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Questions and Answers for Statement of Federal Financial Accounting Standards (SFFAS) No. 47 Working Group review


What guidance does Statement of Federal Financial Accounting Standards (SFFAS) 47, Reporting Entity, provide for evaluating whether grant recipient organizations should be included (by being either consolidated or disclosed) in the federal government’s financial statements?

SFFAS 47 provides the following three principles:

[20] This Statement provides three principles for determining which organizations should be included12 in the government-wide GPFFR (see paragraph 21-35). This Statement also provides an additional principle requiring inclusion of organizations if excluding them would be misleading (see paragraph 36-37). The three principles are to be applied without considering whether the relationship is temporary or permanent. However, whether the relationship is temporary or permanent would influence the likelihood that the entity exhibits the characteristics of a consolidation entity or of a disclosure entity.

[21] An organization meeting any one of the three principles below is included in the government-wide GPFFR:

  1. In the Budget
  2. Majority Ownership Interest
  3. Control with Risk of Loss or Expectation of Benefit

[Footnote12] ”Included” means the information is either consolidated or disclosed

Paragraphs 22-35 provide a detailed explanation of the three principles listed in paragraph 21.  In particular, the following paragraphs should be considered regarding grant recipient organizations:

Situations Where Control Does Not Exist

[33] Because of the federal government’s broad powers and economic influence, control should not be inferred from either:

  1. authority to exercise regulatory powers over an organization; or
  2. economic dependency of the organization on the federal government.

[34] The federal government has the power to regulate many organizations by use of its sovereign and legislative powers. For example, the federal government has the power to regulate the behavior of organizations by imposing conditions or sanctions on their operations. However, the governing bodies of the regulated organizations make decisions within the regulatory framework. Regulatory powers do not constitute control for purposes of this Statement because the federal government’s interest in these organizations extends only to the regulatory aspects of the operations.

[35] Certain organizations may be economically dependent on the federal government but ultimately retain discretion as to whether to accept funding or do business with the federal government. For example, many not-for-profit organizations rely on federal government funding but that does not mean they are controlled by the federal government. Although the federal government may be able to influence organizations dependent on federal funding or business through purchasing power, the federal government typically does not govern their financial and operating policies.

Where will agencies find instructions for reporting disclosure entities and other instructions such as how to report prior periods for changes in consolidation entities?

SFFAS 47 is effective in periods beginning after September 30, 2017, with earlier implementation not permitted. Guidance is provided by Federal Accounting Standards Advisory Board (FASAB) in SFFAS 21, Reporting Corrections of Errors and Changes in Accounting Principles. In addition, implementation guidance will be provided by the Office of Management and Budget (OMB) in Circular A-136.

FASAB guidance: The Board discussed implementation of SFFAS 47 at the October 2015 Board meeting. Conclusion: Prior periods should not be restated, in accordance with paragraph 13 of SFFAS 21, Reporting Corrections of Errors and Changes in Accounting Principles (see text of paragraph 13 below).

OMB guidance: : Detailed instructions for reporting consolidation and disclosure organizations will be provided in OMB Circular A-136, Financial Reporting Requirements.  In addition to the FY 2018 issuance of Circular A-136, OMB will likely provide advance guidance in Circular A-136 to assist agencies in planning for FY 2018 reporting in compliance with SFFAS 47 and paragraph 13 of SFFAS 21.

TFM guidance: A TFM bulletin will be published in July 2016 providing a summary of SFFAS No. 47 and listing all agency determinations of consolidated, disclosure, and related party as well as the component entity.

Text of SFFAS 21, Reporting Corrections of Errors and Changes in Accounting Principles, paragraph 13:
[13] Unless otherwise specified in the transition instructions section of a new FASAB standard, for all changes in accounting principles that would have resulted in a change to prior period financial statements:
(a) The cumulative effect of the change on prior periods should be reported as a “change in accounting principle.” The adjustment should be made to the beginning balance of cumulative results of operations in the statement of changes in net position for the period that the change is made.
(b) Prior period financial statements presented for comparative purposes should be presented as previously reported; and
(c) The nature of the changes in accounting principle and its effect on relevant balances should be disclosed in the current period. Financial statements of subsequent periods need not repeat the disclosure.

Which agencies are considered consolidated?

The following agencies have been recognized as consolidated either by the agency reporting a survey determination as consolidated, or the agency concurred with the Working Group’s determination.

Consolidated Entities

FR Entity Reporting Agency

Administrative Conference of the United States

Administrative Conference of the United States

Advisory Council on Historic Preservation

Advisory Council on Historic Preservation

African Development Foundation             

African Development Foundation

Agency for International Development

Agency for International Development

American Battle Monuments Commission

American Battle Monuments Commission

Appalachian Regional Commission

Appalachian Regional Commission

Appraisal Subcommittee              

Federal Financial Institutions Examination Council

Federal Financial Institutions Examination Council Appraisal Subcommittee

Architect of the Capitol

Architect of the Capitol

Botanic Garden

Architectural and Transportation Barriers Compliance Board

Architectural and Transportation Barriers Compliance Board

Armed Forces Retirement Home

Armed Forces Retirement Home

Barry Goldwater Scholarship & Excellence in Education Foundation

Barry Goldwater Scholarship and Excellence in Education Foundation

Broadcasting Board of Governors

Broadcasting Board of Governors

Bureau of Consumer Financial Protection

Bureau of Consumer Financial Protection

Central Intelligence Agency

Central Intelligence Agency

Chemical Safety and Hazard Investigation Board

Chemical Safety and Hazard Investigation Board

Christopher Columbus Fellowship Foundation

Christopher Columbus Fellowship Foundation

Commission for the Preservation of America’s Heritage Abroad

Commission for the Preservation of America’s Heritage Abroad

Commission of Fine Arts

Commission of Fine Arts

Commission on Civil Rights

U.S. Commission on Civil Rights

Commission on International Religious Freedom - (within Temporary Commissions)

United States - Commission on International Religious Freedom

Commission on Security and Cooperation in Europe

Commission on Security and Cooperation in Europe

Commission to Eliminate Child Abuse and Neglect Fatalities

Commission to Eliminate Child Abuse and Neglect Fatalities

Committee for Purchase from People Who Are Blind or Severely Disabled

Committee for Purchase from People Who Are Blind or Severely Disabled

Commodity Futures Trading Commission

Commodity Futures Trading Commission

Congressional Budget Office

Congressional Budget Office

Congressional-Executive Commission on the People's Republic of China

Congressional-Executive Commission on the People's Republic of China/Other Legislative Branch Boards and Commissions

Consumer Product Safety Commission

Consumer Product Safety Commission

Corporation for National and Community Service

Corporation for National and Community Service

Council of the Inspectors General on Integrity and Efficiency

Council of the Inspectors General on Integrity and Efficiency

Court Services and Offender Supervision Agency for the District of Columbia

Court Services and Offender Supervision Agency for the District of Columbia

Defense Nuclear Facilities Safety Board

Defense Nuclear Facilities Safety Board

Defense Security Cooperation Agency

Defense Security Cooperation Agency

Delta Regional Authority

Delta Regional Authority

Denali Commission

Denali Commission

Department of Agriculture

Department of Agriculture

Department of Commerce

Department of Commerce

National Cybersecurity Center of Excellence

Department of Defense

Aerospace Federally Funded Research and Development Center

Arroyo Center

Lincoln Laboratory

Project Air Force

Software Engineering Institute

Center for Naval Analyses

Department of Defense – Air Force

Department of Defense - Army

Department of Defense – Navy/Marines

US Army Corps of Engineers

Department of Education

Department of Education

Institute of Education Sciences

Department of Energy

Bonneville Power Administration

Department of Energy

Federal Energy Regulatory Commission (FERC)

Southeastern Power Administration

Southwestern Power Administration

Western Area Power Administration

Ames Laboratory

Argonne National Laboratory

Brookhaven National Laboratory

Fermi National Accelerator Laboratory

Idaho National Laboratory

Lawrence Berkeley National Laboratory

Lawrence Livermore National Laboratory

Los Alamos National Laboratory

National Renewable Energy Laboratory

Oak Ridge National Laboratory

Pacific Northwest National Laboratory

Princeton Plasma Physics Laboratory

Sandia National Laboratory

Savannah River National Laboratory

SLAC National Accelerator Laboratory

Thomas Jefferson National Accelerator Facility

Department of Health and Human Services

Department of Health and Human Services

National Cancer Institute

Department of Homeland Security

Department of Homeland Security

Homeland Security Studies and Analysis Institute

Homeland Security Systems Engineering and Development Institute

National Biodefense Analysis and Countermeasures Center

Department of Housing and Urban Development

Affordable Housing Program

Department of Housing and Urban Development

Government National Mortgage Association

Department of Justice

Department of Justice

Federal Prison Industries, Inc (Unicor)

Department of Labor

Department of Labor

Department of State

Administration of Foreign Affairs

Department of State

International Security Assistance

Department of the Interior

Department of the Interior

Department of the Treasury

Department of the Treasury

Federal Financing Bank

Department of Transportation

Department of Transportation

Maritime Administration

Department of Veterans Affairs

Department of Veterans Affairs

District of Columbia - Defender Services/Courts

District of Columbia Courts

Dwight D. Eisenhower Memorial Commission

Dwight D. Eisenhower Memorial Commission

Eisenhower Exchange Fellowship Program

Eisenhower Exchange Fellowship Program

Election Assistance Commission

Election Assistance Commission

Environmental Dispute Resolution Fund

Environmental Dispute Resolution Fund

Environmental Protection Agency

Environmental Protection Agency

Executive Office of the President

Executive Office of the President

Federal Drug Control Programs Federal Fund

Export-Import Bank of the United States

Export-Import Bank of the United States

Farm Credit Administration

Farm Credit Administration

Farm Credit System Insurance Corporation

Farm Credit System Insurance Fund

Federal Communications Commission

Federal Communications Commission

Universal Service Fund

Telecommunications Relay Service Fund (TRS) - the plan administered by Rolka Loube

North American Numbering Plan (NANP) - the plan administered by Welch LLP & Neustar

Federal Deposit Insurance Corporation

Federal Deposit Insurance Corporation

Federal Deposit Insurance Fund and FSLIC Resolution Fund

FDIC Office of Inspector General Federal Fund

Orderly Liquidation Federal Fund

Federal Election Commission

Federal Election Commission

Federal Housing Finance Agency

Federal Housing Finance Agency

Federal Labor Relations Authority

Federal Labor Relations Authority

Federal Maritime Commission

Federal Maritime Commission

Federal Mediation and Conciliation Service

Federal Mediation and Conciliation Service

Federal Mine Safety and Health Review Commission

Federal Mine Safety and Health Review Commission

Federal Retirement Thrift Investment Board

Federal Retirement Thrift Investment Board

Federal Trade Commission

Federal Trade Commission

General Services Administration

General Services Administration

Government Accountability Office

Government Accountability Office

Government Printing Office

Government Printing Office

Gulf Coast Ecosystem Restoration Council

Gulf Coast Ecosystem Restoration Council

Harry S. Truman Scholarship Trust Fund

Harry S. Truman Scholarship Foundation

House and Senate (LEG)

House of Representatives

Indian Law and Order Commission

Indian Law and Order Commission

Institute of Museum and Library Services

Institute of Museum and Library Services

Intelligence Community Management Account

Intelligence Community Management Account

Inter-American Foundation             

Inter-American Foundation

International Trade Commission    

International Trade Commission    

James Madison Memorial Fellowship Foundation

James Madison Memorial Fellowship Foundation

Japan-United States Friendship Commission

The Japan United States Friendship Commission

JFK Center for Performing Arts

JFK Center for Performing Arts

John C. Stennis Center

John C. Stennis Center for Public Service Training and Development

Library of Congress

Library of Congress

Marine Mammal Commission

Marine Mammal Commission

Medicaid and CHIP Payment and Access Commission

Medicaid and CHIP Payment and Access Commission

Medicare Payment Advisory Commission

Medicare Payment Advisory Commission

Merit Systems Protection Board

Merit Systems Protection Board

Military Compensation and Retirement Modernization Commission

Military Compensation and Retirement Modernization Commission

Millennium Challenge Corporation

Millennium Challenge Corporation

Morris K. Udall and Stewart L. Udall Foundation

Morris K. Udall and Stewart L. Udall Foundation

National Aeronautics and Space Administration

National Aeronautics and Space Administration

National Archives and Records Administration

National Archives and Records Administration

National Capital Planning Commission

National Capital Planning Commission

National Council on Disability

National Council on Disability

National Credit Union Administration

National Credit Union Administration

The National Credit Union Share Insurance Fund

The National Credit Union Administration Central Liquidity Facility

The National Credit Union Administration Community Development Revolving Loan Fund

Temporary Corporate Credit Union Stabilization Fund

National Endowment for the Humanities

National Endowment for the Humanities

National Foundation on the Arts and the Humanities

National Endowment for the Arts

National Gallery of Art

National Gallery of Art

National Infrastructure Bank

National Infrastructure Bank

National Labor Relations Board

National Labor Relations Board

National Mediation Board

National Mediation Board

National Railroad Passenger Corporation Office of Inspector General

National Railroad Passenger Corporation Office of Inspector General

National Science Foundation

National Science Foundation

National Transportation Safety Board

National Transportation Safety Board

Neighborhood Reinvestment Corporation

Neighborhood Reinvestment Corporation

Northern Border Regional Commission                   

Northern Border Regional Commission                   

Nuclear Waste Technical Review Board

Nuclear Waste Technical Review Board

Occupational Safety and Health Review Commission

Occupational Safety and Health Review Commission

Office of Compliance

Office of Compliance

Office of Government Ethics

Office of Government Ethics

Office of Navajo and Hopi Indian Relocation

Office of Navajo and Hopi Indian Relocation

Office of Personnel Management

Office of Personnel Management

Office of Special Counsel

Office of Special Counsel

Open World Leadership Center

Open World Leadership Center

Overseas Private Investment Corporation

Overseas Private Investment Corporation

Panama Canal Commission

Panama Canal Commission

Patient-Centered Outcomes Research Trust Fund

Patient-Centered Outcomes Research Trust Fund

Peace Corps              

Peace Corps              

Pension Benefit Guaranty Corporation

Pension Benefit Guaranty Corporation

Presidio Trust

Presidio Trust

Privacy and Civil Liberties Oversight Board

Privacy and Civil Liberties Oversight Board

Public Defender Service

Federal Payment to the District of Columbia Public Defender Service

Railroad Retirement Board

Railroad Retirement Board

Securities and Exchange Commission

Securities and Exchange Commission

Selective Service System

Selective Service System

Senate Preservation Fund

Senate Preservation Fund

Small Business Administration

Small Business Administration

Smithsonian Institution

Smithsonian Network

Friends of the National Zoo

Smithsonian Institution

Social Security Administration

Social Security Administration

Surface Transportation Board

Surface Transportation Board

St. Lawrence Seaway Development Corporation

St. Lawrence Seaway Development Corporation

State Justice Institute

State Justice Institute

The Judiciary

Administrative Office of the United States Courts

Court of Appeals, District Courts, and other Judicial Services

Judicial Retirement Fund

United States Court of Appeals for the Federal Circuit

United States Court of International Trade

Federal Judicial Center

United States Sentencing Commission

Judiciary Engineering and Modernization Center

Supreme Court of the United States

U.S. Capitol Police

U.S. Capitol Police

U.S. Capitol Preservation Commission

U.S. Capitol Preservation Commission

U.S. Equal Employment Opportunity Commission

Equal Employment Opportunity Commission

U.S. Nuclear Regulatory Commission            

U.S. Nuclear Regulatory Commission            

U.S. Postal Service             

U.S. Postal Service             

U.S. Trade and Development Agency

Trade and Development Agency

United States Court of Appeals for Veterans Claims

United States Court of Appeals for Veterans Claims

United States Holocaust Memorial Museum                          

United States Holocaust Memorial Museum                          

United States Institute of Peace

United States Institute of Peace

United States Interagency Council on Homelessness          

United States Interagency Council on Homelessness          

United States Tax Court

United States Tax Court

United States-China Security Review Commission - (within Temporary Commissions)

United States - China Economic Security Review Commission

Vietnam Education Foundation

Vietnam Education Foundation

Woodrow Wilson International Center for Scholars

Woodrow Wilson International Center for Scholars

Which agencies are considered disclosure?

The following agencies have been recognized as disclosure either by the agency reporting a survey determination as disclosure, or the agency concurred with the Working Group’s determination.

Disclosure Entities

FR Entity Reporting Agency

Department of Education

Gallaudet University

Department of the Treasury

Board of Governors of the Federal Reserve System

Corporation for Travel Promotion

Federal Home Loan Mortgage Corp (Freddie Mac)

Federal National Mortgage Association (Fannie Mae)

Federal Reserve System

Securities Investor Protection Corporation

Federal Reserve Banks

Department of Transportation

Amtrak (National Railroad Passenger Service Corp)

Maritime Administration/Employees Association and Regimental Activities Non-Appropriated Fund Instrumentalities

Washington Metropolitan Area Transit Authority

Center for Advanced Aviation System Development (FFRDC & administered by MITRE Corporation)

Federal Communications Commission

Universal Service Administrative Company

National Aeronautics and Space Administration

Jet Propulsion Laboratory

Securities and Exchange Commission

Public Company Accounting Oversight Board

Securities Investor Protection Corporation

WWI Centennial Commission

WWI Centennial Commission

Which agencies are considered related party?

The following agencies have been recognized as related party either by the agency reporting a survey determination as disclosure, or the agency concurred with the Working Group’s determination.

Related Party Entities

FR Entity Reporting Agency

Department of the Treasury

Multilateral Assistance

Federal Communications Commission

Rolka Loube, LLC

NEUSTAR

WELCH LLP

National Credit Union Administration

Federal Financial Institutions Examination Council

Which agencies are considered misleading to include/do not report?

The following agencies have been recognized as misleading to include/do not report either by the agency reporting a survey determination as such, or the agency concurred with the Working Group’s determination.

Misleading to Include/Do Not Report Entities

> > > >

FR Entity

Reporting Agency

 Determination

Office of the Federal Coordinator for Alaska Natural Gas Transportation Projects


Office of the Federal Coordinator for Alaska Natural Gas Transportation Projects

Do not report - Entity closed on March 7, 2015 due to lack of funding.

Department of Defense

National Security Engineering Center

Do not report

Center for Communications and Computing

Do not report

National Defense Research Institute

Do not report

Systems and Analysis Center

Do not report

Department of Education

American Printing House for the Blind

Do not report

Howard University

Do not report

National Technical Institute for the Deaf

Do not report

Department of Energy

Electric Reliability Organization

Do not report

United States Enrichment Corporation Fund

Do not report

Department of the Interior/OSMRE

United Mine Workers of America Benefit Funds

Do not report

Department of the Treasury

Federal Home Loan Banks

Misleading to include

International Monetary Programs

Misleading to Include

Student Loan Marketing Association

Do not report

Resolution Funding Corporation

Do not report - Obligation fulfilled in 2011.

Department of Veterans Affairs

Center for Enterprise Modernization

Do not report

Federal Housing Finance Agency

The Financing Corporation

Do not report

National Science Foundation

National Center for Atmosphere Research

Do not report

National Optical Astronomy Observatory

Do not report

National Radio Astronomy Observatory

Do not report

National Solar Observatory

Do not report

Science and Technology Policy Institute

Do not report

Office of the Nuclear Waste Negotiator

 

Do not report - Inactive

Public Private Investment Funds

Public Private Investment Funds

Do not report - 9/30/13 PPIP was dissolved.  Will not report in FY2018

Recovery Accountability and Transparency Board

Recovery Accountability and Transparency Board

Do not report - Board is closing in Sept 2015.  Will not exist in FY2018.

Securities and Exchange Commission

Standard Setting Body

Misleading to include

Small Business Administration

SCORE

Misleading to include

Tennessee Valley Authority

Babcock and Wilcox

Do not report

Which agencies have a determination discrepancy or have not reported a survey to the SFFAS No. 47 Working Group (WG)?

The WG made a determination for each agency and compared it to the agency’s determination.  The following agencies fell into the determination discrepancy category.  There is ongoing work between the agency and WG to resolve all discrepancies.

There are a few agencies that still have not provided a survey determination.  If you are on this list, and have not provided a survey, please contact janis.doak@fiscal.treasury.gov

Determination Discrepancy/Not Submitted a Survey

FR Entity Reporting Agency Determination Status

Department of Health and Human Services

CMS Alliance to Modernize Healthcare

WG has not received survey.

Department of the Treasury

Institute of American Indian and Alaska Native Culture and Arts Development

Determination Discrepancy - FR Entity is under review.

Corporation for Public Broadcasting

Determination Discrepancy - FR Entity is under review.

Legal Services Corporation

Determination Discrepancy - FR Entity is under review.

Export-Import Bank of the United States

Private Export Funding Corp

WG has not received survey.

National Aeronautics and Space Administration

Center for the Advancement of Science in Space

WG has not received survey.

Space Exploration Technologies Corporation

WG has not received survey.

Blue Origin

WG has not received survey.

Orbital Sciences Corporation

WG has not received survey.

The Boeing Company

WG has not received survey.

Sierra Nevada Corporation

WG has not received survey.

National Railroad Retirement Investment Trust

Railroad Retirement Board

Determination Discrepancy - FR Entity is under review.

Tennessee Valley Authority

Tennessee Valley Authority

Determination Discrepancy - FR Entity is under review.

U.S. Nuclear Regulatory Commission

Center for Nuclear Waste Regulatory Analyses

WG has not received survey.



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