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...er_alerts/ACCOUNTABILITY FOR FUNDS PROVIDED IN RESPONSE TO NATURAL DISASTERS.md
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posted-date: 2017-09-13 | ||
author: Amy Bontrager | ||
title: "ACCOUNTABILITY FOR FUNDS PROVIDED IN RESPONSE TO NATURAL DISASTERS" | ||
permalink: /controller-alert-accountability-for-funds-provided-in-response-to-natural-disasters/ | ||
--- | ||
*Controller Alerts are designed to bring your attention to emerging financial management issues where the Office of Management and Budget (OMB) believes further action may be warranted, but do not constitute official guidance or include specific tasks for agencies beyond consideration of appropriate steps to address the issue. These Alerts are intended to make sure that the Chief Financial Officer (CFO) community is aware of key issues. This Alert includes notice to the Council of the Inspectors General on Integrity and Efficiency (CIGIE) because of reporting specific for Inspectors General. Additional Controller Alerts are available at [https://cfo.gov/controller-alerts/](https://cfo.gov/controller-alerts/).* | ||
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The purpose of this Controller Alert is to remind Executive departments and agencies (“agencies”) of their responsibilities for managing risk and maintaining improper payment protocols in disaster situations. | ||
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On September 8, 2017, President Trump signed into law the Continuing Appropriations Act, 2018 and Supplemental Appropriations for Disaster Relief Requirements Act, 2017. This Act provides approximately $15.25 billion in aid for survivors of natural disasters like Hurricane Harvey and other impacted communities. In addition, this Act invoked the Stafford Act imposing certain funding restrictions. Because relief funding of this magnitude often carries additional risk of misallocation due to fraud, waste or abuse, agencies must ensure that the funds appropriated under the Act are used for their intended purposes and are appropriately accounted for. | ||
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Towards that end, this Controller Alert provides an overview of the risk-based internal control planning for all funding for natural disasters as reflected in OMB Memorandum M-16-17 and OMB Circular No. A-123, Management’s Responsibility for Enterprise Risk Management and Internal Control. | ||
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## <u>Managing Risk in Disaster Situations</u> | ||
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As required by OMB Circular No. A-123, each agency has overall responsibility for establishing internal controls to manage the risk of fraud. Agencies must use a risk-based approach to design and implement financial and administrative control activities to mitigate identified fraud risks. In assessing risk in disaster situations, agencies should leverage their existing enterprise risk management processes, including assessments that contributed to the development of initial risk profiles and efforts to integrate fraud risks identified and linked to formal internal controls. | ||
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This approach includes establishing risk tolerances in disaster situations. Agencies must balance their priorities to fulfill the program mission, such as effectively and expediently disbursing funds or providing services to beneficiaries, and taking actions to safeguard taxpayer dollars from improper use. In disaster situations, fraud risks are higher than under normal circumstances because the need to provide services quickly can hinder the effectiveness of existing controls and create additional opportunities for individuals to engage in fraud. As a result, Federal managers face the additional challenge of balancing their mission to provide assistance quickly with implementing controls to address the increased risk of fraud. | ||
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Risk tolerance reflects a Federal manager’s willingness to accept a higher level of fraud risks and may vary depending on the circumstances of the program. When determining risk tolerances in disaster situations, managers must weigh the program’s operational objectives of expeditiously providing assistance against the objective of lowering the likelihood of fraud as activities to lower fraud risks may cause delays in service. | ||
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## <u>Improper Payments</u> | ||
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As required by Appendix C to OMB Circular No. A-123, Requirements for Effective Estimation and Remediation of Improper Payments, if a low risk program experiences a significant change in legislation and/or a significant increase in its funding level, agencies are required to reassess the program’s risk susceptibility during the next annual cycle, even if it is less than three years from the last risk assessment. Additional funding received after a natural disaster could create a significant increase in funding level and require agencies to reassess the program’s risk in accordance with OMB Circular No. A-123. | ||
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To further assist in ensuring accountability for funds provided for disaster relief, OMB will work with the Chief Financial Officer (CFO) community to develop a more permanent mechanism to track costs expended. Questions about this Controller Alert can be directed to the Office of Federal Financial Management or to Regina Kearney at [email protected]. |
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...DS FOR A SUBSET OF PUBLIC FINANCIAL ASSISTANCE DATA FOR ENTITY ADDRESS ZIP+4.md
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--- | ||
posted-date: 2017-09-13 | ||
author: Amy Bontrager | ||
title: "ACCOUNTABILITY FOR FUNDS PROVIDED IN RESPONSE TO NATURAL DISASTERS" | ||
permalink: /controller-alert-accountability-for-funds-provided-in-response-to-natural-disasters/ | ||
posted-date: 2017-04-03 | ||
author: CFO Council | ||
title: "ACKNOWLEDGING INCONSISTENT RECORDS FOR A SUBSET OF PUBLIC FINANCIAL ASSISTANCE DATA FOR ENTITY ADDRESS ZIP+4" | ||
permalink: /controller-alert-acknowledging-inconsistent-records-for-a-subset-of-public-financial-assistance-data-for-entity-address-zip4/ | ||
--- | ||
Controller Alerts are designed to bring your attention to emerging financial management issues where the Office of Management and Budget (OMB) believes further action may be warranted, but do not constitute official guidance or include specific tasks for agencies beyond consideration of appropriate steps to address the issue. These Alerts are intended to make sure that the Chief Financial Officer (CFO) community is aware of key issues. This Alert includes notice to the Council of the Inspectors General on Integrity and Efficiency (CIGIE) because of reporting specific for Inspectors General. Additional Controller Alerts are available at [https://cfo.gov/controller-alerts/](https://cfo.gov/controller-alerts/). | ||
*Controller Alerts are designed to highlight emerging financial management issues that may require agency attention or action. These Alerts are intended to inform the Chief Financial Officer (CFO) community of key issues where the Office of Management and Budget (OMB) believes further action may be warranted, but do not constitute official guidance or prescribe specific tasks for agencies beyond consideration of appropriate steps to address the issue.* | ||
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The purpose of this Controller Alert is to remind Executive departments and agencies (“agencies”) of their responsibilities for managing risk and maintaining improper payment protocols in disaster situations. | ||
The purpose of this Controller Alert is to acknowledge that entity addresses for a subset of financial assistance records on [USAspending.gov](https://www.usaspending.gov/#/) may have values in the ZIP+4 field that are different from their authoritative source in the System for Award Management (SAM). | ||
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On September 8, 2017, President Trump signed into law the Continuing Appropriations Act, 2018 and Supplemental Appropriations for Disaster Relief Requirements Act, 2017. This Act provides approximately $15.25 billion in aid for survivors of natural disasters like Hurricane Harvey and other impacted communities. In addition, this Act invoked the Stafford Act imposing certain funding restrictions. Because relief funding of this magnitude often carries additional risk of misallocation due to fraud, waste or abuse, agencies must ensure that the funds appropriated under the Act are used for their intended purposes and are appropriately accounted for. | ||
Pursuant to the [Federal Funding Accountability and Transparency Act of 2006 (FFATA)](https://www.govinfo.gov/content/pkg/BILLS-109s2590enr/pdf/BILLS-109s2590enr.pdf), Public Law 109-282, Federal agencies report information about their financial assistance awards for display on [USAspending.gov](https://www.usaspending.gov/#/). The requirements were expanded by [the Digital Accountability and Transparency Act of 2014 (DATA Act)](https://www.govinfo.gov/content/pkg/PLAW-113publ101/pdf/PLAW-113publ101.pdf), Public Law 113-101, which amended FFATA. OMB subsequently issued implementation guidance and requirements for agencies as reflected in OMB Memoranda [M-15-12](https://obamawhitehouse.archives.gov/sites/default/files/omb/memoranda/2015/m-15-12.pdf) [MPM-2016-03](https://obamawhitehouse.archives.gov/sites/default/files/omb/financial/memos/management-procedures-memorandum-no-2016-03-additional-guidance-for-data-act-implementation.pdf), and [M-17-04](https://obamawhitehouse.archives.gov/sites/default/files/omb/memoranda/2017/m-17-04.pdf). | ||
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Towards that end, this Controller Alert provides an overview of the risk-based internal control planning for all funding for natural disasters as reflected in OMB Memorandum M-16-17 and OMB Circular No. A-123, Management’s Responsibility for Enterprise Risk Management and Internal Control. | ||
SAM is an official website of the U.S. Government where entities register to do business with the Federal government. Part 25 of Title 2 of the Code of Federal Regulations includes requirements for specific entities to be registered in SAM prior to submitting an application for a financial assistance award. Additionally, M-17-04 requires agencies to ensure that the registration data they submit about financial assistance awardees matches with the information in SAM, including the awardee’s physical address. OMB, the Department of the Treasury, and Federal awarding agencies are currently working together on a new reporting mechanism that will improve data quality of public information once implementation is complete. In this interim period, in order to maximize the accuracy and completeness of the data that agencies are able to provide, OMB acknowledges that for a subset of reported financial assistance records, the ZIP+4 field for entity address will not match the authoritative source in SAM. This acknowledgement stands until a new reporting mechanism is put in place. | ||
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##Managing Risk in Disaster Situations | ||
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As required by OMB Circular No. A-123, each agency has overall responsibility for establishing internal controls to manage the risk of fraud. Agencies must use a risk-based approach to design and implement financial and administrative control activities to mitigate identified fraud risks. In assessing risk in disaster situations, agencies should leverage their existing enterprise risk management processes, including assessments that contributed to the development of initial risk profiles and efforts to integrate fraud risks identified and linked to formal internal controls. | ||
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This approach includes establishing risk tolerances in disaster situations. Agencies must balance their priorities to fulfill the program mission, such as effectively and expediently disbursing funds or providing services to beneficiaries, and taking actions to safeguard taxpayer dollars from improper use. In disaster situations, fraud risks are higher than under normal circumstances because the need to provide services quickly can hinder the effectiveness of existing controls and create additional opportunities for individuals to engage in fraud. As a result, Federal managers face the additional challenge of balancing their mission to provide assistance quickly with implementing controls to address the increased risk of fraud. | ||
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Risk tolerance reflects a Federal manager’s willingness to accept a higher level of fraud risks and may vary depending on the circumstances of the program. When determining risk tolerances in disaster situations, managers must weigh the program’s operational objectives of expeditiously providing assistance against the objective of lowering the likelihood of fraud as activities to lower fraud risks may cause delays in service. | ||
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##Improper Payments | ||
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As required by Appendix C to OMB Circular No. A-123, Requirements for Effective Estimation and Remediation of Improper Payments, if a low risk program experiences a significant change in legislation and/or a significant increase in its funding level, agencies are required to reassess the program’s risk susceptibility during the next annual cycle, even if it is less than three years from the last risk assessment. Additional funding received after a natural disaster could create a significant increase in funding level and require agencies to reassess the program’s risk in accordance with OMB Circular No. A-123. | ||
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To further assist in ensuring accountability for funds provided for disaster relief, OMB will work with the Chief Financial Officer (CFO) community to develop a more permanent mechanism to track costs expended. Questions about this Controller Alert can be directed to the Office of Federal Financial Management or to Regina Kearney at [email protected]. | ||
Please contact [[email protected]]([email protected]) with any questions. |
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... the Program Management Office for the Financial Management Line of Business.md
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posted-date: 2013-04-29 | ||
author: CFO Council | ||
title: "Announcing the Department of Treasury as the Program Management Office for the Financial Management Line of Business" | ||
permalink: /Controller-Alert-Finanical-Management-Line-of-Business-4.29.13/ | ||
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[Announcing the Department of Treasury as the Program Management Office for the Financial Management Line of Business](/assets/files/Controller-Alert-Finanical-Management-Line-of-Business-4.29.13.pdf) |
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controller_alerts/CATALOG OF FEDERAL DOMESTIC ASSISTANCE NUMBERING SCHEMATIC.md
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posted-date: 2016-12-22 | ||
author: CFO Council | ||
title: "CATALOG OF FEDERAL DOMESTIC ASSISTANCE NUMBERING SCHEMATIC" | ||
permalink: /controller-alert-catalog-of-federal-domestic-assistance-numbering-schematic/ | ||
--- | ||
*Controller Alerts are designed to highlight emerging financial management issues that may require agency attention or action. These Alerts are intended to inform the Chief Financial Officer (CFO) community of key issues where the Office of Management and Budget (OMB) believes further action may be warranted, but do not constitute official guidance or prescribe specific tasks for agencies beyond consideration of appropriate steps to address the issue.* | ||
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The purpose of this Controller Alert is to provide notification to Federal agencies that effective October 1, 2018, the numbering construct associated with the Catalog of Federal Domestic Assistance (CFDA) titles will be changed from ##.### to ###.#### The prefix will align with the 3-digit Common Government-wide Accounting Classification (CGAC) agency code used in the Treasury Account Symbol (TAS) listed in OMB Circular A-11 Appendix C, and the unique suffix number will be revised from 3 to 4 digits to allow additional space for future entries. During this transition, GSA will provide system users with information mapping continuing CFDA titles to their revised CFDA numbers. | ||
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##Background | ||
The Federal Program Information Act (Public Law 95-220) was signed into law in December 1977 and later amended in October 1983 (Public Law 98-169). This Act serves as the mandate for collection and distribution of current information on Federal assistance programs available at CFDA.gov, which is managed by the Integrated Award Environment at GSA. Each CFDA title has an associated number for purposes of tracking. Current OMB guidance regarding CFDA is located at 2 C.F.R. Part 200. | ||
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GSA and agencies have notified OMB of the concern that agencies may run out of space to create new titles within the current numbering schematic. In response to his concern and after requesting information regarding the impact of this change on existing agency systems, GSA and OMB determined that the numbering schematic will change effective October 1, 2018 allowing the unique suffix number length to be 4 digits. | ||
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It was also determined that the CFDA number prefix should align with the 3-digit CGAC agency code used in the TAS listed in OMB Circular A-11 Appendix C. This is consistent with the final [data standards](https://portal.max.gov/portal/assets/public/offm/DataStandardsFinal.htm) established in implementation of the Digital Accountability and Transparency Act of 2014 (DATA Act), which requires that agencies use the 3-digit CGAC as the awarding and funding agency code. | ||
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The timing of this change coincides with the requirement for the Financial assistance community to implement the Activity Address Code (AAC) for awarding and funding offices as required by [MPM-2016-03](https://www.whitehouse.gov/sites/default/files/omb/financial/memos/management-procedures-memorandum-no-2016-03-additional-guidance-for-data-act-implementation.pdf). | ||
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If you have any questions regarding this alert please contact Rhea Hubbard ([[email protected]]([email protected])) |
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...r_alerts/DATA Act Implementation and Offices for Financial Assistance Awards.md
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posted-date: 2015-12-04 | ||
author: CFO Council | ||
title: "DATA Act Implementation and Offices for Financial Assistance Awards" | ||
permalink: /controller-alert-data-act-implementation-and-offices-for-financial-assistance-awards/ | ||
--- | ||
[DATA Act Implementation and Offices for Financial Assistance Awards](/assets/files/CONTROLLER-ALERT-DATA-Act-Implementation-and-Offices-for-Financial-Ass....pdf) |
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...and Ensuring Accurate, Complete and Consistent Data on Federal Real Property.md
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posted-date: 2012-08-31 | ||
author: CFO Council | ||
title: "Efficient Spending on Federal Conferences and Ensuring Accurate, Complete and Consistent Data on Federal Real Property" | ||
permalink: /controller-alert-efficient-spending-on-federal-conferences-and-ensuring-accurate-complete-and-consistent-data-on-federal-real-property-8.31.121/ | ||
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[Efficient Spending on Federal Conferences and Ensuring Accurate, Complete and Consistent Data on Federal Real Property](/assets/files/CONTROLLER-ALERT-Efficient-Spending-on-Federal-Conferences-and-Ensuring-Accurate-Complete-and-Consistent-Data-on-Federal-Real-Property-8.31.121.pdf) |
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