Whoa Nellie!

So I guess you have to be an old guy like me to remember Keith Jackson, long-time ABC Sportscaster,  shouting “Whoa Nellie”KeithJackson1 but that’s what came to mind as I read the latest on the US Marine Corps audit saga.  Apparently GAO has forced the DoD Inspector General to retract the Marine Corp’s clean audit opinion because of problems in the suspense accounts.  Here’s a link to an article in Defense News with  the details. I have opined on DoD audits on several occasions….first shouting with joy at the accomplishment, then wondering if it really mattered and finally pointing a limp finger towards the Defense Finance and Accounting Service for using “plugs” to fix differences with the Treasury.

So for the record……I told you so!  It’s hard for me to believe that the underlying problem has existed for so long without apparent remedy.  Here’s a link to a 2005 GAO Report in which GAO finds:

Until DOD complies with existing laws and enforces its own guidance for reconciling, reporting, and resolving amounts in suspense and check differences on a regular basis, the buildup of current balances will likely continue, the department’s appropriation accounts will remain unreliable, and another costly write-off process may eventually be required.

 That was almost 10 years ago folks!  This has been a continuing report topic for the GAO with various status updates being published throughout the years.  Here’s an excerpt from the Summary of a more recent GAO report from December 2011:

Neither the Navy nor the Marine Corps have implemented effective processes for reconciling their FBWT[Funds Balance With Treasury].

Huh?  Navy and Marine Corps have been preparing for audit for years and yet it doesn’t appear that they were able to make any progress in fixing a problem identified by GAO way back in 2005 as a key impediment to a clean audit opinion.

So what are the “Suspense Accounts” that are causing such a problem?  Technically GAO defines them as “Combined receipt and expenditure accounts established to temporarily hold funds that are later refunded or paid into another government fund when an administrative or final determination as to the proper disposition is made. “ Translation: The place where a transaction is put when the documentation is incomplete so that it can not be assigned to a specific appropriation before it’s written off.  To get an idea of scale, in 2005 GAO reports it was an absolute value of $35 Billion.  Who knows what it is now? But I point out that it’s just about the amount of the DoD Sequestration hit.  Perhaps if they fixed this problem, sequestration wouldn’t have such a bad effect?  It seems to be to be awfully hard to go the the Hill and say that $35 Billion in spending cuts would kill the Department, when they are not exactly sure about $35 Billion already sitting around.  Those on  the defensive will say that the differences are eventually reconciled, but I am skeptical…and since they are already written off, does it really matter?  My guess is the money goes straight into the US Treasury Black Hole that all checks drafted to the US Treasury go…you know…that big ever increasing dense ball of greenbacks sitting in the Treasury Department basement.

This problem is precisely why DoD needs to get on with the audit….so they can be sure they know where the money is and provide accurate estimates of the impact of budget cuts.  If my kids came to me and said” We need more allowance”, and when asked what did they did with allowance I already gave them they reply, “We don’t know, but we need more!”, I would be highly skeptical of their requirement.

As it stands now, the Army, Navy, Air Force and Marines will spend around $45 Million this year for audits they already know will fail because of the DFAS Suspense Account issues.   Why not spend the money to fix that problem before plodding ahead for a pre-ordained result? To be sure it’s a tough problem…after all we have her unable to fix it for 10 years.

Who’s to blame, you ask?  Well, there’s enough to go around….DFAS for not fixing it, but also the Services for not taking actions to fix the paperwork before it gets to DFAS.  Ultimately, the fault probably rests on the shoulders of all those folks in DoD who improperly enter information at the command level.  I would also guess that given the kludge of IT systems required to record transactions, that errors are also introduced between systems, hand-jammed data is incorrectly transferred, and  by improperly trained people entering data.  This is what is referred to as a “Wicked Problem,” in management parlance. A “Wicked Problem” is defined as ” a problem that is difficult or impossible to solve because of incomplete, contradictory, and changing requirements that are often difficult to recognize. The use of term “wicked” here has come to denote resistance to resolution, rather than evil. Moreover, because of complexity, the effort to solve one aspect of a wicked problem may reveal or create other problems. For more info on “Wicked Problems” you can download the original paper written by C. West Churchman for $30 here.

Is the problem of unresolved transactions so complex that it defies correction?  Perhaps given the current architecture within DoD it is, and that alone is reason for the new DCMO to tackle it.  A fresh look is needed and the DCMO might be just the person to do it.  Right now DoD has an acting DCMO, and given the current political environment, I am not too sure the current nominee, Peter Levine will get confirmed….But for now Mr. Dave Tillotson has the dot.  Can someone in an “acting” position draw enough water to tackle this problem?  Don’t know, but why not give it a whirl. If and when Mr. Levine gets in the chair, it would be a great legacy to fix this problem once and for all.  Given his reputation, I have no doubt that he could fix it.

 

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Plugging the DFAS Dam

I saw a reprint of an article done by Reuters the other day entitled “Special Report: The Pentagon’s doctored ledgers conceal epic waste” and even though it’s almost a year old, I think it still applies.  DFAS Leak height= In just a few days, all the big accounting firms that do business with DoD will be submitting proposals to conduct audits of the the Army, Navy and Air Force Statements of Budgetary Activity (SBA)……that’s a high level balance sheet that has little applicability to the actual management of anything.  Experience in auditing the Marine Corps proved that trying to do anything else was futile.  One just has to read the Reuters article on “Plugs” to see just how daunting a task auditing any of the services really is.  Inventing phantom ledger entries or “plugs” to explain away imbalances in the “goes-intas” and the “goes-outtas” is apparently the norm at the Defense Finance and Accounting Service.  What’s a little disturbing about this whole audit thing, is that many of these sins will go unexamined because they do not necessarily impact the SBA. See my article “DoD Audit:  Is the cure worse than the disease?” for the details about just what the SBA is all about.

In fairness, I think the article’s title is misleading in that I doubt if the motivation behind plugging in numbers is a desire to conceal waste, but rather it’s the normal way of balancing the books in order to satisfy the Treasury Department.  The real motivation is to keep the heat off oneself ……does that sound familiar?  Think about recent VA scandal…..I doubt if the real motivation was to  make sure deserving veterans didn’t get appointments, but it was done to keep the front office happy.  Never mind that the green eye shades at Treasury are apparently more interested in balancing the numbers as opposed to the reliability of the numbers used to balance (a la VA!).  It’s been going on for years, so that’s a good indication that nobody cares.  Unlike the VA however, the DFAS guys were caught and still nobody cares!

But we do care these days about getting the DoD auditable.  And the Pentagon’s efforts to get to auditability have been extensive and expensive, with some modest results.  Take a look at the USMC……their SBA has passed audit scrutiny for two years running now.  Some months ago I wrote an article on the USMC audit, “Hall of Heroes and Auditors“, which is worth reviewing for context for what follows.

I support the efforts of DoD to get auditable, but only in so far as those efforts are done for the right reasons….not to keep the front office happy, but to make sure DoD is properly accounting for dollars….When they say “We don’t have money for pay raises”, or “Retiree health care is costing us too much,” or “We have to furlough employees,” are they using data from the system that “plugs” in nonexistent dollars to satisfy the front office?  Who knows if the numbers they are quoting are accurate, given the evidence that the numbers are inherently inaccurate!  My point is DoD audits are only interesting science projects for green eyeshades if we are only auditing things that don’t matter.  SBA audits are interesting, but not compelling. We must follow on and audit all the other aspects of DoD financial accounting and property, plant and equipment inventories. That’s the plan (I think), but after DoD has spent collectively over $200 Million just to get to SBA audit, will they have the fortitude to go further into the things that really matter? Will Congress let them? Will the operational pressures in an very unstable, terrorist filled world trump mundane administrative exercises like audits? Roulette height=Stay tuned, but I think with sequestration about to raise its head once again, the President under pressure to mount military responses to multiple spots around the globe, and political stalemate in the Congress, betting on continued funding for DoD audits is at best like wagering on red or black at the roulette wheel at Trump Towers in Atlantic City (ooppppsss, it’s out of business, so how about The Nugget in Las Vegas?).

So don’t get too worked up and break out the champagne  if it turns out the the service SBA’s pass audit ( they are likely to do so because of the limited scope and usefulness).  Instead remember:

  1. It’s only the SBA, a very limited look into DoD finances.
  2. No one uses the SBA to manage anything.
  3. It only looks at one year…Past sins are ignored.
  4. DFAS is still using plugs to balance the books.
  5. It may be done by the cheapest bidder (As a stockholder, would you want the firm you have your life savings in to use the cheapest auditor?).
  6. Because all the audits are being done at the same time, chances are all the firms will be battling for manpower and may not be hiring the most competent auditors (assuming they hire auditors).  We may even have to open up an auditor refugee camp to handle the influx of auditors to the Beltway.

So to sum it all up, I wholeheartedly support ensuring the DoD manages it funds effectively, efficiently and accurately.  I’m not sure an audit of the SBA does any of those things. Victory is not a clean opinion on the SBA, it’s a clean opinion on the whole enchilada.

PS: Please do not reverse the order of this article’s title, no matter how applicable it may seem 😉

 

 

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DoD Audit: Is the Cure Worse Than the Disease?

I can’t let the recent articles in the press regarding DoD audits go by without commenting.  The headline on the Federal Times web site was “DoD falls behind audit goals – again”.  Again is the operative word here.  Some of the reasons cited for the slide (paraphrasing here): two wars in the last decade, overwhelming size and complexity, furloughs, shut-downs and the general “drain” brought on by an infectious STD in DoD (That’s Sequestration Transmitted Disease).  Preparing for audits has been on the DoD leadership’s plate for over a decade as is regularly cited as the reason for many fits and starts in DoD:  Lean Six Sigma, ERPs, Business Transformation, cost initiatives, process standardization, etc..

But in truth, there has been some progress.  Let’s not forget the US Marine Corp’s efforts in that regard (not mentioned in the article).  I have commented on the USMC progress a few months back in the Hall of Heroes and Auditors article. As of today, the USMC is the only Service to complete an audit of its Statement of Budgetary Activity (SBA), even if it’s only for one year.  We are still awaiting the results of the latest audit of the USMC SBA.  There is every reason to expect that it too will be “clean” and thus the USMC will have two successive years of clean opinions on their SBA.  This was done on purpose, because the previous years were so gooned up that it was pointless to spend the amount of time and money necessary to get things up to speed for water already under the budget bridge.  The SBA can be thought of as that part of the SBR that covers most appropriations and transactions, but not prior-year appropriations and therefore not affected too much by prior-year sins.  It is also accurate to say that DoD is focused on achieving an audit on only one part for the Department’s financials, the Statement of Budgetary Resources (SBR).

In many areas audit readiness is being achieved by manual work-arounds and other non-sustainable means instead of actually simplifying and consolidating the rat’s nest of kludged together systems and processes that have evolved over the ages.  The result of this type of preparation will be continued costly audits, with each one being just as costly as the next.  The only way to save costs is to move to reliance on internal controls instead of conducting on-site, manual inspection of paperwork, digital or otherwise.  (Most private sector audits move rapidly to reliance on internal controls because it’s cheaper and faster).  Reliable internal controls are a result of standard processes, interoperable systems, standardized data and legacy reduction, so the more we focus on the audit (at the expense of fixing internal controls) the more money we will spend.  This means that the 2018 audit is likely to be just as costly as the 2015 audit.  That, my friends, is unsustainable.

We haven’t  gotten around to auditing property records and equipment inventories (existence and completeness), for example. The plan is to do that later, after tackling the SBR.  The problem I have with all the DoD audit rumpus is that no one really understands DoD financial ops and the statements behind them outside a few budgetary monks within DoD.  Contrary to just about any commercial company, no one…not management, not customers, not investors, no one but a few accountant types at GAO and OMB look at these things.  We don’t measure the success of DoD or the desirability of investment in it by its financials.  In the real world, when a company releases its financial reports, stock prices either surge or shrink, depends on the results.  Not so in DoD. DoD Financial Statements do not reflect its performance or effectiveness.   If (almost) no one uses them, then why all the hype?

First things, first.  What the heck is a Statement of Budgetary Resources anyway?  Here’s the definition from GAO’s Financial Audit Guide, Auditing the Statement of Budgetary Resources, dated December 2001:

The SBR and related disclosures provide information about budgetary resources made available to an agency as well as the status of those resources at the end of the fiscal year. The SBR and related note disclosures serve as a tool to link budget execution data in an agencys financial statements to information reported in the actualcolumn of the Program and Financing (P&F) Schedules in the Appendix of the Budget of the United States Government (hereafter referred to as the Presidents Budget). Coupled with the analysis of other budgetary data, the SBRs linkage to the Presidents Budget provides a means to help assess the reliability of budgetary data reported in the Presidents Budget. 

Whew!  How about them apples?  Let me decode for you: The SBR makes it easier for OMB to aggregate the budget numbers.  For the “Show and Tell” crowd, here’s a copy of the Navy’s 2013 SBR.  By the way, don’t go looking for it because it is buried so far down in the paper stack that it’s impossible to find by mere mortals.
Navy 2013 SBR
WoW!  For you purists out there, here is the link to the complete set of Navy’s 2013 Financial Statements along with the accompanying footnotes. I suggest putting it in the bottom of your parrot’s cage so it can memorize the numbers and amaze your accountant friends when they visit.

This is what the little red guy with a pointy tail on my left shoulder says:  So far the Services have spent hundreds of millions of dollars to get this statement correct (Audit Readiness, financial system modernization, ERPs, etc).  But take a look at it.  Is this what really matters?  Our benefactor, the US Congress has never thought we do that bad of a job in accounting for the money.  The money just keeps coming and we are in little danger of Congress withholding the bucks because the SBRs don’t balance.  When we told them we spent $800 on a toilet seat, no one said, “Your accounting practices must be flawed.”  Nope, they believed us.  Why we spent the $800 is far more important than accuracy of the number.   DoD knows to the required degree of accuracy (you engineers will remember the significant digits drill) where the money is.  When you are dealing with half a Trillion dollars, what’s a few million among friends?  Is it worth paying the King’s Treasure to get to the finite level of detail demanded by auditors?  In my previous life as the Navy’s budget guy, I would have declared this a “Science Project for the Green Eye Shades.” There is no doubt that DoD can do a better job at managing the money, but is it really worth the Billions we will ultimately spend to get it THAT right? Maybe DoD audit is too big of a bite to make it worth the cost.  Why not focus on specific processes and make them right.  Get pay and allowance correct, get inter-service transactions right, get contract payments right, etc.  If the individual parts are good, why waste a lot of time and money messing around with trying to combine them.  Let’s spend that money somewhere else.

On the other shoulder, the little guy with the nightgown and halo says: Even if the financial processes in DoD are off by one-tenth of one percent, that’s a lot of money.  Anything we can do to increase confidence in the management of our national treasure is worth the effort.  If these things weren’t valued, why have a GAO?  Obviously the American people have made a judgment that accurate accounting is important.  Why should the DoD be exempt from the requirements levied on every other part of our government year after year after year?  Oh by the way, it’s the law of the land that all federal agencies will have auditable financial statements.  The DoD is not above the law, therefore they must do it (Never mind that DoD has ignored the CFO Act for many years, or at least failed to comply with no consequences!).  Finally, audits can save money.  In the case of the Marine Corps, correcting errors in accounting systems and procedures found during the audit resulted in identifying additional funds it could use.  It’s interesting that the Department almost never spends more money that it has been appropriated because the system is set to err on the side of caution.  Anti-Deficiency Act violations are low.  Just look at the amount of unobligated balances at the end of each year.  If our accounting procedures were better, we could spend that money.

So who’s right….left shoulder or right shoulder?  Hard to say, but the answer to this question falls squarely into the “Tough Decision” category and our leadership should seriously consider what to do.  I would not  push the “Audit” button just because it sounds like a good idea.   A lot of money rides on this decision.  It’s easy to say “It’s good business to spend money on audits,” but others will say, “At what cost?.  At the macro level DoD does an adequate job managing the money, so spend those resources on combating Cyberterrorism, readiness, R&D investments to ensure our dominance on the battlefield or on taking care of Wounded Warriors.”

In the end, I say we should focus less on the obsession with a clean audit opinion, and more on fixing the processes and systems, once and for all, that we use to manage the money.  I don’t think it’s nearly as good as it could be, but it’s certainly not as bad as some assert.

Thanks to BG Roger Scearce USA (Ret.) and Deb Delmar of Vanguard Advisors LLC  for their assistance on this article.

Disclaimer:  I’m sure I may not  have gotten some of the technical terms exactly right, but for the intended audience (non- DoD Budget Monks and Scribes) it’s close enough!

 

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Hall of Heroes and Auditors

USMC_Audit_AwardIt’s like pushing a heavy block across sandpaper.”  That’s what DoD Comptroller Bob Hale said yesterday in the Pentagon’s Hall of Heroes  at a ceremony celebrating a significant milestone– the USMC’s clean audit opinion on the current year Statement of Budgetary Resources.  For those in the federal financial world, that is BIG news!  In typical USMC “Out in Front” style, the Corps took on the task of being the first Service to declare audit readiness  and complete the process to prove they are ready.  It was an effort like no other seen in DoD financial management.  I’m hoping that over the next two years there will be three more ceremonies celebrating audit completion of the remaining Services.  The DoD IG is skeptical given the wording in their recent report to Congress for good reason. These audits are complex, large and little understood by most in the DoD.  The USMC audit involved hundreds, if not thousands, of Marines, civilians and auditors from Grant Thornton LLP (GT)  (lead by audit partner Tracy Greene) and its subcontractors and involved combing through terabytes of data and tons of paperwork around the globe!  One can imagine how much more complex it will be to audit the Army, Navy and Air Force.

So what can the Services learn from the USMC accomplishment?  As the Partner at GT responsible for the DoD account when this journey began I have a few observations from a non-CPA:

  • All senior leaders need to be united in their support of the audit and not just those in  financial management.  In other words, this has to be a priority for the Service Secretary, the  Service chief and every commander in the field.  Most of the transactions take place in individual commands, far removed from the Pentagon. They have far more impact on a successful audit that those in the Pentagon.
  • Don’t let the audit become a bill payer.  Given that there’s well over a trillion dollars  involved, the costs of an audit are immaterial.
  • Fix problems as they arise.  Don’t play “Stump the Monkey” and protect rice bowls. Make it a cooperative effort.
  • Have a dedicated team devoted to accomplishing the audit (a Task Force AUDIT) whose sole purpose is audit.  You can’t be successful by dumping yet another task on an already stressed workforce.
  • Don’t rely on IT systems.  In the end, most problems are people-related.

When I was in uniform I thought audits were just “science projects for the green eyeshades.”  After all, the Congress continued giving us money and rarely questioned our accounting.  If we told Congress we spent $800 for a toilet seat, they believed us!  No one ever said, “Surely there was just a bookkeeping error.”  They believed us.  But I was wrong then because I have come to realize that audits are not about making sure the credits and debits balance.  They are about ensuring the DoD can manage its money, not by figuring out how much money they have after the fiscal year is over, but knowing how much they have today and every day.  DoD is so unsure about balances that it maintains huge cushions of cash in many accounts just to make sure they do not violate the Anti Deficiency Act.  Imagine not looking at your checkbook for six months and writing checks anyway because you know you have put way more money in your account than you could ever spend.  That’s basically what happens.  But the budget environment has changed and money is getting tight.  That cushion is not likely to be around for long.  In order to still accomplish their missions, the Services must have an accurate accounting of their money day-by-day.  Audits allow the services to have confidence in their accounting procedures and thereby allow them the ability to efficiently obligate and track money.

Let’s stop planning and start doing the Service audits and in doing so become even better stewards of the nation’s treasure.

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