Susan Turnbull:
Below is the
original request for information related to FFATA as you requested.
Please contact me if you have any questions. Also, as we discussed, below
are the hyperlinks to the Reason Foundation Oath of Transparency web pages:
http://www.reason.org/Letter_Oath_of_Presidential_Transparency.pdf
http://www.reason.org/oath/
Irv Faunce
From: Irvin Faunce [mailto:ifaunce@xxxxxxxx]
Sent: Sunday, February 24, 2008
10:24 AM
To: 'usaspending-forum@xxxxxxxxxxxxxx'
Subject: FFATA usaspending.gov
Questions
My name is Irvin
Faunce and I am a former Deputy Commissioner, Financial
Management Service, Department of the Treasury. I am very familiar with
the Federal Government’s financial management process having worked 23
years with the Department of the Treasury, Financial Management Service in SES
systems development, policy, procedure, and executive direction
positions. I have been following the Federal Funding Accountability
and Transparency Act of 2006 from it inception and have the following questions
regarding the content of the usaspending.gov web site:
- The term Federal Award is defined in PUBLIC LAW
109–282, Section 2 as follows:
FEDERAL AWARD.—The term ‘‘Federal award’’—
(A)
means Federal financial
assistance and expenditures that—
(i)
include grants,
subgrants, loans, awards, cooperative agreements, and other forms of financial
assistance; include contracts, subcontracts, purchase orders, task orders, and
delivery orders;
The
current usaspending.gov web site presents Federal Awards as representative of
amount extracted from the GSA FPDS and DOC FAADS systems. These amounts
generally represent the equivalent of Federal “obligations” and not
“expenditures” as defined by the above FFATA Section 2(A)(i)
requirements. Expenditures are disbursements, i.e., Federal payments,
e.g., cash, checks, drafts, electronic funds transfers, and credit card
transactions in accordance with the 1967 President’s Commission on Budget
Concepts. When will expenditure transactions be included in the usaspending.gov
web site?
- Section 2(a)(1)(B)
and (C) of FFATA (see below) do not require the reporting of individual
transactions below $25,000
(B) does not include individual transactions below $25,000;
The Federal grant payment
process accounts for payments in terms of advances and reimbursements that are
generally made in large amounts representing multiple grantee
transactions. How will FFATA report advances and reimbursement, e.g., as
consolidated amounts disbursed to grantees and/or after January 1, 2009,
individual amounts disbursed to subgrantees in accordance with Section
2(a)(1)(B) below?
(B) on and after January 1, 2009, includes any
subcontractor or subgrantee;
In addition, the Federal
contractor payment process accounts for payments to contractors by
consolidating contractor invoices into a single disbursement. How will
FFATA report contractor disbursements, e.g., as consolidated amounts disbursed
to contractors and/or after January 1, 2009, individual amounts disbursed to
subcontractors in accordance with Section 2(a)(1)(B) above?
- Section 2(a)(1)(C)
of FFATA (see below) does not require the reporting of credit card
transactions before October 1, 2008.
(C) before October 1, 2008, does not include credit card
transactions.
Federal Credit Card transactions are processed through commercial banks and are
reimbursed by Federal Government agencies in consolidated amounts less
applicable discounts. How will FFATA report credit card
transactions, e.g., as consolidated amounts disbursed to banks or as individual
credit card disbursements after October 1, 2008? Also, how will credit
card discounts be treated with regard to credit card disbursements?
The above questions are critical with
regard to FFATA reporting as compared to other Federal financial management
reporting requirements that are presented by the Office of Management and
Budget, The Department of the Treasury, and Individual Departments and
Agencies. Without consistent reporting standards, FFATA accountability
and transparency goals can be turned into a reconciliation nightmare and loss
of confidence by the public.
Irvin E. Faunce, Jr.
President
Financial Management Services, Inc.
15200 Wycliffe Court
Rockville, Maryland 20853
301-929-3002
301-580-6225 (Mobile)
301-929-1158 (Fax)
Email: ifaunce@xxxxxxxx
Internet: http://fmsi.biz - http://fmsi.net
Text Message: http://www.irv.fmsi.net/message.asp
Microsoft Live Messenger Address: ifaunce@xxxxxxxx
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