This is the accessible text file for GAO report number GAO-03-275 
entitled 'Defense Budget: Improved Reviews Needed to Ensure Better 
Management of Obligated Funds' which was released on January 30, 2003.



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Report to the Secretary of Defense:



United States General Accounting Office:



GAO:



January 2003:



DEFENSE BUDGET:



Improved Reviews Needed to Ensure Better Management of Obligated Funds:



Defense Budget:



GAO-03-275:



GAO Highlights:



Highlights of GAO-03-275, a report to the

Secretary of Defense.



DEFENSE BUDGET

Improved Reviews Needed to Ensure

Better Management of Obligated Funds.



Why GAO Did This Study:



As of September 30, 2001, the Navy’s operating appropriations

had $2.1 billion in unliquidated—or unpaid—funds that were obligated

during fiscal years 1997-99. Unliquidated obligations that are

no longer needed to pay for goods and services tie up funds that could

be used for other permissible purposes. In addition, inaccurate

obligation data result in misstatement of budgetary

information. Because of the large dollar value,

we examined the Navy’s management of unliquidated obligations. 

Specifically, we reviewed a statistically representative sample of the 

Navy’s $1.4 billion in unliquidated operating obligations valued at

$50,000 or more for fiscal years 1997-99 to determine whether these

obligations were (1) properly accounted for and (2) reviewed in

accordance with DOD regulations.



What GAO Found:



We estimated that $929 million of the $1.4 billion in unliquidated 

operating obligations valued at $50,000 or more for fiscal years 1997-
99 

was not properly accounted for (see table). Specifically, the Navy 

failed to deobligate $452 million of unliquidated operating obligations 

that was no longer needed and potentially available for other 
permissible 

purposes, such as contract modifications. In addition, $147 million of 

unliquidated operating obligations was inaccurately recorded because of 

problem disbursements—payments not properly matched to the correct 

obligation. A further $330 million was inaccurately recorded due to 

unresolved errors, such as bills that were not processed properly. The 

remaining $489 million in unliquidated operating obligations was 

properly accounted for and still needed for the original purpose.

An estimated two-thirds of the unliquidated operating obligations over

$50,000 were not properly accounted for as a result of the Navy’s 

failure to

review such obligations three times each year as required by DOD

regulations. In addition, the Navy did not fully adhere to the 

regulation 

that unliquidated operating obligations of any value be reviewed at 

least once each year. Consequently, the Navy did not know how much 

money 

was tied up in unliquidated operating obligations that could 

potentially 

be used for other appropriate needs, and its budgetary reports to 

Congress and financial statements were inaccurate. Navy fund managers 

chose to selectively review their operating obligations, citing 

obstacles 

such as difficulties in obtaining accurate payment and billing data 

and 

the extensive length of time needed to review large numbers of 

obligations. 

Further, the Navy did not apply existing internal control activities to 

ensure that fund managers performed obligation reviews in accordance 

with DOD 

regulations, nor did it hold fund managers accountable for the accuracy 

and completeness of the reviews.



Estimate of Navy’s Unliquidated Operating Obligations Valued at $50,000

or More for Fiscal Year 1997-99, as of September 30, 2001.



[See PDF for Image]

[End of Figure]



What GAO Recommends:



We are recommending that the Navy adhere to obligation review

regulations and better apply existing internal controls to ensure

fund managers adhere to these regulations and are accountable for

accuracy and completeness. The Navy partially concurred, but

stated that it prioritizes obligation reviews to enable it to also 

pursue other efforts to improve financial reporting. We note that DOD

regulations require review of all unliquidated obligations and do not

allow for prioritization.



To view the full report, including the scope

and methodology, click on the link above.

For more information, contact Sharon Pickup

at (202) 512-9619 or pickups@gao.gov



Contents:



Letter:



Results in Brief:



Background:



Navy Did Not Properly Account for Large Portion of Unliquidated 

Operating Obligations:



Navy Did Not Fully Adhere to DOD Review Regulations:



Conclusions:



Recommendations for Executive Action:



Agency Comments and Our Evaluation:



Appendix I: Scope and Methodology:



Appendix II: Agency Comments:



Appendix III: GAO Contacts and Staff Acknowledgments:



Tables:



Table 1: Estimate of Navy’s Unliquidated Operating Obligations for 

Fiscal Years 1997-99, as of September 30, 2001:



Table 2: Dollar Value Distribution of Fiscal Year 1997-99 Obligations 

Reviewed in the GAO Sample, as of 

September 30, 2001:



Abbreviations:



DODDepartment of Defense:



FMRFinancial Management Regulations:



United States General Accounting Office:



Washington, DC 20548:



January 30, 2003:



The Honorable Donald H. Rumsfeld

Secretary of Defense:



Dear Mr. Secretary:



The Department of Defense (DOD) confronts pervasive and complex 

financial management problems that can seriously diminish the 

efficiency of the military services’ support operations. Recent audits 

of DOD’s financial statements highlight ongoing financial management 

challenges that affect the development of accurate and complete 

financial information. Among the challenges facing DOD is the lack of 

accurate obligation data needed for effective budget management and 

reliable financial reporting.



To ensure accuracy, it is important for the services to liquidate 

obligations if funds are no longer needed as originally planned and 

adjust their financial records accordingly. Unliquidated obligations 

are those that have not yet been paid. The unliquidated obligations 

that are no longer needed to pay for goods and services tie up funds 

that could be used for other permissible purposes. Inaccurate 

obligation data result in misstatement of budgetary information on 

federal financial statements and in the President’s budget and 

contribute to the failure to provide basic financial 

accountability.[Footnote 1]



DOD has recognized the need for the services to identify and reduce the 

number and amount of unliquidated obligations by requiring that fund 

managers review these obligations. In 1996, the DOD Office of the Under 

Secretary of Defense (Comptroller) issued a memorandum directing DOD 

components to review three times each year the accuracy of unliquidated 

operating obligations valued at $50,000 or more. DOD also directed 

agencies to review all other unliquidated operating obligations at 

least once a year. In reviewing service obligation data, we noted that 

the Navy has significantly large amounts of unliquidated obligations. 

As of September 30, 2001, the Navy’s operating appropriations[Footnote 

2] had $2.1 billion in unliquidated funds that were obligated during 

fiscal years 1997-99, of which $1.4 billion (67 percent) represented 

unliquidated operating obligations of $50,000 or more.[Footnote 3] 

Also, in 1999 and 2000, Navy auditors reported inaccuracies in the 

Navy’s obligation data and found that fund managers were not fully 

complying with DOD review regulations.



Because of the large dollar value of unliquidated obligations and Navy 

audit findings, we reviewed the Navy’s management of its unliquidated 

operating obligations. More specifically, we determined whether these 

unliquidated operating obligations were (1) properly accounted for and 

(2) periodically reviewed in accordance with DOD regulations. We 

reviewed a statistically representative sample of the Navy’s 

unliquidated operating obligations of $50,000 or more for fiscal years 

1997-99. We also analyzed documentation related to DOD’s obligation 

review regulations and the Navy’s guidance to adhere to the 

regulations, and interviewed Navy officials. A more detailed 

description of our scope and methodology is included in appendix I.



Results in Brief:



On the basis of our sample, we estimated that $929 million of the 

$1.4 billion in unliquidated operating obligations valued at $50,000 or 

more for fiscal years 1997-99 was not properly accounted for. 

Specifically, the Navy failed to deobligate $452 million of 

unliquidated operating obligations that was no longer needed and 

potentially available for other permissible purposes, such as contract 

cost overruns or contract modifications. In addition, $477 million of 

unliquidated operating obligations was not properly accounted for due 

to billing and recording errors. For example, payments were made and 

recorded on behalf of the wrong obligation, or payments were not made 

because bills were not processed properly. In addition to tying up 

funds unnecessarily, these obligation errors resulted in inaccurate 

reporting in the Navy’s budgetary reports and in its financial 

statements. The remaining $489 million in unliquidated operating 

obligations was properly accounted for and still needed for the 

original purpose.



An estimated two-thirds of the unliquidated operating obligations over 

$50,000 were not properly accounted for as a result of the Navy’s 

failure to review such obligations three times each year as required by 

DOD regulations. In addition, the Navy did not fully adhere to the 

regulation that unliquidated operating obligations of any value be 

reviewed at least once each year. Consequently, the Navy did not know 

how much money was tied up in unliquidated operating obligations that 

could potentially be used for other permissible needs, and its 

budgetary reports to Congress and financial statements were inaccurate. 

Navy fund managers chose to selectively review their operating 

obligations, citing obstacles such as difficulties in obtaining 

accurate payment and billing data and the extensive length of time 

needed to review large numbers of obligations. Further, the Navy did 

not apply existing internal control activities to ensure that fund 

managers performed obligation reviews in accordance with DOD 

regulations, nor did it hold fund managers accountable for the accuracy 

and completeness of the reviews.



Accordingly, we are recommending that the Navy adhere to its obligation 

review regulations and apply existing internal controls to ensure fund 

manager adherence to these regulations. The Navy partially concurred 

with our recommendations, acknowledging that more thorough efforts 

dedicated to the review of obligations would increase the accuracy and 

reliability of financial reports. The Navy, however, noted that because 

numerous factors contribute to problems in financial reports, it has to 

prioritize its remedial efforts and therefore focus on reviewing 

unliquidated obligations in available appropriations, correcting 

systemic problems, and pursuing broad improvements in financial 

management. When appropriate requirements have arisen, the Navy 

commented that encumbrances for unliquidated obligations have not been 

an impediment to obtaining necessary funds. While we agree focusing on 

systemic issues offers opportunities to improve the Navy’s financial 

information, we note DOD’s obligation review regulations are in fact 

designed to minimize systemic problems and do not allow for 

prioritization. Furthermore, the ability of the Navy to gain access to 

funds when needs arise does not relieve it of the responsibility to 

adhere to existing laws and regulations governing sound financial 

management. We therefore are making no changes to the recommendations 

in our report.



Background:



Obligations are recorded when an authorized agent of the federal 

government enters into a legally binding agreement to purchase specific 

goods or services.[Footnote 4] As bills are received and payments are 

made, the recorded obligation is reduced by the amount of the payments 

made. When all services or goods have been received and paid for, the 

obligation is considered “liquidated,” and any remaining amount of the 

unliquidated (unpaid) obligation should be deobligated and reduced to 

zero.[Footnote 5] Operating funds must be obligated in the fiscal year 

for which they are appropriated. However, obligated funds may be spent 

over a period of 5 additional years, as bills for goods and services 

are received and paid.[Footnote 6] If the goods and services are 

received and paid for in the first year of the obligation, the 

remaining unliquidated obligation can be reused for other needs 

consistent with the source appropriation. If the goods and services are 

received and paid for in the subsequent 5 years, the remaining 

unliquidated obligation can still be used, if permissible, to modify 

contracts or to increase existing obligations that might need more 

funds.



Accurate obligation information is essential for reliable budgeting 

reports to Congress, agency financial statements, performance 

measurements, and funds control. Inaccurate obligation data misstates 

the amount of funds available from the appropriation, contributes to 

inaccuracies in the Navy’s budget and financial reports, and 

subsequently leads to inaccuracies in federal financial statements. For 

example, the Navy’s unliquidated obligations are reported in the Navy 

Statement of Budgetary Resources, which are in turn incorporated in 

other DOD and federal budget reports and financial statements.



We have documented weaknesses in DOD’s accounting practices and Navy 

auditors have documented inaccuracies in the Navy’s obligations data. 

In our 2001 Performance and Accountability Series report, we stated 

that because of weaknesses in DOD’s budget execution accounting, the 

department does not know with certainty the amount of funding it has 

available.[Footnote 7] Naval Audit Service reports published in 

February 1999[Footnote 8] and January 2000[Footnote 9] reported that 

Navy fund managers were not complying with obligation review 

regulations and documented inaccuracies in the Navy’s obligation data. 

In July 2000 we reported that such inaccuracies in obligation data not 

only hamper DOD’s ability to produce timely and accurate financial 

information, but also significantly impair efforts to improve the 

economy and efficiency of its operations.[Footnote 10]



To ensure that obligation data are tracked and accurately reported, the 

DOD Financial Management Regulations (FMR) require that the services, 

including the Navy, review their unliquidated operating obligations 

valued $50,000 or more three times a year to ensure that they are 

accurate and that the funds are still needed.[Footnote 11] All 

unliquidated operating obligations, regardless of dollar value, must be 

reviewed at least once a year.[Footnote 12] Also, Congress specifically 

established in chapter 15 of title 31, United States Code, a framework 

for reviewing, adjusting, certifying to, and reporting on, among other 

items, the status and amounts of unliquidated obligations.[Footnote 13] 

In addition, for many interagency obligations entered under specific 

statutory authority, such as the Economy Act,[Footnote 14] the 

authorizing statute may mandate the deobligation of appropriations at 

specific times or when certain conditions arise.[Footnote 15]



The DOD regulation also directs the services to implement effective 

internal controls to ensure that the required reviews are completed and 

that identified corrective actions are completed in a timely 

manner.[Footnote 16] Further, the Federal Managers’ Financial Integrity 

Act of 1982[Footnote 17] requires that agencies’ controls reasonably 

ensure that (1) obligations and costs comply with applicable law and 

(2) revenues and expenditures applicable to agency operations are 

properly recorded and accounted for so that agency accounts and 

reliable financial and statistical reports may be prepared and the 

accountability of assets may be maintained.[Footnote 18]



Navy Did Not Properly Account for Large Portion of Unliquidated 

Operating Obligations:



An estimated two-thirds of the Navy’s unliquidated operating 

obligations valued at $50,000 or more from the fiscal years 1997-99 

operating appropriations was not properly accounted for. Specifically, 

we estimated that $929 million of the $1.4 billion in unliquidated 

operating obligations was not properly accounted for. As shown in table 

1, $452 million of the unliquidated operating obligations was no longer 

needed for its original purpose. These funds could have been used for 

other permissible purposes of the same appropriation and fiscal year, 

such as contract modifications. In addition, $477 million was not 

properly accounted for due to billing and recording errors, including 

$147 million in problem disbursements and $330 million in unresolved 

accounting and recording errors. Finally, 

$489 million in unliquidated operating obligations was properly 

accounted for and still needed for the original purpose.



Table 1: Estimate of Navy’s Unliquidated Operating Obligations for 

Fiscal Years 1997-99, as of September 30, 2001:



Dollars in millions: Category: Still needed for original purpose; 

Estimated total: $489; Percentage of total: 35.



Dollars in millions: Category: Not properly accounted for:; Estimated 

total: [Empty]; Percentage of total:  .



Dollars in millions: Category: No longer needed for original purpose; 

Estimated total: 452; Percentage of total: 32.



Dollars in millions: Category: Problem disbursements; Estimated total: 

147; Percentage of total: 10.



Dollars in millions: Category: Unresolved errors; Estimated total: 330; 

Percentage of total: 23.



Dollars in millions: Category: Subtotal not properly accounted for:; 

Estimated total: 929; Percentage of total: 65.



Dollars in millions: Category: Total; Estimated total: $1,419[A]; 

Percentage of total: 100.



[End of table]



Source: DOD.

Note: GAO analysis of DOD data.



[A] Amounts do not add to total due to rounding.



The Navy failed to deobligate an estimated $452 million that was no 

longer needed for the original obligated purpose. According to DOD 

regulations, these unliquidated funds should have been deobligated once 

services had been performed, final payment issued, and the funds made 

available for other purposes consistent with the appropriation. In many 

of our sample cases, the entire amount of an obligation was not 

required to meet billing needs and resulted in funds remaining over. 

For example, in one of the cases we reviewed, $4.7 million had been 

disbursed from a 1997 obligation, valued at $6 million, to support the 

San Diego Harbor Tug Charter; however, the last disbursement was made 

in October 1999. We discovered that the remaining unliquidated funds 

were no longer needed and the Navy subsequently deobligated the 

unliquidated $1.3 million. Similarly, we reviewed a 1996 (fiscal year 

1997) obligation to fund systems development at the Bureau of Naval 

Personnel. When the responsible Navy fund manager reviewed the 

unliquidated obligation at our request, he determined that the 

outstanding balance of $1.4 million attached to this obligation was no 

longer required and deobligated it. In both of these cases, if Navy 

personnel had reviewed these obligations in accordance with DOD 

regulations, they would have detected the error and deobligated the 

funds years ago, thereby possibly allowing Navy to use the funds for 

other permissible purposes, including contract modifications, or other 

obligation needs of the same appropriation and fiscal year.



The Navy had also not properly accounted for an estimated $147 million 

in unliquidated operating obligations due to expenditures that were not 

properly matched to a specific obligation recorded in the Navyís 

recordsóproblem disbursementsWe previously reported that the Navy’s 

financial control policy and procedures do not ensure that the Navy can 

match payments to corresponding obligations before or at the time a 

payment is made. [Footnote 19]Consequently, if the Navy cannot resolve 

these problem disbursements by matching the disbursement to the 

original obligation, it must record a new obligation to cover the 

disbursement after a payment is made. For example, one of our sample 

items had an unliquidated obligation balance of $1,362,790 on September 

30, 2001. The fund manager of this 1998 obligation stated that all of 

the funds had been disbursed; however, the Navy’s Standard Accounting 

and Reporting System indicated that no disbursements had been made. We 

discovered that in fact all of the funds had been disbursed for this 

obligation, but the disbursements had been posted to the wrong 

obligation in the accounting system. Funds that remain unliquidated due 

to a problem disbursement may not be deobligated and used for other 

purposes because the funds are still needed to reimburse the obligation 

that was erroneously charged for the disbursement..



The Navy had not properly accounted for an estimated $330 million due 

to unresolved accounting and recording errors. These obligations 

remained unliquidated for several reasons. Most unresolved errors in 

our sample occurred because fund managers were unable to identify 

whether the providers of goods or services had been paid in full for 

services rendered. The fund managers claimed that providers were often 

slow to bill or had not sent a final bill. For example, we reviewed a 

1997 obligation for aircraft maintenance that had an unliquidated 

balance of $14.4 million. The fund managers said that they had not 

received a bill from the Air Force, which provided the maintenance 

service. In this case, the $14.4 million remained on the books as 

unresolved, because the fund managers still expected to receive a bill 

for the services. An example of a recording error is illustrated in a 

$12 million obligation to support alterations on the USS LaSalle. A 

disbursement was input twice and then reversed twice instead of once. 

The second reversal of the disbursement left an unliquidated balance on 

the obligation that should have been disbursed. Funds that remain 

unliquidated due to unresolved accounting and recording errors cannot 

be deobligated and used for other purposes, because the Navy needs to 

have funds available to pay providers after the errors have been 

resolved.



Navy Did Not Fully Adhere to DOD Review Regulations:



The Navy did not fully adhere to DOD regulations to review all 

unliquidated operating obligations, including those obligations valued 

at $50,000 or more three times per year and those obligations valued at 

less than $50,000 once every year. Furthermore, the Navy did not 

utilize internal controls to determine the accuracy of the review 

process or the outcomes of the reviews. As a result, the Navy did not 

know how much money was tied up in unliquidated operating obligations 

that could potentially be used for other permissible needs.



According to DOD regulations, obligation reviews are to be conducted by 

fund managers within 14 days following the end of January, May, and 

September. DOD regulations also require the services to implement 

effective internal controls to ensure that the reviews are completed 

and corrective actions are implemented in a timely manner. The purpose 

of these reviews is to ensure that the unliquidated balances are 

accurate and still needed. The Navy issued implementing guidance that 

(1) restates the three deadlines provided in the DOD regulations, (2) 

requires that internal controls be implemented by each entity as 

described in DOD regulations, and (3) requires each fund manager to 

complete a checklist of the review steps performed. For example, one 

required step is to follow up and ensure the obligation is still 

needed. The guidance also requires the comptroller of each major 

command to consolidate the review results from the fund managers and 

include a list of all fund managers who did not fully adhere to DOD 

regulations and the reason why. The major command confirmation 

statement is to be forwarded to the Assistant Secretary of the Navy 

(Financial Management and Comptroller), Office of Budget.



Although DOD regulations require Navy fund managers to review all 

operating obligations once annually and those $50,000 and above three 

times each year, fund managers have not fully adhered. Fund managers 

stated that they selectively reviewed some unliquidated operating 

obligations, but were unable to make all the required reviews or 

complete all the steps on some of the cases they reviewed. For example, 

fund managers first prioritize for review the high-value unliquidated 

operating obligations in the current fiscal year to accommodate 

immediate funding requirements. That frees the funds for reobligation 

during the same fiscal year. Unliquidated operating obligations that 

are approximately 5 years old and, based on appropriations that will 

cancel at the end of the fiscal year, are also a high priority for 

review in order to pay outstanding bills while funds are available. As 

a result of prioritized and selective obligations review, some 

operating obligations are not reviewed three times a year as required 

by DOD regulations and some are not reviewed at all.



Navy fund managers provided several reasons why they selectively 

reviewed obligations and did not review all of them. They stated that 

the process of reviewing an obligation can be time-consuming due to a 

lack of automated tools and, often, a lack of accurate billing 

information needed to assess the validity of an obligation, especially 

for older obligations. Officials acknowledged that the Navy’s Standard 

Accounting and Reporting System provides users with the capability to 

conduct ad hoc queries of the obligation database, but they claim these 

tools are not user-friendly because users must be familiar with the 

system’s database-programming code to take full advantage of its 

capabilities. Few of the staff assigned to perform obligation reviews 

had the required computer training or knowledge to write queries. Some 

of the fund managers also told us that they were reluctant to review 

the large volume of low dollar unliquidated operating obligations 

because they felt the expected rate of return was not cost beneficial 

given the magnitude of resources required to conduct the review. To 

illustrate the large volume, Atlantic Fleet officials reported that 

they had 579,904 unliquidated operating obligations valued $50,000 or 

less,[Footnote 20] and officials at the Pacific Fleet reported 724,266 

such unliquidated operating obligations.[Footnote 21] Further, some 

fund managers stated that it was impossible for them to comply with the 

requirement to review all such unliquidated operating obligations even 

once a year, because they did not have enough staff to review the large 

number of such obligations.



Officials in the Navy Comptroller Office acknowledged that fund 

managers have reported difficulties performing obligation reviews. Navy 

officials also acknowledged that inaccurate obligation data compromises 

the reliability of their financial statements, and therefore it is 

reasonable that they review their obligations according to the 

regulations. Consequently, the Navy has not sought relief from DOD 

obligation review regulations.



The Navy did not utilize internal control activities necessary to 

ensure that fund managers performed thorough obligation reviews in 

accordance with DOD regulations. Although some major commands had 

developed written standard operating procedures or checklists to track 

whether fund managers had reviewed their unliquidated operating 

obligations, they did not hold managers accountable for the accuracy 

and completeness of the reviews. Fund managers submitted obligation-

review confirmation statements to their major commands, but often the 

commands could not determine specific details about the obligations, 

including the number of unliquidated operating obligations reviewed, 

the amount of the obligations reviewed, and the resolution of any 

problems identified during the review. For example, one major command 

has a process to review whether fund managers submit the required 

obligation review paperwork. However, the command does not spot-check 

obligations to determine if they are valid as claimed by the fund 

managers and accepts the fund managers obligations review paperwork as 

is.



Officials in the Navy Comptroller Office stated that fund managers 

should place more emphasis on reviewing obligations in accordance with 

DOD regulations. However, they did not think it would be productive to 

discipline fund managers for failure to adhere to the regulations. 

Rather, they believe that the Navy should rely on financial system 

upgrades to improve the accuracy of obligation data.



Conclusions:



As highlighted in our 2001 Performance and Accountability Series 

reports, financial management is one of the major management challenges 

facing DOD.[Footnote 22] The large dollar value of unliquidated Navy 

obligations that were not properly accounted for contributes to 

inaccuracies in the Navy’s budget and financial reports, and 

subsequently leads to inaccuracies in federal financial statements and 

the President’s budget. Moreover, the Navy will not be able to pass the 

test of an independent financial audit until it corrects inaccurate 

obligation data.



DOD regulations and Navy guidance provide for unliquidated obligations 

to be reviewed by fund managers on a regular basis. The fund managers’ 

ability to deobligate or resolve the errors on many of our sample items 

demonstrates that the review process could be effective. But the fund 

managers have chosen to only selectively follow the requirements for 

review because they said they were constrained by too little time to 

review the large number of transactions, inaccurate billing 

information, and the lack of automated tools. Although the Navy 

recognized the potential benefits of timely identification of funds 

that are no longer needed or in error, its internal controls have not 

ensured that required reviews were made and corrective action taken. We 

note that fund managers were able to successfully resolve nearly all of 

the unliquidated operating obligations in our sample even though the 

resolution of some of the obligations required an extensive amount of 

time and effort. Therefore, it is likely that many of the unliquidated 

obligations in our sample that were not properly accounted for could 

have been identified and accounting errors could have been corrected 

prior to our review had fund managers performed obligation reviews in 

accordance with the DOD regulations.



Recommendations for Executive Action:



We recommend that the Secretary of Defense direct the Secretary of Navy 

to:



* adhere to DOD unliquidated operating obligation review regulations; 

and:



* better apply existing internal control activities to ensure adherence 

to these regulations, and to hold fund managers accountable for the 

accuracy and completeness of their reviews.



As you know, 31 U.S.C. requires the head of a federal agency to submit 

a written statement of the actions taken on our recommendations to the 

Senate Committee on Government Affairs and the House Committee on 

Government Reform not later than 60 days after the dare of this report. 

A written statement must also be sent to the House and Senate 

Committees on Appropriations with the agency’s first request for 

appropriations made more than 60 days after the date of this report.



Agency Comments and Our Evaluation:



The Director, Office of the Budget, Department of the Navy provided 

DOD’s written comments on a draft of this report, which are provided in 

their entirety in appendix II. The Navy partially concurred with our 

recommendations and noted that more thorough efforts dedicated to the 

review of obligations would increase the accuracy and reliability of 

financial reports. It also plans to make the review process a part of 

its management structure and stress the importance of accurate 

financial statements. The Navy, however, commented that because 

numerous factors contribute to problems in financial reports, it has to 

prioritize its remedial efforts. Specifically, the Navy places a 

premium on reviewing unliquidated obligations in available 

appropriations, correcting systemic problems, and pursuing broad 

improvements in financial management. For example, the Navy stated it 

made significant improvements in correcting systemic issues--such as 

problem disbursements--and is working to provide automated tools and 

correct systemic issues that would positively impact the fund managers’ 

ability to conduct obligation reviews. While it noted validating 

unliquidated obligations is desirable and important, the Navy 

emphasized that systemic improvement of its financial information 

offers the better opportunity for success.



The Navy did not agree that the difficulty the fund managers have had 

in reviewing unliquidated obligations precluded the use of funds for 

other appropriate needs. It noted that Congress has intentionally and 

progressively limited the availability of funds from prior year 

appropriations, clearly establishing that the appropriateness of use 

outweighs the efficiency of use. When appropriate requirements for the 

application of available funds from prior year appropriations have 

arisen, the Navy commented that encumbrances for unliquidated 

obligations have not been an impediment to obtaining necessary funds.



While we understand numerous factors, including systemic issues, affect 

the accuracy of Navy financial reports, DOD regulations require that 

fund managers annually review all unliquidated obligations and, as 

currently written, do not provide for prioritization of such reviews. 

We recognize the Navy has taken steps to significantly reduce the 

amount of outstanding problem disbursements; however, as our report 

points out, problem disbursements are only part of the reason for the 

significant amount of unliquidated obligations. For example, about $782 

million of the $929 million in unliquidated obligations in our sample 

were improperly accounted for due to reasons unrelated to problem 

disbursements. Specifically, the aggregate of these transactions 

involved funds that were no longer needed for their original purpose or 

involved unresolved accounting and recording errors. While we agree 

that focusing on systemic issues offers opportunities to improve the 

Navy’s financial information, we also note that the internal control 

procedures reflected in DOD’s obligation review regulations are in fact 

designed to minimize systemic problems such as problem disbursements. 

To the extent that the Navy’s efforts to make systemic improvements 

include automated tools designed to assist the fund managers in 

complying with obligation review requirements, we believe these efforts 

represent a positive step.



We disagree with the Navy’s views regarding the impact of failing to 

review all unliquidated obligations as required under current DOD 

regulations. Regardless of whether the Navy is able to gain the funds 

necessary from unliquidated obligations to satisfy appropriate 

requirements as they arise, inaccurate obligation data in the Navy’s 

financial system has broader implications, such as inaccurate financial 

reports and misstatements of budgetary information on federal financial 

statements and in the President’s budget. While we agree Congress has 

placed statutory limitations on the availability of appropriated funds, 

DOD, like all agencies, is responsible for effectively and efficiently 

implementing its activities within the limitations applicable to the 

appropriations it receives. Indeed, Congress specifically established 

in chapter 15 of title 31, United States Code, a framework for 

reviewing, adjusting, certifying to, and reporting on, among other 

items, the status and amounts of unliquidated obligations.[Footnote 23] 

In addition, the Federal Managers’ Financial Integrity Act of 

1982[Footnote 24] requires that agencies have controls to reasonably 

ensure that revenues and expenditures applicable to agency operations 

are recorded and accounted for properly so that accounts and reliable 

financial and statistical reports may be prepared and accountability of 

assets may be maintained.[Footnote 25] Finally, for many interagency 

obligations entered under a specific statutory authority--such as the 

Economy Act[Footnote 26]--the authorizing statute may mandate the 

deobligation of appropriations at specific times or when certain 

conditions arise.[Footnote 27] In this context, the ability of the Navy 

to access funds encumbered by unliquidated obligations does not relieve 

it of the responsibility to adhere to existing laws and regulations 

governing sound financial management. We therefore are making no 

changes to the recommendations in our report.



We are sending copies of this report to congressional committees with 

jurisdiction over DOD’s budget and the Secretary of the Navy. We will 

also make copies available to others upon request. In addition, the 

report will be available at no charge on the GAO Web site at http://

www.gao.gov.



If you or your staff have any questions about this report, please call 

me at (202) 512-9619. Key contributors to this report are listed in 

appendix III.



Sharon Pickup

Director, Defense Capabilities and Management:

Signed by Sharon Pickup:



[End of section]



Appendix I: Scope and Methodology:



Our objective was to determine whether the Navy’s unliquidated 

operating obligations were (1) properly accounted for and (2) 

periodically reviewed in accordance with DOD regulations.



To determine whether Navy’s unliquidated operating obligations were 

properly accounted for, we requested that the Defense Finance 

Accounting Office provide us with a database that identified all 

unliquidated operating obligations outstanding on September 30, 2001. 

We relied on the completeness and accuracy of that database based on 

the office’s representations and did not independently test or 

reconcile the validity of their database. For our review, we selected 

unliquidated operating obligations for fiscal years 1997-99. Older 

obligations are more likely to be in error and thus provided a better 

test of the Navy’s obligation management practices. We then divided the 

individual unliquidated operating obligations into two groups--those 

valued at less than $50,000 and those valued at $50,000 or more. Those 

valued at $50,000 or more represented $1.4 billion, or 67 percent of 

the value of all outstanding operating obligations for fiscal years 

1997-99.



From the population of obligations valued at $50,000 or more, we drew a 

stratified random sample of 205 unliquidated operating obligations to 

review. For each transaction, we obtained the following documentation: 

(1) documentary support describing each obligation, including 

amendments and modifications for each sample transaction; (2) responses 

from Navy officials regarding whether each unliquidated operating 

obligation in our sample was still needed for its original purpose 

according to the criteria in the DOD Financial Management 

Regulation[Footnote 28] (FMR); and (3) support for how to classify each 

unliquidated operating obligation in our sample as still needed, no-

longer-needed, problem disbursement, or an unresolved accounting and 

recording error.



The sample was selected from three strata defined by the dollar value 

of the obligations, as shown in table 3.



Table 2: Dollar Value Distribution of Fiscal Year 1997-99 Obligations 

Reviewed in the GAO Sample, as of September 30, 2001:



Strata: Over $10,000,000; Number of items: 5; Total value: 

$240,382,914.38.



Strata: $500,000 to $10,000,000; Number of items: 100; Total value: 

113,190,918.46.



Strata: $50,000 to $499,999; Number of items: 100; Total value: 

14,571,125.75.



Strata: Total; Number of items: 205; Total value: $368,144,958.59.



[End of table]



Source: DOD.

Note: GAO analysis of DOD data.



To determine whether the amount of each unliquidated operating 

obligation was properly accounted for, we reviewed support provided by 

the Navy, discussed the status of the unliquidated obligation with the 

primary Navy official responsible for the individual transaction, and 

used the criteria set forth in DOD’s regulations. We classified 

unliquidated operating obligation transactions as “still needed” and 

properly accounted for when the Navy provided documentation to support 

that the contracted goods or services were still needed; thus, the 

transaction passed a bona fide needs test. Items not properly accounted 

for fell into three categories. We classified the transaction “no 

longer needed for original purposes” when the Navy could not provide 

support that a bona fide need existed. We classified transactions as 

“problem disbursements” when specific disbursements were not properly 

matched to corresponding obligations recorded in the department’s 

records. We classified the remaining unliquidated operating obligation 

transactions as “unresolved accounting and recording errors” when they 

did not clearly meet the criteria for needed, no-longer-needed, or 

problem disbursements.



To determine if the Navy’s unliquidated operating obligations were 

periodically reviewed in accordance with DOD regulations, we requested 

that the Navy provide documentation and guidance on the Navy’s 

implementation of the regulations. We also interviewed officials at 

12 locations to discuss (1) their procedures for performing obligation 

reviews, (2) the magnitude of transactions involved to perform the 

review as set forth in the DOD obligation review regulations, and (3) 

whether the officials had difficulty meeting the obligation review 

requirements, including the reasons why. We visited the Commander in 

Chief of the Atlantic Fleet in Norfolk, Va.; the Commander, Navy Mid-

Atlantic Region in Norfolk, Va.; the Commander, Naval Sea Systems 

Command in Washington, D.C.; the Naval Facilities Engineering Command 

in Washington, D.C.; the Director of Strategic Systems Programs in 

Washington, D.C.; the Commander in Chief of the Pacific Fleet in Pearl 

Harbor, Hawaii; the Commander, Naval Region in Pearl Harbor, Hawaii; 

the Commander, Naval Air Force Command of the Pacific Fleet in San 

Diego, Calif.; the Commander, Naval Surface Force Command of the 

Pacific Fleet in San Diego, Calif.; the Space and Naval Warfare Systems 

Command in San Diego, Calif.; the Commander, Naval Air Systems Command 

in Patuxent River, Md.; and the Bureau of Medicine and Surgery in 

Washington, D.C.



We conducted our review from October 2001 through October 2002 in 

accordance with generally accepted government auditing standards.



[End of section]



Appendix II: Agency Comments:



DEPARTMENT OF THE NAVY:



OFFICE OF THE ASSISTANT SECRETARY (FINANCIAL MANAGEMENT AND 

COMPTROLLER) 1000 NAVY PENTAGON WASHINGTON, DC 20350-1000:



DEC 13:



Ms. Sharon L. Pickup:



Director, Defense Capabilities and Management U.S. General Accounting 

Office:



441 G. Street, N.W. Washington, DC 20548:



Dear Ms. Pickup,



This is the Department of Defense (DoD) response to the GAO draft 

report, “DEFENSE BUDGET: Improved Reviews Needed to Ensure More 

Efficient Use of Obligated Funds,” dated November 8, 2002, (GAO Code 

350126/GAO-03-275).



The Department of the Navy (DoN) has reviewed the draft report and 

partially concurs with the recommendations. More thorough efforts 

dedicated to the review of obligations in expired accounts would 

increase the accuracy and reliability of financial reports. However, 

problems in departmental financial reports have been recognized as 

attributable to numerous factors, and DoN must prioritize its approach 

to pursuing the most effective remedies across-the-board. DoN places a 

premium on reviewing those accounts available for new obligations, in 

correcting major systemic problems, and in pursuing improvements in 

financial management of broad reach. We also do not agree that the 

difficulty our organizations have had in comprehensively validating 

unliquidated obligations has precluded the use of funds for other 

appropriate needs. The availability of resources in expired accounts 

has been intentionally and progressively limited by the Congress, 

clearly establishing that the appropriateness of use outweighs the 

efficiency of use. When appropriate requirements for application of 

expired balances have arisen, encumbrances for unliquidated obligations 

have simply not been an impediment.



Our focus on systemic solutions has resulted in significant 

improvements. For example, outstanding problem disbursement balances in 

DoN, over $14 billion just a few years ago, have been reduced to less 

than $400 million in FY 2002. The DoN will continue to explore ways to 

improve our accounting and reporting systems, in accordance with the 

priorities that emerge from the Financial Management Modernization 

Program. In short, we believe that although unliquidated obligation 

validation requirements are desirable and important, the systemic 

improvement of our financial information offers the better opportunity 

for success. Specific comments for each recommendation are enclosed. My 

action officer is Mr. John Frey, (703) 614-5343, frey.john@hq.navy.mil.



We appreciate the opportunity to comment on the draft report.



Sincerely,



Albert T. Church, III:

Director:

Office of Budget:

Signed by Albert T. Church III:



GAO DRAFT REPORT - DATED NOVEMBER 8, 2002 GAO CODE 350126/GAO-03-275:



“DEFENSE BUDGET: IMPROVED REVIEWS NEEDED TO ENSURE MORE EFFICIENT USE 

OF OBLIGATED FUNDS”:



DEPARTMENT OF DEFENSE COMMENTS TO THE RECOMMENDATIONS:



RECOMMENDATION 1: The GAO recommended that the Secretary of Defense:



direct the Secretary of the Navy to adhere to DoD and Navy unliquidated 

operating obligation review regulations.	(p.12/GAO Draft Report):



DOD RESPONSE: Partially concur. Secretary of Defense direction is not 

needed to implement the recommendation. DoN has demonstrated that 

accurate budgetary and financial reports are important by focusing its 

resources on unliquidated obligations in available appropriations and 

correcting systemic issues such as problem disbursements. The DoN has 

made tremendous strides over the past several years in reducing 

outstanding problem disbursement balances, with an FY 2002 ending year 

balance of less than $400 million compared with over $14 billion 

several years ago.



Departmental financial statement accuracy and completeness in general, 

and unliquidated obligation reviews specifically, are affected by 

numerous systematic issues; therefore, DoN fund holders are required to 

prioritize their efforts and have been unable to comply fully with the 

requirement to review expired appropriations. Since reviewing 

unliquidated obligations in expired appropriations is required, the 

Department of the Navy is working to provide automated tools and 

correct systemic issues which positively impacts the fund holders’ 

ability to perform these reviews.



RECOMMENDATION 2: The GAO recommended that the Secretary of Defense:



direct the Secretary of the Navy better apply existing internal control 

activities to ensure adherence to the DoD and Navy’s unliquidated 

operating obligation review regulations, and to hold fund managers 

accountable for the accuracy and completeness of their reviews. (p.12/

GAO Draft Report):



DOD RESPONSE: Partially concur. Secretary of Defense direction is not 

needed to implement the recommendation. The Department of the Navy will 

continue to make the review process itself a continuous part of our 

management structures and stress the importance of accuracy of monthly 

and quarterly financial statements.



[End of section]



Appendix III: GAO Contacts and Staff Acknowledgments:



GAO Contacts:



Sharon Pickup (202) 512-9619

Gary L. Billen (214) 777-5703:



Staff Acknowledgments:



In addition to the individuals named above, Lori Adams, Linda Garrison, 

Gregory Kutz, Steve L. Pruitt, Rhonda P. Rose, and R.K. Wild made key 

contributions to this report.



GAO’s Mission:



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of the federal government for the American people. GAO examines the use 

of public funds; evaluates federal programs and policies; and provides 

analyses, recommendations, and other assistance to help Congress make 

informed oversight, policy, and funding decisions. GAO’s commitment to 

good government is reflected in its core values of accountability, 

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FOOTNOTES



[1] “Providing basic financial accountability” has been identified by 

GAO as a governmentwide high-risk area in need of attention. See U.S. 

General Accounting Office, High-Risk Series: An Update, GAO-01-263 

(Washington, D.C.: Jan. 2001).



[2] “Operating” appropriations include the Operation and Maintenance 

(O&M), Defense-wide, and Defense Health Program appropriations. 



[3] The Navy obligated a total of $25.6 billion in operating funds 

during fiscal years 1997-99, as reported in its Standard Accounting and 

Reporting System, which maintains approximately 90 percent of all 

operating appropriation obligations.



[4] 31 U.S.C. 1501; DOD Financial Management Regulation (FMR) volume 3, 

chapter 8, section 080301.



[5] DOD FMR volume 3, chapter 8, section 080405 A, requires all 

deobligations, adjustments or corrections to be documented and 

processed within 10 working days of their identification.



[6] 31 U.S.C. 1552.



[7] U.S. General Accounting Office, High Risk Series: An 

Update,GAO-01-263 (Washington, D.C.: Jan. 1, 2001).



[8] Naval Audit Service, Obligations Associated Primarily with 

Indefinite Delivery Contracts and Basic Ordering Agreements (Falls 

Church, Va.: February 18, 1999).



[9] Naval Audit Service, Validation of Selected Work Request 

Obligations in the Standard Accounting and Reporting System 

(Washington, D.C.: Jan. 28, 2000).



[10] U.S. General Accounting Office, Department of Defense: 

Implications of Financial Management Issues, GAO/T-AIMD/NSIAD-00-264 

(Washington, D.C.: July 20, 2000).



[11] DOD FMR volume 3, chapter 8, section 080403 B. DOD first 

implemented this requirement in May 1996 via a memorandum issued by the 

Office of the Under Secretary of Defense to all military services, 

including the Navy. DOD formally added the requirement to volume 3, 

chapter 8 of the FMR in November 2000. 



[12] DOD FMR volume 3, chapter 8, section 080403 E.



[13] 31 U.S.C., chapter 15, subchapter IV. 31 U.S.C. § 1554(b) 

specifically directs heads of agencies to report to the President and 

the Secretary of the Treasury, and to certify to those reports, 

regarding unliquidated obligations and other balances and adjustments. 

Section 1554(c) directs agencies to establish controls to assure that 

an adequate review of obligated balances is performed.



[14] 31 U.S.C. § 1535.



[15] Section 1535(d) of the Economy Act, for example, requires 

deobligation of funds at the end of their period of availability if the 

performing agency has not performed or otherwise made authorized 

contracts. 



[16] DOD FMR volume 3, chapter 8, section 080404.



[17] P.L. 97-255, § 2, 96 Stat. 814, September 8, 1982 (codified at 31 

U.S.C. § 3512(b) and (c)), and is commonly called the Federal Managers’ 

Financial Integrity Act of 1982.



[18] 31 U.S.C. § 3512(c)(1).



[19] U.S. General Accounting Office, Financial Management: Problems in 

Accounting for Navy Transactions Impair Funds Control and Financial 

Reporting, GAO/AIMD-99-19 (Washington, D.C.: Jan. 19, 1999).



[20] As of Mar. 10, 2002.



[21] As of June 14, 2002.



[22] U.S. General Accounting Office, High Risk Series: An Update, 

GAO-01-263 (Washington, D.C.: Jan. 1, 2001).



[23] 31 U.S.C., chapter 15, subchapter IV. 31 U.S.C. § 1554(b) 

specifically directs heads of agencies to report to the President and 

the Secretary of the Treasury, and to certify to those reports 

regarding unliquidated obligations and other balances and adjustments. 

Section 1554(c) directs agencies to establish controls to assure that 

an adequate review of obligated balances is performed.



[24] P.L. 97-255, § 2, 96 Stat. 814, September 8, 1982 (codified at 31 

U.S.C. § 3512(b) and (c)), and is commonly called the Federal Managers’ 

Financial Integrity Act of 1982.



[25] 31 U.S.C. § 3512(c)(1).



[26] 31 U.S.C. § 1535.



[27] Section 1535(d) of the Economy Act, for example, requires 

deobligation of funds at the end of their period of availability if the 

performing agency has not performed or otherwise made authorized 

contracts. 



[28] DOD FMR volume 3, chapter 8, section 080303 A.



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of the federal government for the American people. GAO examines the use 

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analyses, recommendations, and other assistance to help Congress make 

informed oversight, policy, and funding decisions. GAO’s commitment to 

good government is reflected in its core values of accountability, 

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20548: