Notice of Proposed Revisions to OMB Circular No. A-123, ``Management Accountability and Control''

OFFICE OF MANAGEMENT AND BUDGET

Office of Federal Financial Management

Notice of Proposed Revisions to OMB Circular No. A-123,

``Management Accountability and Control''

agency: Office of Management and Budget, Office of Federal Financial

Management.

action: Proposed Revisions to OMB Circular No. A-123.

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summary: This Notice offers interested parties an opportunity to

comment on proposed revisions to OMB Circular No. A-123, ``Management

Accountability and Control.''

for further information contact: Cindy Salavantis, OMB, Office of

Federal Financial Management, (202) 395-6911.

Dated: March 7, 1995.

John B. Arthur,

Associate Director for Administration.

Attachment

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OFFICE OF MANAGEMENT AND BUDGET

Management Accountability and Control

AGENCY: Office of Management and Budget.

ACTION: Proposed Revisions to OMB Circular No. A-123.

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SUMMARY: This Notice offers interested parties an opportunity to

comment on proposed revisions to Office of Management and Budget (OMB)

Circular No. A-123, ``Management Accountability and Control.'' The

Circular, which was previously titled ``Internal Control Systems,''

implements the Federal Managers' Financial Integrity Act of 1982

(FMFIA).

Also, this action seeks comments on a proposal to streamline agency

FMFIA reporting, which has not yet been incorporated into this proposed

revision to Circular No. A-123. OMB is permitted by the Government

Management Reform Act (GMRA) of 1994 (P.L. 103-356) to consult with the

Congress on modifications to current reporting requirements. A possible

modification affecting FMFIA reporting is under consideration (see

Supplementary Information below for further details).

DATES: All comments on this proposal should be in writing, and must be

received by April 12, 1995. Late comments will be considered only to

the extent practicable. When comments are sent in by facsimile, they

should be followed up with an original printed copy.

ADDRESSES: Office of Management and Budget, Office of Federal Financial

Management, Management Integrity Branch, Room 6025, New Executive

Office Building, Washington, DC 20503. For a copy of the current

Circular, contact Office of Administration, Publications Office, Room

2200, New Executive Office Building, Washington, DC 20503, or telephone

(202) 395-7332.

FOR FURTHER INFORMATION CONTACT: Cindy Salavantis, Office of Federal

Financial Management, Management Integrity Branch, telephone (202) 395-

6911 and fax (202) 395-3952.

SUPPLEMENTARY INFORMATION: The proposed revision alters current

requirements for executive agencies on evaluating management controls,

consistent with recommendations made by the National Performance

Review. The proposed revision integrates many of the current policy

issuances on management control into a single document, and provides a

framework for integrating management control assessments with other

work now being performed by agency managers, auditors and evaluators.

The proposed revision emphasizes that management controls should

benefit rather than encumber management, and should make sense for each

agency's operating structure and environment. By giving agencies the

discretion to determine which tools to use in arriving at the annual

assurance statement to the President and the Congress, the Circular

represents an important step towards a streamlined management control

program that incorporates the reinvention principles of this

Administration.

The proposed revision is presented in five sections:

Section I. Introduction. This section describes a framework for

agency management control programs. Particular attention is directed to

the integration of agency management control activities with other

management requirements and policies, such as the Government

Performance and Results Act, the Chief Financial Officers (CFOs) Act,

the Inspector General Act, and other congressional and Executive Branch

requirements. The foundation of this proposed policy is that management

control activities are not stand alone management practices, but rather

are woven into the day-to-day operational responsibilities of agency

managers.

Agencies are encouraged to plan for how the requirements of the

Circular will be implemented. Agencies are also encouraged to establish

senior level management councils to address management accountability

and related issues within the broad context of agency operations.

Section II. Establishing Management Controls. This section defines

management controls, and requires agency managers to develop and

implement appropriate management controls. Included in this section are

general and specific management control standards, drawn in large part

from the standards issued by the General Accounting Office.

By including these standards in this proposed revision, OMB is

continuing its efforts to integrate various management control policies

into a single document. It is anticipated that this effort will make it

easier for Federal managers to implement good management controls.

Section III. Assessing and Improving Management Controls. This

section states that agency managers should continuously monitor and

improve the effectiveness of management controls. This continuous

monitoring, and other periodic evaluations, should provide the basis

for the agency head's annual [[Page 13485]] assessment of and report on

management controls.

Agencies are encouraged to use a variety of information sources to

arrive at the annual assurance statement to the President and the

Congress. Several examples of sources of information are included in

this section.

Agency managers and the agency's senior management council will

consider and make recommendations to the agency head regarding the

annual assurance statement required by FMFIA, and which deficiencies in

management controls should be considered material and included in the

agency head's FMFIA Report.

Section IV. Correcting Management Control Deficiencies. This

section states that agency management is responsible for taking timely

and effective action to correct management control deficiencies.

Correcting these deficiencies is an integral part of management's

responsibilities and must be considered a priority by the agency.

Section V. Reporting on Management Controls. This section describes

the required components of the agency's annual FMFIA report and the

suggested report distribution to the President and the Congress.

Periodically, questions are raised as to FMFIA coverage by

government corporations. This section presents FMFIA requirements as

they pertain to government corporations pursuant to the CFOs Act. 31

U.S.C. 9106.

Finally, as noted in the Summary above, this Notice also seeks

input on a proposal to streamline agency FMFIA reporting, which has not

yet been incorporated into this proposed revision to Circular No. A-

123. Respondents are encouraged to comment on a possible modification

affecting FMFIA reporting which has been proposed by the CFO Council.

Under this proposal, agencies would consolidate FMFIA information

with other performance-related reporting into a broader

``Accountability Report'' to be issued annually by the agency head.

This report would be issued as soon as possible after the end of the

fiscal year, but no later than March 31 for agencies producing audited

financial statements and December 31 for all other agencies. The other

components of the proposed ``Accountability Report'' include: audited

financial statements; agency management's followup on audit

recommendations; financial reporting data on prompt payment and civil

monetary penalties; and available information on agency performance

compared to its stated goals and objectives, in preparation for

implementation of the Government Performance and Results Act. While

financial data would be reported for the fiscal year just ended, the

most current information available at the time the report is issued

would be included on management controls and audit followup issues.

John B. Arthur,

Associate Director for Administration.

To the Heads of Executive Departments and Establishments

Subject: Management Accountability and Control

1. Purpose and Authority. As Federal employees develop and

implement strategies for reengineering agency programs and operations,

they should design management structures that help ensure

accountability for results, and include appropriate, cost-effective

controls. This Circular provides guidance to Federal managers on

improving the accountability and effectiveness of Federal programs and

operations by establishing, assessing, correcting, and reporting on

management controls.

The Circular is issued under the authority of the Federal Managers'

Financial Integrity Act of 1982 as codified in 31 U.S.C. 3512.

The Circular replaces Circular No. A-123, ``Internal Control

Systems,'' revised, dated August 4, 1986, and OMB's 1982 ``Internal

Controls Guidelines'' and associated ``Questions and Answers''

document, which are hereby rescinded.

2. Policy. Management accountability is the expectation that

managers are responsible for the quality and timeliness of program

performance, increasing productivity, controlling costs and mitigating

adverse aspects of agency operations, and assuring that programs are

managed with integrity and in compliance with applicable law.

Management controls are the organization, policies, and procedures

used to reasonably ensure that (i) programs achieve their intended

results; (ii) resources are used consistent with agency mission; (iii)

programs and resources are protected from waste, fraud, and

mismanagement; (iv) laws and regulations are followed; and (v) reliable

information is obtained, maintained, reported and used for decision

making.

3. Actions Required. Agencies and individual Federal managers must

take systematic and proactive measures to (i) develop and implement

appropriate, cost-effective management controls for results-oriented

management; (ii) assess the adequacy of management controls in Federal

programs and operations; (iii) identify needed improvements; and (iv)

take corresponding corrective action.

4. Effective Date. This Circular is effective upon issuance.

5. Inquiries. Further information concerning this Circular may be

obtained from the Management Integrity Branch, Office of Federal

Financial Management, Office of Management and Budget, Washington, DC

20503, 202/395-6911.

6. Copies. Copies of this Circular may be obtained by telephoning

the Executive Office of the President, Publication Services, at 202/

395-7332.

[to be signed by Director, OMB]

Attachment

I. Introduction

The proper stewardship of Federal resources is a fundamental

responsibility of agency managers and staff. Federal employees must

ensure that government resources are used efficiently and effectively

to achieve intended program results. Resources must be used consistent

with agency mission, in compliance with law and regulation, and with

minimal potential for waste, fraud, and mismanagement.

To support results-oriented management, the Government Performance

and Results Act (GPRA, P.L. 103-62) requires agencies to develop

strategic plans, set performance goals, and report annually on actual

performance compared to goals. As the Federal government implements

this legislation, these plans and goals should be integrated into (i)

the budget process, (ii) the operational management of agencies and

programs, and (iii) accountability reporting to the public on

performance results, and on the integrity, efficiency, and

effectiveness with which they are achieved.

Management controls--organization, policies, and procedures--are

tools to help program and financial managers achieve results and

safeguard the integrity of their programs. This Circular provides

guidance on using the range of tools at the disposal of agency managers

to achieve desired program results and meet the requirements of the

Federal Managers' Financial Integrity Act (FMFIA).

Framework. The importance of management controls is addressed, both

explicitly and implicitly, in many statutes and executive documents.

The Federal Managers' Financial Integrity Act (P.L. 97-255) establishes

specific expectations with regard to management controls. The agency

head must establish controls that reasonably ensure that: (i)

obligations and costs comply with applicable law; (ii) assets are

safeguarded against waste, loss, [[Page 13486]] unauthorized use or

misappropriation; and (iii) revenues and expenditures are properly

recorded and accounted for. 31 U.S.C. 3512 (c)(1). In addition, the

agency head annually must evaluate and report on the control and

financial systems that protect the integrity of Federal programs. 31

U.S.C. 3512 (d)(2). The Act encompasses program and administrative

areas as well as accounting and financial management.

Instead of considering controls as an isolated management tool,

agencies should integrate their efforts to meet the requirements of

FMFIA with other efforts to improve effectiveness and accountability.

Thus, management controls should be an integral part of the entire

cycle of planning, budgeting, management, accounting, and auditing.

They should support the effectiveness and the integrity of every step

of the process and provide continual feedback to management.

For example, good management controls can assure that performance

measures are complete and accurate. The management control standard of

organization would align staff and authority with the program

responsibilities to be carried out, improving both effectiveness and

accountability. Similarly, accountability for resources could be

improved by more closely aligning budget accounts with programs and

charging them with all significant resources used to produce the

program's outputs and outcomes.

Meeting the requirements of the Chief Financial Officers Act (P.L.

101-576, as amended) should help agencies both establish and evaluate

management controls. The Act requires the preparation and audit of

financial statements for 23 Federal agencies. In this process, auditors

report on internal controls and compliance with laws and regulations.

Therefore, the agencies covered by the Act have a clear opportunity

both to improve controls over their financial activities, and to

evaluate the controls that are in place.

The Inspector General Act (P.L. 95-452, as amended) provides for

independent reviews of agency programs and operations. Offices of

Inspectors General (OIGs) and other external audit organizations

frequently cite specific deficiencies in management controls and

recommend opportunities for improvements. Agency managers, who are

required by the Act to follow up on audit recommendations, should use

these reviews to identify and correct problems resulting from

inadequate, excessive, or poorly designed controls, and to build

appropriate controls into new programs.

Federal managers must carefully consider the appropriate balance of

controls in their programs and operations. Fulfilling requirements to

eliminate regulations (``Elimination of One-Half of Executive Branch

Internal Regulations,'' Executive Order 12861) and streamline staffing

(the Federal Workforce Restructuring Act of 1994, P.L. 103-226), should

reinforce to agency managers that too many controls can result in

inefficient and ineffective government, and therefore that they must

ensure an appropriate balance between too many controls and too few

controls. Managers should benefit from controls, not be encumbered by

them.

Agency Implementation. Appropriate management controls should be

integrated into each system established by agency management to direct

and guide its operations. A separate management control process need

not be instituted, particularly if its sole purpose is to satisfy the

FMFIA's reporting requirements.

Agencies need to plan for how the requirements of this Circular

will be implemented. Developing a written strategy for internal agency

use may help ensure that appropriate action is taken throughout the

year to meet the objectives of the FMFIA. The absence of such a

strategy may itself be a serious management control deficiency.

Identifying and implementing the specific procedures necessary to

ensure good management controls, and determining how to evaluate the

effectiveness of those controls, is left to the discretion of the

agency head. However, agencies are encouraged to streamline their

management control efforts in accordance with the recommendations of

the National Performance Review.

The President's Management Council, composed of the major agencies'

chief operating officers, has been established to foster governmentwide

management and cultural changes (``Implementing Management Reform in

the Executive Branch,'' October 1, 1993). Many agencies are

establishing their own senior management council, often chaired by the

agency's chief operating officer, to address management accountability

and related issues within the broader context of agency operations.

Relevant issues for such a council include ensuring the agency's

commitment to an appropriate system of management controls;

recommending to the agency head which control deficiencies are

sufficiently serious to report in the annual FMFIA report; and

providing input for the level and priority of resource needs to correct

these deficiencies. (See also Section III of this Circular.)

II. Establishing Management Controls

Definition of Management Controls. Management controls are the

organization, policies, and procedures used by agencies to reasonably

ensure that (i) programs achieve their intended results; (ii) resources

are used consistent with agency mission; (iii) programs and resources

are protected from waste, fraud, and mismanagement; (iv) laws and

regulations are followed; and (v) reliable information is obtained,

maintained, reported and used for decision making.

Management controls, in the broadest sense, include the plan of

organization, methods and procedures adopted by management to ensure

that its goals are met. Management controls include processes for

planning, organizing, directing, and controlling program operations. A

subset of management controls are the internal controls used to assure

that there is prevention or timely detection of unauthorized

acquisition, use, or disposition of the entity's assets that could have

a material effect on its financial statements.

Developing Management Controls. As Federal employees develop and

implement strategies for reengineering agency programs and operations,

they should design management structures that help ensure

accountability for results. As part of this process, agencies and

individual Federal managers must take systematic and proactive measures

to develop and implement appropriate, cost-effective management

controls. Such controls guarantee neither the success of agency

programs, nor the absence of waste, fraud, and mismanagement, but they

are a means of managing the risk associated with Federal programs and

operations. To help ensure that controls are appropriate and cost-

effective, agencies should consider the extent and cost of controls

relative to the importance and risk associated with a given program.

Standards. Agency managers should incorporate basic management

controls in the strategies, plans, guidance and procedures that govern

their programs and operations. Controls should be consistent with the

following standards, which are drawn in large part from the ``Standards

for Internal Control in the Federal Government,'' issued by the General

Accounting Office (GAO).

General management control standards are:

Compliance With Law. All program operations, obligations

and costs must comply with applicable law. Resources

[[Page 13487]] should be efficiently and effectively allocated for duly

authorized purposes.

Reasonable Assurance and Safeguards. Management controls

must provide reasonable assurance that assets are safeguarded against

waste, loss, unauthorized use, and misappropriation. Management

controls developed for agency programs should be logical, applicable,

reasonably complete, and effective and efficient in accomplishing

management objectives.

Integrity, Competence, and Attitude. Managers and

employees must have personal integrity and are obligated to support the

ethics programs in their agencies. The spirit of the Standards of

Ethical Conduct requires that they develop and implement effective

management controls and maintain a level of competence that allows them

to accomplish their assigned duties. Effective communication within and

between offices should be encouraged.

Specific management control standards are:

Delegation of Authority and Organization. Managers should

ensure that appropriate authority, responsibility and accountability

are delegated to accomplish the mission of the organization, and that

an appropriate organizational structure is established to effectively

carry out program responsibilities. To the extent possible, controls

and related decision-making authority should be in the hands of line

managers and staff.

Separation of Duties and Supervision. Key duties and

responsibilities in authorizing, processing, recording, and reviewing

official agency transactions should be separated among individuals.

Managers should exercise appropriate oversight to ensure individuals do

not exceed or abuse their assigned authorities.

Access to and Accountability for Resources. Access to

resources and records should be limited to authorized individuals, and

accountability for the custody and use of resources should be assigned

and maintained.

Recording and Documentation. Transactions should be

promptly recorded, properly classified and accounted for in order to

prepare timely accounts and reliable financial and other reports. The

documentation for transactions, management controls, and other

significant events must be clear and readily available for examination.

Resolution of Audit Findings and Other Deficiencies.

Managers should promptly evaluate and determine proper actions in

response to known deficiencies, reported audit and other findings, and

related recommendations. Managers should complete, within established

timeframes, all actions that correct or otherwise resolve the

appropriate matters brought to management's attention.

Other policy documents may describe additional specific standards

for particular functional or program activities. For example, OMB

Circular No. A-127, ``Financial Management Systems,'' describes

government-wide requirements for financial systems. The Federal

Acquisition Regulations define requirements for agency procurement

activities.

III. Assessing and Improving Management Controls

Agency managers should continuously monitor and improve the

effectiveness of management controls associated with their programs.

This continuous monitoring, and other periodic evaluations, should

provide the basis for the agency head's annual assessment of and report

on management controls, as required by the FMFIA. Agency management

should determine the appropriate level of documentation needed to

support this assessment.

Sources of Information. The agency head's assessment of management

controls can be performed using a variety of information sources.

Management has primary responsibility for monitoring and assessing

controls, and should use other sources as a supplement to--not a

replacement for--its own judgment. Sources of information include:

Management knowledge gained from the daily operation of

agency programs and systems.

Management reviews conducted (i) expressly for the purpose

of assessing management controls, or (ii) for other purposes with an

assessment of management controls as a by-product of the review.

IG and GAO reports, including audits, inspections,

reviews, investigations, outcome of hotline complaints, or other

products.

Program evaluations.

Audits of financial statements conducted pursuant to the

Chief Financial Officers Act, as amended, including: information

revealed in preparing the financial statements; the auditor's reports

on the financial statements, internal controls, and compliance with

laws and regulations; and any other materials prepared relating to the

statements.

Reviews of financial systems which consider whether the

requirements of OMB Circular No. A-127 are being met.

Reviews of systems and applications conducted pursuant to

the Computer Security Act of 1987 and OMB Circular No. A-130,

``Management of Federal Information Resources.''

Annual performance plans and reports pursuant to the

Government Performance and Results Act.

Reports and other information provided by the

Congressional committees of jurisdiction.

Other reviews or reports relating to agency operations,

e.g. for the Department of Health and Human Services, quality control

reviews of the Medicaid and Aid to Families with Dependent Children

programs.

Use of a source of information should take into consideration

whether the process included an evaluation of management controls.

Agency management should avoid duplicating reviews which assess

management controls, and should coordinate their efforts with other

evaluations to the extent practicable.

If a Federal manager determines that there is insufficient

information available upon which to base an assessment of management

controls, then appropriate reviews should be conducted which will

provide such a basis.

Identification of Deficiencies. Agency managers and employees

should identify deficiencies in management controls from the sources of

information described above. A deficiency should be reported if it is

or should be of interest to the next level of management. Agency

employees and managers generally report deficiencies to the next

supervisory level, which allows the chain of command structure to

determine the relative importance of each deficiency.

A deficiency that the agency head determines to be significant

enough to be reported outside the agency (i.e. included in the annual

FMFIA report to the President and the Congress) should be considered a

``material weakness.'' This designation requires a judgment by agency

managers as to the relative risk and significance of deficiencies.

Agencies may wish to use a different term to describe less significant

deficiencies, which are reported only internally in an agency. In

identifying and assessing the relative importance of deficiencies,

particular attention should be paid to the views of the agency's IG.

Agencies should carefully consider whether systemic problems exist

that adversely affect management controls across organizational or

program lines. The Chief Financial Officer, the Senior Procurement

Executive, the Senior IRM Official, and the managers of other

[[Page 13488]] functional offices should be involved in identifying and

ensuring correction of systemic deficiencies relating to their

respective functions.

Agency managers and staff should be encouraged to identify and

report deficiencies, as this reflects positively on the agency's

commitment to recognizing and addressing management problems. Failing

to report a known deficiency would reflect adversely on the agency.

Role of Senior Management Council. Many agencies have found that a

senior management council is a useful forum for assessing and

monitoring deficiencies in management controls. The membership of such

councils generally includes both line and staff management;

consideration should be given to involving the IG. Such councils

generally recommend to the agency head which deficiencies are deemed to

be material to the agency as a whole, and should therefore be included

in the annual FMFIA report to the President and the Congress. (Such a

council need not be exclusively devoted to management control issues.)

This process will help identify deficiencies that although minor

individually, may constitute a material weakness in the aggregate. Such

a council may also be useful in determining when sufficient action has

been taken to declare that a deficiency has been corrected.

IV. Correcting Management Control Deficiencies

Agency managers are responsible for taking timely and effective

action to correct deficiencies identified by the variety of sources

discussed in Section III. Correcting deficiencies is an integral part

of management accountability and must be considered a priority by the

agency.

The extent to which corrective actions are tracked by the agency

should be commensurate with the severity of the deficiency. Corrective

action plans should be developed for all material weaknesses, and

progress against plans should be periodically assessed and reported to

agency management. Management should track progress to ensure timely

and effective results. For deficiencies that are not included in the

FMFIA report, corrective action plans should be developed and tracked

internally at the appropriate level.

A determination that a deficiency has been corrected should be made

only when sufficient corrective actions have been taken and the desired

results achieved. This determination should be in writing, and along

with other appropriate documentation, should be available for review by

appropriate officials. (See also role of senior management council in

Section III.)

As managers consider IG and GAO audit reports in identifying and

correcting management control deficiencies, they must be mindful of the

statutory requirements for audit followup included in the IG Act, as

amended. Under this law, management has a responsibility to complete

action, in a timely manner, on audit recommendations on which agreement

with the IG has been reached. 5 U.S.C. Appendix 3. (Management must

make a decision regarding IG audit recommendations within a six month

period and implementation of management's decision should be completed

within one year to the extent practicable.) Agency managers and the IG

share responsibility for ensuring that IG Act requirements are met.

V. Reporting on Management Controls

Reporting Pursuant to Section 2. 31 U.S.C. 3512(d)(2) (commonly

referred to as Section 2 of the FMFIA) requires that annually by

December 31, the head of each executive agency submit to the President

and the Congress (i) a statement on whether there is reasonable

assurance that the agency's controls are achieving their intended

objectives; and (ii) a report on material weaknesses in the agency's

controls. OMB may provide guidance on the composition of the annual

report.

Statement of Assurance. The statement on reasonable

assurance represents the agency head's informed judgment as to the

overall adequacy and effectiveness of management controls within the

agency. The statement must take one of the following forms: statement

of assurance; qualified statement of assurance, considering the

exceptions explicitly noted; or statement of no assurance.

In deciding on the type of assurance to provide, the agency head

should consider information from the sources described in Section III

of this Circular, with input from senior program and administrative

officials and the IG. The agency head must describe the analytical

basis for the type of assurance being provided, and the extent to which

agency activities were assessed. The statement of assurance must be

signed by the agency head.

Report on Material Weaknesses. The FMFIA report should

include agency plans to correct the material weaknesses and progress

against those plans.

Reporting Pursuant to Section 4. 31 U.S.C. 3512 (d)(2)(B) (commonly

referred to as Section 4 of the FMFIA) requires an annual statement on

whether the agency's financial management systems conform with

government-wide requirements. These financial systems requirements are

presented in OMB Circular No. A-127, ``Financial Management Systems,''

section 7. If the agency does not conform with financial systems

requirements, the statement should discuss the agency's plans for

bringing its systems into compliance.

If the agency head judges a deficiency in financial management

systems and/or operations to be material when weighed against other

agency deficiencies, the issue should be included in the annual FMFIA

report in the same manner as other material weaknesses.

Distribution of FMFIA Report. The assurance statements and

information related to both Sections 2 and 4 should be provided in a

single FMFIA report. Copies of the report should be transmitted to the

President; the Director of OMB; the President of the Senate; the

Speaker of the House of Representatives; and the Chairpersons and

Ranking Members of the Senate Committee on Governmental Affairs, the

House Committee on Government Operations, and the relevant authorizing

and appropriations committees and subcommittees. In addition, 10 copies

of the report should be provided to OMB's Management Integrity Branch.

Government Corporations. Section 306 of the Chief Financial

Officers Act established a reporting requirement related to management

controls for corporations covered by the Government Corporation and

Control Act. 31 U.S.C. 9106. These corporations must submit an annual

management report to the Congress not later than 180 days after the end

of the corporation's fiscal year. This report must include, among other

items, a statement on control systems by the head of the management of

the corporation consistent with the requirements of the FMFIA.

The corporation is required to provide the President, the Director

of OMB, and the Comptroller General a copy of the management report

when it is submitted to Congress.

[FR Doc. 95-6024 Filed 3-10-95; 8:45 am]

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