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OMB Circular A-123, Appendix A Adam Goldberg Office of Federal Financial Management Office of Management and Budget.

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Presentation on theme: "OMB Circular A-123, Appendix A Adam Goldberg Office of Federal Financial Management Office of Management and Budget."— Presentation transcript:

1 OMB Circular A-123, Appendix A Adam Goldberg Office of Federal Financial Management Office of Management and Budget

2 2 Corporation: An ingenious device for obtaining profit without individual responsibility. Ambrose Bierce

3 3 As a small businessperson, you have no greater leverage than the truth. John Greenleaf Whittier

4 4 Legislative History SEC Act 33 / 34, Public Utilities Act Foreign Corrupt Practices Act 1982FMFIA (Circular A-123) 1990CFO Act 2002Sarbanes Oxley 2004Circular A-123, Appendix A

5 5 Circular A-123 A-123 was revised in December 2004 to incorporate Sarbanes-Oxley Section 404 principles into federal financial management. –Revision deals primarily with internal controls over financial reporting. Revised A-123 effective FY2006.

6 6 OMB Circular No. A-123 Revised Guidance Management Assurance Self Assessment Enhanced Documentation Annual Reporting New Appendix A –Testing for Reasonable Assurance –Additional Assurance for Internal Control over Financial Reporting Original Guidance Management Assurance Self Assessment Documentation Annual Reporting

7 7 Management Responsibility A-123, App A Enhanced Financial Disclosures SOX 404 Who Agency ManagementCorporate Management What Estab & Maintain ICOFR Provide Reasonable Assurance Statement of ICOFR Provide Assurance Statement of Managements Responsibility for ICOFR Statement of Effectiveness of IC Structure Auditor Attestation Report on Managements Assessment When Fiscal Year 2006Year-ending on or after Nov. 15, 2004 How Often Annual A-123, Appendix A vs. Sarbanes- Oxley

8 8 Similarities (Sarbanes-Oxley/A-123) Focus is on internal controls Purpose is for reliable financial reporting and effective, efficient operations Responsibility falls primarily on management

9 9 Differences (Sarbanes Oxley/A-123) Criminal penalties Separate audit of internal controls over financial reporting

10 10 Differences in Implementation: Federal vs. Private 1.All transactions in the federal government must have legal authority (prescribed by law). 2.Goals and motivations of federal agencies differ from their private sector counterparts. 3.Federal Agencies already subject to a web of laws to promote prudence and accountability (before Sarbanes-Oxley or A-123 revision)

11 11 Puzzle Pieces of Federal Internal Control Framework FMFIA GPRA CFO Act IG Act FFMIA FISMA IPIASingle Audit Act Clinger-Cohen Act A-123 GAO Green Book


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