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DOD Financial Management: Continued Efforts Needed to Correct Material Weaknesses Identified in Financial Statement Audits

GAO-21-157 Published: Oct 13, 2020. Publicly Released: Oct 13, 2020.
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Fast Facts

Since 1995, the Department of Defense's financial management has been on our High Risk List. Thousands of audit findings from DOD's department-wide financial statement audits in 2018 show the extent of improvements needed. Our 2017 recommendation prompted DOD to develop a centralized database that uses real-time data to track audit findings and its progress in addressing them.

However, some of the data used to report on DOD's progress is inaccurate and incomplete. We made 5 recommendations, including that DOD improve the quality of its corrective action plans to address audit findings and its database information used to report progress.

Someone holds a magnifying glass in one hand a pen in the other to examine a financial spreadsheet.

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Highlights

What GAO Found

The Department of Defense (DOD) continues to face financial management issues and challenges that have prevented it from obtaining a clean audit opinion on the fair presentation of its financial statements. Specifically, financial statement auditors issued disclaimers of opinion on DOD's and the military services' fiscal year 2018 and 2019 financial statements. These disclaimers resulted from numerous material weaknesses based on thousands of notices of findings and recommendations (NFR) that the auditors issued. Of the 2,409 NFRs issued to DOD and its components in fiscal year 2018, DOD's auditors were able to close 623 (26 percent) in fiscal year 2019; the remaining 1,786 (74 percent) remained open. These results provide useful insights on DOD's remediation progress since beginning department-wide full audits in fiscal year 2018; it is important for DOD to equal or exceed this progress in the future.

Financial statement audits have value beyond the audit opinion and can help management save resources and improve military readiness. DOD leadership identified a number of benefits that resulted from these financial statement audits. For example, the Navy identified a warehouse that was not in its property records that contained approximately $126 million in aircraft parts. The Navy was able to fill over $20 million in open orders for these parts. By using these parts, aircraft were repaired quicker and made available for use, which improved military readiness. To help guide and prioritize department-wide efforts, DOD identified eight audit remediation priority areas (four in 2019 and four in 2020), seven of which specifically related to material weaknesses that its auditor reported. The military services also developed methodologies to prioritize NFRs and determined that over half of their fiscal year 2018 NFRs are high priority and significant to their financial statement audits.

DOD and its components have taken steps to develop corrective action plans (CAP) to address NFRs. However, most of the CAPs that GAO tested did not include at least one data element or evidence that a root-cause analysis was performed, as directed by Office of Management and Budget (OMB) and other related guidance, in part, because DOD guidance and monitoring efforts did not clearly identify the need for such documentation. As a result, DOD and its components may lack sufficient information and assurance that their remediation efforts will resolve the underlying causes associated with the NFRs and related material weaknesses. Based on these issues, DOD and its components are at increased risk that their actions may not effectively address identified deficiencies in a timely manner.

DOD developed an NFR Database that contains useful information on deficiencies that financial auditors identified and actions to address them, which has improved its ability to monitor and report on audit remediation efforts using dashboard reports based on real-time data contained in the database. However, certain database information on which these reports are based may not be accurate, reliable, and complete. For example, although DOD reviews NFR Database information monthly, it does not follow up on instances of outdated information or other exceptions identified to ensure components resolve them timely. Without complete and reliable information on DOD's audit remediation efforts, internal and external stakeholders may not have quality information to effectively monitor and measure DOD's progress.

Why GAO Did This Study

DOD is responsible for about half of the federal government's discretionary spending, yet it remains the only major federal agency that has been unable to receive a clean audit opinion on its financial statements. After years of working toward financial statement audit readiness, DOD underwent full financial statement audits in fiscal years 2018 and 2019.

This report, developed in connection with fulfilling GAO's mandate to audit the U.S. government's consolidated financial statements, examines the (1) actions taken by DOD and the military services to prioritize financial statement audit findings; (2) extent to which DOD and its components developed CAPs to address audit findings in accordance with OMB, DOD, and other guidance; and (3) extent to which DOD improved its ability to monitor and report on audit remediation efforts.

GAO reviewed documentation and interviewed officials about DOD's and the military services' audit remediation prioritization, monitoring, and reporting. GAO selected a generalizable sample of 98 NFRs to determine whether CAPs to address them were developed according to established guidance.

Recommendations

GAO is making five recommendations to DOD to improve the quality of CAPs to address audit findings and information in the NFR Database and related reports provided to internal and external stakeholders to monitor and assess audit remediation efforts. DOD concurred with three of GAO's recommendations, partially concurred with one recommendation, and disagreed with one recommendation. GAO continues to believe that all the recommendations are valid.

Recommendations for Executive Action

Agency Affected Recommendation Status
Department of Defense ODCFO should update the CAP template provided in its guidance to assist components in developing CAPs to include the year deficiencies are first identified data element defined in the Implementation Guide for OMB Circular A-123. (Recommendation 1)
Closed – Implemented
DOD concurred with this recommendation and stated that the Corrective Action Plan (CAP) template includes data elements defined in OMB Circular A-123, except for the data element related to the year the deficiency was first identified. DOD stated that this missing data element will be added to the CAP template during 2020. In March 2021, DOD informed us that an updated CAP template with the "Year First Identified" field had been communicated to DOD Components in a January 2021 training. We also reviewed the updated CAP template, dated August 2020, and confirmed that it had been revised in accordance with our recommendation.
Department of Defense ODCFO should update the NFR Database with a field to record the year deficiencies are first identified. (Recommendation 2)
Closed – Implemented
DOD concurred with this recommendation and stated that a single data field to record the year the deficiency was first identified will be added to the Notice of Findings and Recommendations (NFR) Database. In March 2021, DOD demonstrated that the NFR Database was updated to include a field "First Year Identified" to record the year deficiencies are first identified. Further, in January 2022, DOD provided an extract from the NFR Database with this field populated for all NFRs. We reviewed the data extract and confirmed that that the database was updated in accordance with our recommendation.
Department of Defense
Priority Rec.
ODCFO should incorporate appropriate steps to improve its CAP review process, including ensuring that (1) data elements not included in CAPs are appropriately identified and communicated to components and resolved, (2) NFRs are appropriately linked to the correct CAPs to address them, and (3) components document their rationale for accepting the risk associated with certain deficiencies and appropriately identify such instances in the NFR Database. (Recommendation 3)
Closed – Implemented
DOD partially concurred with this recommendation and stated that it ensures that a Notice of Findings and Recommendations (NFR) is appropriately linked to the right Corrective Action Plan (CAP) and that data elements missing from CAPs are identified and communicated to components through its CAP quality and monthly data control review processes. However, based on our testing of CAPs associated with NFRs included in a generalizable sample, we found that NFRs were not always linked to the correct CAP in the NFR Database. In response to our recommendation, in January 2024, DOD provided its CAP Assessment Guidance for CAP reviewers to help through considerations on how to evaluate each criteria of the CAP review process, including steps for both automated and manual review. Additionally, DOD's Office of the Deputy Chief Financial Officer (ODCFO) developed the Advana Dashboard for the CAP and Milestone Data Quality Review, which acts as a control tool to identify Material Weakness NFRs indicated as Low Impact. ODCFO also provided a detailed guidance for selecting low impact NFRs and recommendations for documenting a Memorandum for Record. Utilizing the dashboard to monitor data control results helps ensure timely and accurate remediation efforts. DOD components receive a monthly notification of results regarding updates and Dashboard results are presented to Senior Leaders throughout various governance meetings. In January 2025, DOD updated its Financial Statement Audit Requirements and Overview Guide for DOD personnel to use while supporting financial statement audits, to include the CAP quality control reviews with annual manual reviews and monthly automatic data quality checks. In total, these actions addressed this recommendation.
Department of Defense
Priority Rec.
ODCFO should update DOD guidance to instruct DOD and components to document root-cause analysis when needed to address deficiencies auditors identified. (Recommendation 4)
Closed – Implemented
DOD concurred with this recommendation and stated that it will update the appropriate DOD guidance to specifically instruct that a Corrective Action Plan (CAP) include documented evidence that a root-cause analysis was conducted and an explanation as to how it was conducted. In February 2025, DOD provided an updated CAP template with a field for "root cause description," and also provided an updated Financial Statement Audit Requirements and Overview Guide that DOD personnel use while supporting financial statement audits. The guide now requires that CAPs provide a detailed root cause description of the underlying problems or events identified that contributed to an audit finding. DOD has also developed various training for components on preparing CAPs to help ensure remediation will address audit findings. As a result, DOD gains assurance that it is taking appropriate actions to resolve underlying causes associated with audit findings and related material weaknesses that collectively prevent the auditability of its financial statements. In total, these actions addressed the deficiencies we identified.
Department of Defense ODCFO should include appropriate steps in its monthly NFR Database review process to evaluate and follow-up on previously identified exceptions to ensure that they are resolved timely. (Recommendation 5)
Open
DOD did not concur with this recommendation and stated that this action is already being performed. However, DOD's process does not include steps to determine how long exceptions have existed, and as a result, DOD lacks important information regarding the timeliness of efforts to resolve them. We will continue to monitor DOD's progress to address this recommendation.

Full Report

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Topics

Auditing proceduresAuditorsConsolidated Financial Statements of the U.S. GovernmentDefense auditsFinancial auditsFinancial managementFinancial reportingFinancial statementsFinancial statement auditsMaterial weaknessesRemediation