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entitled 'Financial Audit: Restatement to the General Services 
Administration's Fiscal Year 2003 Financial Statements' which was 
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December 6, 2005: 

Ms. Kathleen M. Turco: 
Chief Financial Officer: 
General Services Administration: 

The Honorable Brian D. Miller: 
Inspector General: 
General Services Administration: 

Subject: Financial Audit: Restatement to the General Services 
Administration's Fiscal Year 2003 Financial Statements: 

As you know, the Secretary of the Treasury, in coordination with the 
Director of the Office of Management and Budget (OMB), is required to 
annually prepare and submit audited financial statements of the U.S. 
government to the President and Congress. We are required to audit 
these consolidated financial statements (CFS) and report on the results 
of our work.[Footnote 1] An issue meriting concern and close scrutiny 
that emerged during our fiscal year 2004 CFS audit was the growing 
number of Chief Financial Officers (CFO) Act agencies that 
restated[Footnote 2] certain of their financial statements for fiscal 
year 2003 to correct errors.[Footnote 3] Errors in financial statements 
can result from mathematical mistakes, mistakes in the application of 
accounting principles, or oversight or misuse of facts that existed at 
the time the financial statements were prepared. Frequent restatements 
to correct errors can undermine public trust and confidence in both the 
entity and all responsible parties. Further, when restatements do 
occur, it is important that financial statements clearly communicate, 
and readers of the restated financial statements understand, that the 
financial statements originally issued by management in the previous 
year and the opinion thereon should no longer be relied on and instead 
the restated financial statements and related auditor's opinion should 
be used. 

Eleven of the 23 CFO Act agencies[Footnote 4] restated certain of their 
financial statements for fiscal year 2003. Five CFO Act agencies had 
restatements in fiscal year 2003 covering their fiscal year 2002 
financial statements. Three CFO Act agencies had restatements covering 
both years. We noted that the extent of the restatements to CFO Act 
agencies' fiscal year 2003 financial statements varied from agency to 
agency, ranging from correcting two line items on one agency's balance 
sheet to correcting numerous line items on several of another agency's 
financial statements. In some cases, the net operating results of the 
agency were affected by the restatement. The amounts of the agencies' 
restatements ranged from several million dollars to more than $91 
billion. 

Nine of the 11 agencies that had restatements for fiscal year 2003 
received unqualified opinions on their originally issued fiscal year 
2003 financial statements. The auditors for 6 of these 9 agencies 
issued unqualified opinions on the restated financial statements, 
replacing the previous unqualified opinions on the respective agencies' 
original fiscal year 2003 financial statements. The auditors for 2 of 
these 9 withdrew their unqualified opinions on the fiscal year 2003 
financial statements and issued other than unqualified opinions on the 
respective agencies' restated fiscal year 2003 financial statements 
because they could not determine whether there were any additional 
misstatements and the effect of any such misstatements on the restated 
fiscal year 2003 financial statements. For the remaining agency, the 
principal auditor of the agency's fiscal year 2004 financial statements 
was not the principal auditor of the agency's fiscal year 2003 
financial statements, and an audit opinion on the agency's restated 
fiscal year 2003 financial statements was not issued. 

Our review focused on the 9 agencies with restatements for fiscal year 
2003 that received unqualified opinions on their originally issued 
fiscal year 2003 financial statements.[Footnote 5] These were the 
Department of Agriculture, Department of State, Department of Justice, 
Department of Transportation, Department of Health and Human Services, 
General Services Administration (GSA), National Science Foundation, 
Nuclear Regulatory Commission, and Office of Personnel Management. 

Because of the varying nature and circumstances surrounding the 
restatements, we are issuing a number of separate reports on the 
matter. This report communicates our observations regarding GSA's 
fiscal year 2003 restatement. Going forward, we hope that the lessons 
learned from the fiscal year 2003 restatement, together with our 
recommendations, will help GSA and its auditor avoid the need for 
restatements to GSA's future financial statements. 

We reviewed four key areas with respect to the restatement of GSA's 
fiscal year 2003 financial statements: (1) the nature and cause of the 
errors that necessitated the restatement, including planned corrective 
actions by the agency and its auditors; (2) the timing of communicating 
the material misstatement to users of the financial statements; (3) the 
extent of transparency[Footnote 6] exhibited in disclosing the nature 
and impact of the material misstatement in the financial statements and 
the reissued auditor's report; and (4) audit issues that contributed to 
the failure to detect the errors that necessitated the restatement 
during the audit of the agency's fiscal year 2003 financial statements. 

Results in Brief: 

Improperly transferring costs related to one major construction project 
out of the Construction in Process (CIP)[Footnote 7] account and into 
the Buildings account led to the material misstatement that 
necessitated the restatement of two separate and distinct line items on 
GSA's originally issued fiscal year 2003 Balance Sheet. Specifically, 
at fiscal year 2003 year end, GSA recorded an adjusting journal entry 
to transfer about $952 million of construction costs from the CIP 
account to the Buildings account. This amount was derived based on a 
statistical sample of construction projects included in GSA's 
unadjusted year-end balance for the CIP account. The largest project 
included in GSA's statistical sample was a multiphase project totaling 
about $68.6 million, which was incorrectly classified as substantially 
complete[Footnote 8] at that time. This incorrect classification, when 
projected to the population of CIP projects, was the basis for about 
$921 million of the $952 million, or over 96 percent, of the estimated 
costs transferred at year end. 

GSA's auditor did not detect the error because its fiscal year 2003 
audit tests were not adequately designed to test the validity of GSA's 
transfers of construction costs between the two accounts. Although the 
journal entry used to record the transfer between the accounts involved 
a material amount and GSA's contracted independent public accountant 
(IPA) had reported a reportable condition relating to CIP transfers in 
its previous two years audit reports, in our view, the IPA did not 
adequately understand the significant components underlying this 
journal entry. As a result, the IPA randomly selected 10 projects from 
GSA's statistical sample of 99 projects and did not review the above 
noted project that GSA had incorrectly classified. Further, in our 
view, the title of GSA's note disclosure of the restatement could be 
misinterpreted. 

We are recommending that GSA's CFO ensures that GSA fully and 
effectively implements control procedures to properly transfer costs 
from the CIP account to the Buildings account. We are also making a 
recommendation to GSA's Inspector General to work with the IPA so that 
audit procedures to sufficiently test for any similar errors in the 
transfer of amounts from the CIP account to the Buildings account in 
the future are implemented. 

GSA, along with its Inspector General concurred with our 
recommendations for ensuring reliable balances in the CIP and Buildings 
accounts. In separate responses on a draft of this report, they 
described the accounting and auditing procedures planned to avoid 
similar restatements of this nature in the future. 

Background: 

In conducting the fiscal year 2004 audit of the CFS, we reviewed the 23 
CFO Act agencies' performance and accountability reports for possible 
restatements and identified 11 agencies that had restated certain of 
their audited fiscal year 2003 financial statements. 

The primary intended users of federal agencies' financial reports are 
citizens, Congress, federal executives, and federal program 
managers.[Footnote 9] Each of these groups may use federal agencies' 
financial statements to satisfy their specific needs. Citizens are 
interested in many aspects of the federal government, particularly 
federal programs that affect their financial well-being. Congress is 
interested in monitoring and assessing the efficiency and effectiveness 
of federal programs. Federal executives, such as central agency 
officials at OMB and the Department of the Treasury (Treasury), are 
interested in federal financial statements to assist the President of 
the United States. OMB assists the President in overseeing the 
preparation of the federal budget by formulating the President's 
spending plans, evaluating the effectiveness of agency programs, 
assessing competing funding demands among agencies, and setting funding 
priorities. Treasury assists the President in managing the finances of 
the federal government and prepares the CFS, which is based on audited 
financial statements prepared by federal agencies. GAO audits the CFS 
and reports on the results of its audit. Finally, federal program 
managers use agency financial statements as tools for managing their 
operations within the limits of the spending authority granted by 
Congress. 

The primary accounting and auditing standards that apply to restatement 
disclosures by federal entities are the Federal Accounting Standards 
Advisory Board's Statement of Federal Financial Accounting Standards 
(SFFAS) No. 21, Reporting Corrections of Errors and Changes in 
Accounting Principles, and the American Institute of Certified Public 
Accountants (AICPA) Codification of Auditing Standards, AU section 561, 
Subsequent Discovery of Facts Existing at the Date of the Auditor's 
Report.[Footnote 10] 

Objective, Scope, and Methodology: 

The objective of our review of the restatement of GSA's fiscal year 
2003 financial statements was to determine the nature and cause of the 
errors, the transparency and timing of communicating the material 
misstatements, any audit issues relating to such misstatements, and any 
actions being taken to help preclude similar errors from occurring in 
the future. 

We reviewed the nature and causes of the restatement, and we also 
examined corrective action plans to be implemented by GSA to help 
preclude similar errors from occurring in the future. We interviewed 
the preparers and auditors of GSA's fiscal year 2003 financial 
statements, including staff from the agency's Office of Inspector 
General (OIG), and we obtained and reviewed relevant audit 
documentation. Our work was not designed to and we did not test the 
accuracy or appropriateness of the restatement. 

In our review, we considered certain accounting and auditing standards, 
including SFFAS No. 21; the Financial Accounting Standards Board's 
Statement of Financial Accounting Standards No. 16, Prior Period 
Adjustments; and the AICPA Codification of Auditing Standards, AU 
section 420, Consistency of Application of Generally Accepted 
Accounting Principles, AU section 508, Reports on Audited Financial 
Statements, and AU section 561. 

We performed our review of the restatement of GSA's fiscal year 2003 
financial statements from December 2004 to October 2005 in accordance 
with U.S. generally accepted government auditing standards. 

We requested comments on the draft of this report from GSA's CFO and 
Inspector General or their designees. Written comments from GSA's 
Acting Administrator and Inspector General are reprinted in enclosures 
I and II, respectively, and are also discussed in the Agency Comments 
section. 

Issues Related to Restatement of GSA's Fiscal Year 2003 Balance Sheet: 

With respect to the restatement of GSA's fiscal year 2003 Balance 
Sheet, we identified the following three areas that need improvement: 
(1) identification of substantially complete CIP transfers, (2) design 
of audit procedures relating to adjusting journal entries used to 
transfer amounts from the CIP account, and (3) the title of the note 
disclosure of the restatement. These issues are discussed in detail 
below. 

Adjustment to CIP and Buildings Accounts Were Erroneous: 

GSA's Balance Sheet for fiscal year 2003 was restated because of an 
error in the adjusting journal entry that was used to transfer 
approximately $952 million of estimated costs from the CIP account to 
the Buildings account. The error caused the Buildings line item on the 
Balance Sheet to be materially overstated by approximately $921 million 
and the CIP line item on the Balance Sheet to be materially understated 
by this same amount. 

The CIP general ledger account includes construction of, and major 
improvements and renovation projects to, buildings that GSA owns and 
leases to other federal entities. Upon substantial completion, certain 
costs are to be transferred to the appropriate Property and Equipment 
(P&E) asset account. The transfer from the CIP account to the 
appropriate P&E account is necessary for proper classification of 
assets in the Balance Sheet as well as accurate and complete reporting 
of depreciation expenses. Depreciation is not calculated and recorded 
until the asset is transferred from CIP to the appropriate asset 
account. 

When a new CIP project is established, regional personnel are expected 
to enter all necessary information, including the expected date of 
completion into the Inventory Reporting Information System (IRIS) that 
GSA management uses to monitor the status of construction projects. 
Construction costs are accumulated in the CIP account. Once a project 
is substantially complete, the project manager is supposed to enter the 
date of substantial completion into IRIS so that the CIP account 
project costs will be automatically transferred into the Real Property 
Accounting Depreciation System (RPADS). Also, building projects that 
meet certain capitalization criteria and are determined to have been 
substantially completed during the reporting period should be 
transferred to the Buildings account from the CIP account. 

Transfers of the costs of substantially completed projects from the CIP 
to the appropriate P&E account are necessary for proper classification 
of the related assets in the Balance Sheet. For fiscal year 2003, GSA's 
net Buildings account and CIP account totaled about 52 percent of its 
total assets. However, according to the IPA's fiscal year 2004 Report 
on Internal Control, since fiscal year 2001, GSA has experienced 
problems related to cost transfers from CIP to the appropriate P&E 
account. Specifically, the IPA's report noted that GSA's Public 
Buildings Service (PBS) controls over transferring substantially 
complete CIP projects continue to need improvement. 

GSA has been aware that weaknesses in these processes can lead to the 
failure to recognize the completion of construction projects on a 
timely basis. Among the causes of the underlying weaknesses previously 
reported by GSA's auditor are regional personnel not entering 
completion dates in IRIS, and manual procedures performed by central 
staff not addressing all CIP issues. In order to mitigate these control 
weaknesses, each quarter GSA's PBS uses a random statistical sample to 
assess the accuracy of data in its RPADS and makes an adjusting journal 
entry to correct for any errors for reporting purposes. 

Based on PBS's review of a statistical sample of projects still 
classified in IRIS as CIP at the end of fiscal year 2003, GSA recorded 
an adjusting journal entry to transfer about $952 million of estimated 
costs from the CIP account to the Buildings account. In September 2004, 
during GSA's OIG review of GSA's quarterly financial statements, the 
OIG discovered an error in the agency's classification of the largest 
project included in GSA's end of fiscal year 2003 statistical sample. 
Specifically, the OIG found that PBS incorrectly classified a $68.6 
million multiphase project from the fiscal year 2003 CIP sample as 
substantially complete when it should have remained in CIP. PBS 
identified the multiphase project as substantially complete without 
obtaining written documentation from the region responsible for the 
project to support such a determination. This incorrect classification, 
when projected to the population of CIP projects, was the basis for 
about $921 million of the approximately $952 million of the estimated 
costs that were transferred. As a result, GSA's adjusting journal entry 
to transfer approximately $952 million in estimated costs from the CIP 
account to the Buildings account was overstated by about $921 million. 
GSA's OIG communicated the error to GSA management and to the IPA in 
September 2004, which was appropriate. After researching the issue, GSA 
management concurred that the error warranted an adjustment to restate 
the CIP and Buildings line items on the fiscal year 2003 Balance Sheet. 

To reduce the risk of similar errors in the future, GSA officials told 
us that GSA has refined its methodology for determining the CIP 
transfer amounts. Starting with fiscal year 2005, GSA will semi- 
annually review all of the CIP projects over $7 million and 
statistically sample the remaining lower cost CIP projects to develop 
an adjusting journal entry, if necessary. In addition, according to 
GSA's Corrective Action Plan, GSA intends to improve its controls over 
transferring substantially complete CIP projects by enforcing its 
control procedures at the project level to ensure that all 
substantially complete and only substantially complete CIP projects are 
transferred out of the CIP account. GSA's plan calls for GSA regions to 
make entries into a weekly nationwide CIP Progress Report to certain 
GSA officials regarding the number of projects: (1) with no substantial 
completion date, (2) with substantial completion dates in the past, and 
(3) marked to be completed in the current month. In addition, according 
to GSA's Plan, PBS intends to work with regions to develop regional 
action plans that enforce entering timely substantial completion dates 
at the project level. 

Auditor's Procedures Were Not Adequately Designed to Detect Error in 
the Transfer of CIP Costs: 

The above-noted error was not discovered during the audit of GSA's 
fiscal year 2003 financial statements because the fiscal year 2003 
audit procedures performed by GSA's IPA were not adequately designed to 
detect the error. The journal entry used to record the transfer between 
the accounts involved a material amount and GSA's IPA had reported a 
reportable condition relating to CIP transfers in its previous two 
years audit reports. In addition, as noted above, over 96 percent of 
the estimated costs that were transferred resulted from the incorrectly 
classified multiphase project. Nevertheless, the IPA randomly selected 
10 projects from GSA's statistical sample of 99 projects and did not 
review the largest cost project in the sample, which is the above noted 
project that GSA had incorrectly classified. 

The Financial Audit Manual (FAM)[Footnote 11] states that during the 
audit planning process, the auditor should identify conditions that 
significantly increase inherent, fraud, and control risk. Among other 
things, the auditor should perform procedures to identify account 
balances and transactions that might signal inherent risk. According to 
FAM 260.40, the auditor should obtain an understanding of the financial 
reporting process and the controls over journal entries and other 
adjustments; identify and select journal entries and other adjustments 
for testing; determine the nature, timing, and extent of the testing; 
and inquire of individuals involved in the financial reporting process 
about inappropriate or unusual activity related to the processing of 
journal entries and adjustments. In our view, if the IPA had had a 
better understanding of the significant components of the calculations 
used to determine the material adjusting journal entry that transferred 
construction costs from the CIP account to the Buildings account and 
had then designed and performed sufficient audit procedures over such 
components, the error that necessitated the restatement might have been 
detected. 

According to GSA's IPA, future audits will include testing more 
projects from GSA's sample. Specifically, the IPA intends to increase 
the sample size from 10 to about 45. Given the known risks in this 
area, it will be important for the IPA to perform adequate audit 
procedures over any significant adjusting journal entries made by GSA 
to transfer CIP costs. 

The Title of GSA's Note Disclosure of the Restatement Could Be 
Misinterpreted: 

The notes to GSA's comparative fiscal years 2004 and 2003 financial 
statements included a note disclosure titled "Prior Period 
Reclassification." In our view, this title could be misinterpreted, 
since the note disclosure discussed the adjustment to correct the $921 
million material misstatement and the adjustment represented a 
restatement as defined by SFFAS No. 21 rather than a prior period 
reclassification. 

Conclusions: 

The restatement was caused by an error that GSA's OIG identified. GSA 
corrected the error and issued restated financial statements. Going 
forward, the key will be for GSA to ensure that the planned corrective 
actions established to help prevent future errors in the transfer of 
CIP costs are fully and effectively implemented. In addition, it will 
be important that GSA's OIG work with GSA's IPA so that audit 
procedures to detect any similar errors in the future are fully and 
effectively implemented. 

Recommendations for Executive Action: 

We recommend that GSA's Chief Financial Officer ensure that GSA fully 
and effectively implements control procedures to properly transfer 
costs from the CIP account to the Buildings account. 

We recommend that GSA's Inspector General, work with GSA's IPA so that 
audit procedures to sufficiently test adjusting journal entries related 
to the transfer of amounts from the CIP account to the Buildings 
account are fully and effectively implemented. 

Agency Comments: 

In commenting on a draft of this report, GSA's Acting Administrator 
stated that GSA concurs with our recommendation to implement control 
procedures to properly transfer costs from the CIP account to the 
Buildings account and has made changes in the statistical sample 
process as we acknowledged in our report. He also stated that GSA 
developed a weekly report that is sent to the regional offices to 
highlight the CIP projects where the estimated substantial completion 
date is overdue, missing, or scheduled to occur within 30 days to 
assist in ensuring the CIP projects are accurately capitalized and 
depreciated in a timely fashion. GSA's Inspector General concurred with 
our recommendation and stated that his office will continue to work 
with the IPA regarding auditing the transfer of CIP to the Buildings 
account and that since fiscal year 2003, the IPA's testing in this area 
has expanded to reduce the likelihood that a similar error would occur 
in the future. He also stated that his office will continue to monitor 
the IPA's efforts to plan and perform its tests of the adjusting 
journal entries related to the transfer of amounts from the CIP account 
to the Buildings account. 

Within 60 days of the date of this report, we would appreciate 
receiving a written statement on actions taken to address these 
recommendations. 

We are sending copies of this report to the Chairmen and Ranking 
Minority Members of the Senate Committee on Homeland Security and 
Governmental Affairs; the Subcommittee on Federal Financial Management, 
Government Information, and International Security, Senate Committee on 
Homeland Security and Governmental Affairs; the House Committee on 
Government Reform; and the Subcommittee on Government Management, 
Finance and Accountability, House Committee on Government Reform. In 
addition, we are sending copies to the Fiscal Assistant Secretary of 
the Treasury and the Controller of OMB. This report is also available 
at no charge on GAO's Web site at www.gao.gov. 

We appreciate the courtesy and cooperation extended to us by your staff 
throughout our work. We look forward to continuing to work with your 
offices to help improve financial management in the federal government. 
If you have any questions about the contents of this report, please 
contact me at (202) 512-3406 or engelg@gao.gov. 

Signed by: 

Gary T. Engel: 
Director: 
Financial Management and Assurance: 

Enclosure I: Comments from the Acting Administrator, General Services 
Administration: 

GSA Administrator: 

November 28, 2005: 

The Honorable David M. Walker: 
Comptroller General of the United States: 
Government Accountability Office: 
Washington, DC 20548: 

Dear Mr. Walker: 

The General Services Administration (GSA) appreciates this opportunity 
to review and provide comments to the Government Accountability 
Office's (GAO's) draft report, FINANCIAL AUDIT: Restatement to the 
General Services Administration's Fiscal Year 2003 Financial 
Statements, GAO-06-70R. 

The draft report recommends that GSA's Chief Financial Officer ensure 
that GSA fully and effectively implements control procedures to 
properly transfer costs from the Construction in Process (CIP) account 
to the Buildings account. 

GSA concurs with the recommendations to implement controls procedures 
to properly transfer cost from the CIP account to Buildings account and 
has made changes in the statistical sample process as you acknowledged 
in the report. Specifically, beginning with the September 2004 
statistical sample, the Public Buildings Service (PBS) Chief Financial 
Officer's (CFO's) Office required the Regional Offices to provide 
documentation that supports the status of the project as of the date 
the sample was pulled. In addition, beginning in March 2005, the sample 
process was restructured to segregate the CIP universe into strata. 
Stratum one contains all projects over $7 million dollars in addition 
to some other special projects that are reviewed 100 percent, thus 
eliminating the need to project the error rates on large projects over 
the population. These projects are reviewed every quarter and represent 
approximately 75 percent of the total adjusted CIP account balance. 
Stratum two contains all projects that make up 1 percent of the 
adjusted CIP account balance. Stratum three contains all remaining CIP 
projects. A statistical sample is drawn semi-annually from both Stratum 
two and three and the error rate is projected over each Stratum's 
universe. Also, the PBS CFO's Office developed a weekly report that is 
sent to the regional offices to highlight the CIP projects where the 
Estimated Substantial Completion date is overdue, missing, or scheduled 
to occur within 30 days. The report highlights those projects to assist 
in ensuring the CIP projects are accurately capitalized and depreciated 
in a timely fashion. 

Should you have any questions, please contact Kathleen M. Turco, Acting 
Deputy Administrator. Staff inquiries may be directed to Mr. Donzell 
Jackson, Director, Financial Consulting and Analysis Division at (202) 
501-0110. 

Sincerely, 

Signed by: 

David L. Bibb: 
Acting Administrator: 

[End of section] 

Enclosure II: Comments from the Inspector General, General Services 
Administration: 

U.S. GENERAL SERVICES ADMINISTRATION: 
Office of Inspector General: 

NOV 21 '05: 

Mr. Gary T. Engel: 
Director: 
Financial Management and Assurance: 
Government Accountability Office: 
441 G St., NW: 
Washington, DC 20548: 

Dear Mr. Engel: 

Thank you for the opportunity to respond to your report entitled, 
Financial Audit. Restatements to the General Services Administration's 
Fiscal Year 2003 Financial Statements. 

Your report recommends "GSA's Inspector General work with GSA's 
independent public accountant (IPA) so that audit procedures to 
sufficiently test adjusting journal entries related to the transfer of 
amounts from the Construction in Progress (CIP) account to the 
Buildings account are fully and effectively implemented." We concur 
with your recommendation, and continue to work with GSA's IPA regarding 
the transfer of CIP to the Building account. Since Fiscal Year 2003, 
the IPA's testing in this area has expanded to reduce the likelihood 
that a reclassification would occur in the future. The IPA has achieved 
this through segregating the CIP population and increasing the sample 
size. We will continue to monitor the IPA's efforts to plan and perform 
its tests of the adjusting journal entries related to the transfer of 
amounts from the CIP account to the Buildings account. 

We understand and appreciate the impact of financial statement errors 
on the public's trust and confidence in GSA and the Federal Government 
as a whole, and remain deeply committed to working with GSA's IPA to 
ensure that tests are sufficient. If you should have any questions or 
would like to discuss this issue further, please contact Eugene 
Waszily, Assistant Inspector General for Auditing, of my staff on (202) 
501-0374. 

Sincerely, 

Signed by: 
Brian D. Miller: 
Inspector General: 

[End of section] 

(198396): 

FOOTNOTES 

[1] The Government Management Reform Act of 1994 has required such 
reporting, covering the executive branch of government, beginning with 
financial statements prepared for fiscal year 1997. 31 U.S.C. § 331 
(e). The federal government has elected to include certain financial 
information on the legislative and judicial branches in the CFS as 
well. 

[2] A financial statement restatement occurs when an entity either 
voluntarily or prompted by its auditors or regulators revises public 
financial information that has previously been reported. 

[3] According to Federal Accounting Standards Advisory Board, Statement 
of Federal Financial Accounting Standards (SFFAS) No. 21, Reporting 
Corrections of Errors and Changes in Accounting Principles, prior 
period financial statements presented should be restated only to 
correct errors that caused such statements to be materially misstated. 

[4] The Federal Emergency Management Agency (FEMA) was transferred to 
the Department of Homeland Security (DHS) effective March 1, 2003. With 
this transfer, FEMA was no longer required to prepare and have audited 
stand-alone financial statements under the CFO Act, leaving 23 CFO Act 
agencies for the remainder of fiscal year 2003 and for fiscal year 
2004. The DHS Financial Accountability Act, Pub. L. No. 108-330, 118 
Stat. 1275 (Oct. 16, 2004), added DHS to the list of CFO Act agencies, 
increasing the number of CFO Act agencies again to 24 beginning in 
fiscal year 2005. 

[5] The 2 agencies that had restatements for fiscal year 2003 but did 
not receive unqualified opinions on their originally issued fiscal year 
2003 financial statements were the Department of Defense and the Small 
Business Administration. 

[6] Transparency is the full, accurate, and timely disclosure of 
information. 

[7] The United States General Ledger uses the term Construction in 
Progress, but GSA presents this account as Construction in Process in 
the fiscal year 2003 financial statements. We will use the term 
Construction in Process (CIP) to refer to the account. 

[8] According to the IPA's Property Cycle memorandum, GSA defines 
substantial completion as the date when GSA can use the constructed 
item for its intended use. Substantial completion is not equivalent to 
the completion date for the contract. Substantial completion is also 
the date for the transfer of the project from the work in process 
account to the Buildings account.

[9] Federal Accounting Standards Advisory Board, Statement of Federal 
Financial Accounting Concepts No. 1, Objectives of Federal Financial 
Reporting. 

[10] Generally accepted government auditing standards incorporate AICPA 
reporting standards and Statements on Auditing Standards unless the 
Comptroller General of the United States excludes them by formal 
announcement. 

[11] GAO/President's Council on Integrity and Efficiency, Financial 
Audit Manual, GAO-01-765G (Washington, D.C.: July 2001), updated by GAO-
04-1015G and GAO-04-924G (July 2004).