
falter, similar to previous efforts. Continued congressional oversight 
will be an important factor in helping to ensure the department's 
success. 

Chairman Carper, Ranking Member Brown, and members of the 
Subcommittee, this completes my prepared statement. I would be pleased 
to respond to any questions that you may have at this time. 

GAO Contacts and Staff Acknowledgments: 

If you or your staff have any questions about this testimony please 
contact me at (202) 512-9869 or khana@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this testimony. GAO staff who made key contributions 
to this testimony included Abe Dymond, Assistant Director; Francine 
Delvecchio; Kristi Karls; Sheila Miller; Heather Rasmussen; and David 
Yoder. 

[End of section] 

Footnotes: 

[1] DOD bears responsibility, in whole or in part, for 14 of the 30 
federal programs or activities that GAO has identified as being at 
high risk of waste, fraud, abuse, and mismanagement. The seven 
specific DOD high-risk areas are (1) approach to business 
transformation, (2) business systems modernization, (3) contract 
management, (4) financial management, (5) supply chain management, (6) 
support infrastructure management, and (7) weapon systems acquisition. 
The seven governmentwide high-risk areas that include DOD are: (1) 
disability programs, (2) interagency contracting, (3) information 
systems and critical infrastructure, (4) information sharing for 
homeland security, (5) human capital, (6) real property, and (7) 
ensuring the effective protection of technologies critical to U.S. 
national security interests. 

[2] DOD's auditors have reported material financial management 
weaknesses in the following areas: (1) Financial Management Systems, 
(2) Fund Balance with Treasury, (3) Accounts Receivable, (4) 
Inventory, (5) Operating Materials and Supplies, (6) General Property, 
Plant, and Equipment, (7) Government-Furnished Material and Contractor-
Acquired Material, (8) Accounts Payable, (9) Environmental 
Liabilities, (10) Statement of Net Cost, (11) Intragovernmental 
Eliminations, (12) Other Accounting Entries, and (13) Reconciliation 
of Net Cost of Operations to Budget. 

[3] Pub. L. No. 111-84, div. A, § 1003(a), (b), 123 Stat. 2190, 2439-
40 (Oct. 28, 2009). 

[4] GAO, Department of Defense: Financial Management Improvement and 
Audit Readiness Efforts Continue to Evolve, [hyperlink, 
http://www.gao.gov/products/GAO-10-1059T] (Washington, D.C.: Sept. 29, 
2010). 

[5] GAO, DOD Financial Management: Improvement Needed in DOD 
Components' Implementation of Audit Readiness Efforts, GAO-11-851 
(Washington, D.C.: Sept. 13, 2011); and DOD Financial Management: 
Marine Corps Statement of Budgetary Resources Audit Results and 
Lessons Learned, [hyperlink, http://www.gao.gov/products/GAO-11-830] 
(Washington, D.C.: Sept. 15, 2011). 

[6] [hyperlink, http://www.gao.gov/products/GAO-11-851]. 

[7] [hyperlink, http://www.gao.gov/products/GAO-11-830]. 

[8] An ERP solution is an automated system using commercial off-the- 
shelf (COTS) software consisting of multiple, integrated functional 
modules that perform a variety of business-related tasks, such as 
general ledger accounting, payroll, and supply chain management. 

[9] GAO, Financial Management: Achieving Financial Statement 
Auditability in the Department of Defense, [hyperlink, 
http://www.gao.gov/products/GAO-09-373] (Washington, D.C.: May 6, 
2009); DOD Financial Management: Integrated Approach, Accountability, 
Transparency, and Incentives Are Keys to Effective Reform, [hyperlink, 
http://www.gao.gov/products/GAO-02-537T] (Washington, D.C.: Mar. 20, 
2002); Defense Management: Actions Needed to Sustain Reform 
Initiatives and Achieve Greater Results, [hyperlink, 
http://www.gao.gov/products/GAO/NSIAD-00-72] (Washington, D.C.: July 
25, 2000). 

[10] "Appropriations received" is an element of the SBR that 
represents appropriated funds made available for use by DOD components. 

[11] As we have reported 
[hyperlink, http://www.gao.gov/products/GAO-11-851], the department 
has not yet fully defined its strategy for completing all actions 
necessary to achieve the FIAR goals, including actions related to the 
auditability of most of the department's consolidated financial 
statements such as the Balance Sheet and the Statement of Net Cost, 
and significant audit areas such as equipment valuation. 

[12] [hyperlink, http://www.gao.gov/products/GAO-09-373]. 

[13] An assessable unit can be any part of the financial statements, 
such as a line item or a class of assets (e.g., civilian pay or 
military equipment), a class of transactions, or it can be a process 
or a system that helps produce the financial statements. 

[14] [hyperlink, http://www.gao.gov/products/GAO-11-851]. 

[15] The objectives of general controls include safeguarding data, 
protecting application programs, and ensuring continued computer 
operations in case of unexpected interruptions. 

[16] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999); and OMB Circular No. A-123, 
Appendix A, Internal Control Over Financial Reporting. 

[17] [hyperlink, http://www.gao.gov/products/GAO-11-851]. 

[18] Budgetary resources include the amount available to enter into 
new obligations and to liquidate them. Budgetary resources are made up 
of new budget authority (including direct spending authority provided 
in existing statute and obligation limitations) and unobligated 
balances of budget authority provided in previous years. 

[19] In a disclaimer of opinion, the auditor does not express an 
opinion on the financial statements. A disclaimer of opinion is 
appropriate when the audit scope is not sufficient to enable the 
auditor to express an opinion, or when there are material 
uncertainties involving a scope limitation--a situation where the 
auditor is unable to obtain sufficient appropriate audit evidence. 

[20] Internal control comprises the plans, methods, and procedures to 
provide reasonable assurance that objectives are being achieved in the 
following areas: (1) effectiveness and efficiency of operations, (2) 
reliability of financial reporting, and (3) compliance with applicable 
laws and regulations. 

[21] Some of these elements are consistent with the FIAR Guidance 
requirements for a corrective action plan, such as identifying 
required resources and ensuring that actions address the identified 
deficiencies. 

[22] The three systems are the Marine Corps Total Force System 
(MCTFS), which is an integrated military personnel and payroll system; 
the Standard Accounting, Budgeting, Reporting System (SABRS), which is 
the Marine Corps' general ledger accounting system; and the Defense 
Departmental Reporting System (DDRS), which is a DOD-wide financial 
reporting system. 

[23] [hyperlink, http://www.gao.gov/products/GAO-11-830]. 

[24] GAO, DOD Business Transformation: Improved Management Oversight 
of Business System Modernization Efforts Needed, [hyperlink, 
http://www.gao.gov/products/GAO-11-53] (Washington, D.C.: Oct. 7, 
2010). 

[25] [hyperlink, http://www.gao.gov/products/GAO-11-53]. The 10 ERPs 
are as follows: Army--General Fund Enterprise Business System (GFEBS), 
Global Combat Support System-Army (GCSS-Army), and Logistics 
Modernization Program (LMP); Navy--Navy Enterprise Resource Planning 
(Navy ERP) and Global Combat Support System-Marine Corps (GCSS-MC); 
Air Force--Defense Enterprise Accounting and Management System (DEAMS) 
and Expeditionary Combat Support System (ECSS); Defense--Service 
Specific Integrated Personnel and Pay Systems and Defense Agencies 
Initiative (DAI); and Defense Logistics Agency--Business System 
Modernization (BSM). According to DOD, BSM was fully implemented in 
July 2007. 

[26] The Milestone Decision Authority is the senior DOD official who 
has overall authority to approve entry of an acquisition program into 
the next phase of the acquisition process and is accountable for cost, 
schedule, and performance reporting, including congressional reporting. 

[27] Office of Federal Financial Management, Core Financial System 
Requirements (Washington, D.C.: January 2006) states that a Core 
financial system must deliver workflow capabilities including 
integrated workflow, workflow process definition and processing 
exception notices. 

[28] Office of Federal Financial Management, Core Financial System 
Requirements state a Core financial system must provide an integrated 
ad hoc query capability to support agency access to and analysis of 
system-maintained financial data. 

[29] Office of Federal Financial Management, Core Financial System 
Requirements state that a Core financial system financial transactions 
can be originated using multiple external feeder applications. These 
feeder systems and the Core financial system must interface seamlessly 
so that data can move effectively between them. The Core system must 
be able to process and validate the data independent of origination. 
There must also be a process for handling erroneous input and 
correction." 

[30] Office of Federal Financial Management, Core Financial System 
Requirements state that a Core financial system financial transactions 
must deliver an integrated ad hoc query capability to support agency 
access to and analysis of system maintained financial data. 

[31] [hyperlink, http://www.gao.gov/products/GAO-11-851]. 

[32] GAO, DOD Financial Management: Numerous Challenges Must Be 
Addressed to Achieve Auditability, [hyperlink, 
http://www.gao.gov/products/GAO-11-864T] (Washington, D.C.: July 28, 
2011). 

[33] [hyperlink, http://www.gao.gov/products/GAO-11-830]. 

[34] DOD financial management systems are required by the Federal 
Financial Management Improvement Act of 1996 (FFMIA) to comply with 
federal financial management systems, applicable federal accounting 
standards, and the United States Government Standard General Ledger at 
the transaction level. Pub. L. No. 104-208, div. A, title VIII, § 803, 
110 Stat. 3009, 3009-390 (Sept. 30, 1996). 

[35] [hyperlink, http://www.gao.gov/products/GAO-11-835T]; [hyperlink, 
http://www.gao.gov/products/GAO-11-864T]. 

[End of section] 

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