Statement
of
The Honorable Linda M. Springer
Controller, Office of Federal Financial Management,
Office of Management and Budget,
Before the
Subcommittee on Government Efficiency and Financial Management
Committee on Government Reform
United States House of Representatives
September 10, 2003
Thank you, Mr. Chairman, for the opportunity to appear
before you today to testify on financial management at the Department
of Homeland Security (DHS). As you know, the enactment of the Homeland
Security Act of 2002 (P.L. 107-296) represents an historic moment of almost
unprecedented action by the Federal Government to fundamentally transform
how the nation will protect itself from terrorism. Rarely in our countrys
past has such a large and complex reorganization of government entities
occurred with such a singular and urgent purpose.
The government is undertaking a unique effort to transform
a distinct group of agencies with multiple missions, values, and cultures
into a strong and effective cabinet department whose mission is to analyze
threats and intelligence, guard U.S. borders and airports, protect the
nations critical infrastructure, and coordinate the countrys
response for future emergencies. This unique opportunity, however, comes
with many challenges, including those related to the new departments
stewardship obligation to use tax dollars appropriately and to ensure
accountability to the President, the Congress, and the American people.
The Homeland Security Departments charge to have
a premier financial management organization is no different than the objective
this Administration and the Congress have set before each of the departments
and agencies in the executive branch. However, the merger of 22 disparate
entities, each with different missions, cultures, programs and operating
systems, greatly complicates the task and places the Department at higher
risk for ineffective and inefficient financial management.
But with great challenge comes great opportunityboth
the opportunity to reengineer and develop seamless systems and processes
that support day-to-day operations and the opportunity to provide analysis
and insight about the financial implications of program decisions that
will ultimately assist this Administration, the Congress, and other decision-makers
in evaluating the value and cost of federal programs.
Overview of DHS Financial Management
Challenges
The creation of the Department of Homeland Security marks
one of the largest and most complex mergers ever undertaken by the Federal
Government. Yet, in the face of the many challenges involved with its
creation, DHS has demonstrated a strong commitment to financial excellence
and should be recognized for its efforts during the past year.
Even before the creation of the Department of Homeland
Security on March 1, 2003, individuals from the affected finance
and budget offices formed an interagency task force, consisting of senior
and mid-level management, which met regularly to identify issues and begin
developing solutions to many of the challenges facing the new Department.
To ensure a smooth transition, this task force worked with OMB and others
to: identify key financial, logistical, and human resources that would
be transferred to the new Department; develop interim management directives
that would provide at least temporary direction to the new Department;
analyze the affects of moving the smaller components into the larger components;
study the capabilities of the financial management systems in place at
its largest components; and identify the audit scope of the new Department
and its legacy agencies.
DHS has worked with the Financial Accounting Standards
Advisory Board (FASAB) to develop guidance on a financial statement presentation
that is consistent with current accounting standards. The Department has
also consulted OMB to ensure that performance reporting for fiscal year
2003 is meaningful to the reader of the performance and accountability
report. Further, OMB has worked with the Department on a myriad of technical
financial issues, such as the appropriate presentation of Customs revenue,
which has been delegated to DHS but whose collection remains a responsibility
of the Department of the Treasury.
DHS has shown commitment to preparing audited financial
statements in its first year of existence to demonstrate accountability
to the Congress and the American people, even though the Accountability
of Tax Dollars Act of 2002 allows the Department to request a waiver from
this requirement. This commitment, coupled with the preparation of quarterly
financial statements, shows the Departments determination to be
fiscally responsible from its inception, accounting for all transferred
assets, liabilities, and operations. DHS goal is to obtain an unqualified
(clean) opinion for fiscal year 2003 and, if events permit, to issue its
performance and accountability report on an accelerated timeframe.
As with any merger, some of the new Departments
efforts must focus on the most immediate challenges. Other efforts, however,
by their nature will take several years to successfully develop and implement.
The startup of DHS, unlike other agencies that carry out programs through
grants or other third parties, is largely a salaries and expense agency
with its own personnel and assets carrying out its vast responsibilities.
Cost control and asset management, coupled with the need to successfully
blend individuals from departments and agencies with different cultures,
values, and missions, are critical to its effectiveness and efficiency.
Although the creation of DHS began just over six months ago, it is off
to a good start with regard to its financial management.
One of the first challenges DHS must overcome is to obtain
a clean audit opinion on its financial statements, which will demonstrate
tangible evidence of its efforts to create a premier financial management
organization. Reaching that goal, however, will require a cooperative
effort among the 22 entities that were transferred to the Department mid-year.
Many issues have been raised regarding the proper accounting
treatment of the new Departments financial activity and its presentation
in the financial statements that must be addressed. OMB has worked, and
continues to work, with DHS to resolve these issues in a timely manner.
Undoubtedly, new issues will surface, but we look forward to working with
DHS to address them together.
DHS must also begin to address the longstanding weaknesses
inherited from its components, such as weak financial accounting and reporting
processes, inadequate information technology (IT) systems functionality
and security controls, ineffective real and personal property processes,
and insufficient internal controls over duties and taxes. The Department
has inventoried these weaknesses and developed corrective action plans,
although these weaknesses are not yet resolved.
DHS has already taken steps to integrate the diverse financial
and performance information systems. It has identified the financial management
systems to which the smaller component agencies may migrate beginning
October 1. However, this step is just the first of many in a long process
to streamline the Departments systems. The Chief Financial Officer
(CFO) must also identify the Departments IT assets and then, in
conjunction with each program, determine what IT assets are needed to
meet mission requirements. The CFO must work with the Chief Information
Officer (CIO) to identify a financial management system or systems to
meet user needs, whether it be commercial-off-the-shelf, internally developed,
or a hybrid of the two.
Establishing Sound Financial Management
and Business Processes
The push to create a citizen-centered, results-oriented
government has been exacerbated by the demands on available resources.
It is necessary for financial managers to provide its management, this
Administration, the Congress and other decision-makers with quality, timely
information and analysis that better informs about the financial implications
of program decisions and the impact of those decisions on agency performance
goals and objectives. To this end, we believe that DHS must focus its
attention on four critical areas:
-
Ensuring top leadership drives the transformation to a single agency,
single vision/goal
-
Creating the financial organization that adds value and supports the
Departments mission
- Establishing
seamless financial systems and businesses processes
-
Providing meaningful information to decision-makers by routinely generating
reliable cost and performance information analysis
Ensuring Top Leadership. Leadership
is critical to establishing sound financial management within the Department.
The merger of 22 disparate entities into a single financial organization
must begin with a clear vision of performance and expectations that is
communicated throughout the organization at all levels. To be successful,
DHS top leadership must make attaining that vision a priority,
and the message must be reinforced in both words and actions.
A vision of fundamentally improved financial management
and the uncompromising organization-wide pursuit of that vision are critical
within the culture of DHS. A foundation of control and accountability
that supports external reporting and performance management, as well as
using training to change the organizational culture and engage program
managers, serves to provide necessary clear and strong executive leadership.
Additionally, it is also important to have a financial management team,
with the right mix of skills and competencies that is dedicated to the
transformation process to ensure changes are thoroughly implemented and
sustained over time.
Creating the Financial Organization.
A premier financial organization must recognize that it exists to provide
quality, timely and relevant information about the financial implications
of program decisions and the impact of those decisions on agency performance
goals and objectives. To accomplish this purpose, leading financial organizations
must serve their customers both internally and externally, aligning their
mission and organizational structure to better support the entitys
mission and objectives. DHS should take all necessary steps toward creating
a financial team that supports the overall missions, goals, and objectives
of the Department.
Seamless Financial Systems and Business Processes.
Building a premier financial organization will also require DHS to establish
seamless financial systems and business processes to enable it to successfully
fulfill its mission and achieve its goals and objectives. At the earliest
opportunity, DHS must determine the essential system and process infrastructure
that it requires throughout the organization. This infrastructure must
also be flexible enough to support information needs at the detailed program
level.
To this end, it is crucial that DHS give careful thought
to its IT modernization efforts. OMBs experience with federal agencies
has shown that attempts to modernize IT environments require specific
blueprints, models that simplify the complexities of how agencies operate
today, how they want to operate in the future, and how they will get there.
In the absence of such blueprints, there is often unconstrained investment
and systems that are duplicative and ineffective. Certain enterprise architectures
offer such blueprints. If managed properly, architectures can clarify
and help optimize the interdependencies and interrelationships among enterprise
operations and the underlying IT infrastructure and applications that
support them. The development, implementation, and maintenance of such
an architecture, inclusive of robust financial functionality, are recognized
hallmarks of successful public and private organizations.
Providing Meaningful Information.
In seeking to create a premier financial organization, DHS must also pursue
means that will permit it to routinely generate reliable cost and performance
information analysis. Such analytics combined with other value-added activities
will support the agencys mission and goals. This capability is
a requirement for getting to green on the Improved Financial
Performance initiative of the Presidents Management Agenda,
and it gets to the heart of first-class financial management.
The creation of DHS provides an opportunity to reengineer
much of the management reporting formats produced by its components to
meet the needs of its users. As DHS looks to develop a new strategic plan
that will outline its goals and objectives, its financial organization
should design reporting formats that are aligned to measure performance
in executing its strategy.
H.R. 2886, Department of
Homeland Security Financial
Accountability Act
Similar to the Committee, OMB has high expectations of
solid financial management practices for this new Department, especially
in light of its unique role and function within the Federal Government.
To that end, we appreciate your efforts in introducing H.R. 2886, the
Department of Homeland Security Financial Accountability Act,
and we look forward to discussing several issues of this legislation with
you.
Fiscal Year 2003 Financial Reporting and Audit.
Preparation of audited financial statements is a crucial step in DHSs
path to financial management excellence. The Department of Homeland Security
Financial Accountability Act (H.R. 2886), however, contains a provision
that would lift the requirement of DHS to prepare and submit audited financial
statements for any fiscal year before fiscal year 2004. It is our understanding
that this provision is intended to provide DHS with adequate time to meet
this requirement. (A similar provision is not included in the Senate companion
bill, S. 1567.)
Much work has already been done toward the completion
of the fiscal year 2003 financial statement process at DHS. As the Departments
acting Inspector General recently communicated to the Committee on Government
Reform, the fiscal year 2003 audit is very much in progress. This effort
has not only involved the Department and its auditors but also the 22
legacy agencies, the Financial Accounting Standards Advisory Board, and
others. It is our understanding from discussions with the Office of the
Chief Financial Officer that DHS intends to see this process to its conclusion.
OMB commends DHS for its recognition of the value that
is provided in this initial year by preparing and undergoing an audit
of financial statements, and it is the position of OMB that this process
be completed to gain full benefit. We would ask the Committee to allow
the Department to continue the fiscal year 2003 financial reporting and
audit process.
Internal Control Audit Opinion.
H.R. 2886 also contains a requirement for DHS to include in each
performance and accountability report an audit opinion of the Department's
internal controls over its financial reporting. It is our understanding
that this requirement is intended to hold Federal agencies to the same
standards for financial accountability as the private sector. At the present
time, however, no other sectors are required to obtain an audit opinion
on internal control.
While SEC registrants will be subjected in the future
to such a requirement under Section 404 of the Sarbanes-Oxley Act (enacted
July 2002), the effective date has been delayed as a result of public
comments. The provision was originally planned for fiscal years ending
on or after September 15, 2003, but was deferred to fiscal years ending
on or after June 15, 2004, for large US companies, and April 15, 2005,
for smaller US companies and foreign companies. This deferral recognized
the following concerns (as outlined in a May 29, 2003, speech by SEC Deputy
Chief Accountant Scott A. Taub):
-
cost and time needed to properly implement the rules;
-
uncertainty and disagreements about the level of work required to comply
with the internal control requirement;
-
whether sufficient time was permitted to resolve uncertainties adequately;
and
-
whether the professional auditing standards needed revision.
These same concerns would also apply to federal agencies.
The Administration acknowledges that obtaining an audit
opinion on internal control is a potentially useful, yet very significant,
undertaking. While we agree that an opinion level internal control audit
could have merit, a review of this magnitude will require the allocation
of additional resources and sufficient time to coordinate among agency
Chief Financial Officers, Inspectors General, and independent public auditors.
Three agencies (General Services Administration, Nuclear
Regulatory Commission, and Social Security Administration) have voluntarily
elected to obtain audit opinions on internal control; however, cabinet
departments and other agencies covered by the Chief Financial Officers
Act (CFO Act) are not currently required to obtain such an opinion. This
provision, if enacted, would impose a more stringent requirement on DHS
than other Federal departments and agencies. OMB recommends that a cost-benefit
study of the internal control audit provision be performed jointly by
the CFO Council and the Presidents Council on Integrity and Efficiency
to provide the necessary insight as to the cost and proper timing of such
a requirement.
Applying the CFO Act to DHS.
It is OMBs position that the substantive provisions of the CFO
Act should apply to the new Department of Homeland Security as they do
every other major Department and agency of the Federal Government. However,
the CFO Act specifies an organizational structure direct reporting
of the CFO to the agency head that is inconsistent with the structure
Congress endorsed when it passed the Homeland Security Act of 2002. The
Homeland Security Act enacted the Presidents proposal to consolidate
management responsibilities at the new Department under the Under Secretary
for Management. The Administration believes that with a strong and competent
leader in the position of Under Secretary for Management, sound management
policies and practices receive maximum standing within the agency. Requiring
the CFO at the Department of Homeland Security to report directly to the
Secretary of Homeland Security would dilute this principle.
The Administration is also working with Congress to reduce
the number of officials subject to confirmation by the Senate, and therefore
opposes making the CFO subject to confirmation by the Senate. In this
vein, Congress agreed last fall that through passage of the Homeland Security
Act, the Department of Homeland Security CFO would not be subject to Senate
confirmation. This action does not compromise the applicability of the
qualification requirement for CFOs as articulated by the Act.
I hope we can work together to apply the substantive provisions
of the CFO Act to the new Department of Homeland Security, while remaining
faithful to the Presidents original proposal to create the new
Department, as well as the Homeland Security Act of 2002.
Conclusion
Establishing sound financial management and business processes
within the Department of Homeland Security will not occur overnight. Rather,
such a transformation will take several years to achieve. OMB believes
that DHS has demonstrated a commitment to sound financial management,
and its focus on implementing the most effective and efficient systems
and processes is the beginning to achieve this outcome.
Thank you, Mr. Chairman. I look forward to answering your
questions.
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