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Report to the Secretary of Defense:

United States Government Accountability Office:

GAO:

November 2004:

Military Personnel:

DOD Needs to Strengthen the Annual Review and Certification of Military 
Personnel Obligations:

GAO-05-87R:

United States Government Accountability Office:

Washington, DC 20548:

November 29, 2004:

The Honorable Donald H. Rumsfeld: 
Secretary of Defense:

Subject: Military Personnel: DOD Needs to Strengthen the Annual Review 
and Certification of Military Personnel Obligations:

Dear Mr. Secretary:

Each year, Congress appropriates billions of dollars to pay and support 
U.S. military personnel at home and overseas. In fiscal year 2003, 
military personnel (MILPERS) appropriations amounted to more than 
$109 billion.[Footnote 1] Once the funds are appropriated, the military 
services are responsible for ensuring that the funds are properly 
obligated and disbursed. Their efforts include conducting an annual 
review and certification to ensure that obligations are still needed in 
the amounts and for the purposes obligated and that disbursements are 
supported by a proper obligation of funds. The end-of-the-fiscal-year 
review is critical to the next year's budget formulation process 
because the services use the obligations for the most recent fiscal 
year completed as a point of reference in developing their new budgets, 
and Congress uses this information as a point of comparison in its 
review of the new budget requests.

In our prior work for the House and Senate appropriation and 
authorization committees, reviewing the services' budget 
justifications, we found that although the services were conducting 
annual reviews and certifications, the services did not review 
transactions by matching obligations to individual disbursements in all 
of the years that disbursements can occur, as required by the 
Department of Defense (DOD) Financial Management Regulation.[Footnote 
2] We also found that the services disbursed some obligations for 
purposes other than those reported in their budget submission, but 
their year-end reviews did not show how these funds were actually 
disbursed. Specifically, the year-end reviews did not provide 
transparency over disbursements that occurred after the first year of 
the appropriation. As a result of our work, the report by the conferees 
for the House and Senate defense appropriations committees for fiscal 
year 2004 directed "the Secretary of Defense to ensure that the 
services strengthen the annual review process by including a review of 
the accuracy of prior year appropriations below the budget activity 
level. To facilitate this review, the financial management improvement 
initiative should include financial decision-making processes that 
provide transparency of disbursements at the same level as the budget 
submission."[Footnote 3] In its report for fiscal year 2005, the House 
Appropriations Committee reiterated this direction.[Footnote 4]

For this letter, we examined whether the military services are 
reviewing the accuracy of their MILPERS obligation balances as required 
by DOD's Financial Management Regulation and as directed by 
congressional conferees, and, if not, what factors are preventing the 
services from doing this.

To answer this objective, we reviewed applicable Office of the 
Secretary of Defense (OSD) regulations and the services' procedures for 
performing the reviews; interviewed OSD officials in the Office of 
Accounting, Finance, Policy and Analysis, within the office of the 
Under Secretary of Defense (Comptroller/Chief Financial Officer), as 
well as service Comptroller officials; and reviewed Defense Finance and 
Accounting Service (DFAS) financial reports. We conducted our review 
from August 2004 to October 2004 in accordance with generally accepted 
government auditing standards. We determined that the data used in this 
letter are generally reliable for the purposes for which we used them. 
(See encl. I for more information on our scope and methodology.)

Results in Brief:

The military services are not matching obligations to disbursements at 
the individual disbursement transaction level in all of the years that 
disbursements can occur as required by the Financial Management 
Regulation. Additionally, the services are not reporting the obligation 
balances at the budget submission level as directed by congressional 
conferees. This has made it difficult, if not impossible, for decision 
makers to oversee how the services actually use MILPERS funds. One 
reason for this is that OSD has not provided the services with explicit 
instructions in the Financial Management Regulation requiring them to 
review MILPERS obligations at the budget justification level, 
especially as related to disbursements made after the first year of the 
appropriation. Moreover, OSD has not effectively monitored the 
services' compliance with the Financial Management Regulation's 
requirement to review obligation balances. Unless the services 
strengthen their year-end reviews and certification processes, the 
actual use of MILPERS funds will continue to be masked and the baseline 
for future budget requests may be inaccurate. In addition, OSD has not 
ensured that the detailed financial data from DFAS that the services 
need to conduct their reviews have been readily available. DFAS only 
produces the detailed data for the first year of the appropriation. 
Nevertheless, some of the services have begun to gather MILPERS budget 
execution data at the budget justification level for all years of the 
appropriation. For example, the Army and Marine Corps have started to 
obtain needed data from DFAS to improve their review and follow the 
congressional direction. Until all the services can strengthen their 
budget execution accounting and related year-end review process to 
ensure that their MILPERS obligations are valid, accurate, and matched 
to individual disbursements and summarized at the level at which funds 
were justified to Congress, decision makers will find it difficult, if 
not impossible, to properly oversee how the services actually use the 
appropriations. As a result, neither DOD nor the Congress has reliable 
information on the status of MILPERS appropriations and future budget 
submissions could be over-or understated.

We are recommending that OSD clarify the Financial Management 
Regulation provisions applicable to the year-end review and 
certification process for MILPERS obligations, monitor the services' 
annual review results, and take steps to ensure that the services have 
the financial information they need to conduct proper reviews.

Background:

MILPERS appropriations are available for obligation for a period of 
1 year (or for the duration of the fiscal year in which the budget 
authority was appropriated). However, the appropriated funds remain 
available for 5 additional fiscal years for the payment of obligations 
(e.g., for permanent change-of-station contracts or pay adjustments 
that were incurred during the year of appropriation). Thus, the 
military services can disburse MILPERS obligations over a period of up 
to 6 years. For example, about 94 percent of fiscal year 2003 MILPERS 
obligations were disbursed during the first year. The remaining 
6 percent, or about $6.5 billion, was not disbursed (i.e., remained as 
unliquidated obligations) and is available to disburse for up to 5 
additional fiscal years. MILPERS obligations differ from other 
obligations such as for operations and maintenance and procurement 
where payments are made for specific transactions, such as under a 
contract. MILPERS individual payments are made against a planned level 
of obligations for like items,[Footnote 5] such as incentive bonuses 
and payroll checks. The MILPERS fund manager allots an amount to DFAS 
to expend for like disbursements.

The annual review and certification process for MILPERS appropriations 
serves as an important oversight and internal control tool for decision 
makers in OSD, the military services, and the House and Senate 
appropriation and authorization committees, as well as input to 
financial statements, to ensure that appropriated funds are properly 
obligated and disbursed at the end of each fiscal year. OSD officials 
responsible for Financial Management Regulations (the Office of 
Accounting, Finance, Policy and Analysis) within the office of the 
Under Secretary of Defense (Comptroller/Chief Financial Officer) stated 
that the services are required to review commitments and obligation 
transactions for timeliness, accuracy, and completeness and ensure that 
unliquidated amounts are valid.[Footnote 6] The review covers the 
obligation balances for each year, starting with the appropriation year 
plus 5 years to expend until the appropriation cancels.[Footnote 7] 
Only the first year of the appropriation is reviewed at the line item 
level. The subsequent 5 years of obligations can only be reviewed at 
the budget activity and subactivity level because of data limitations. 
Based on this review, the services must then certify to the President 
and the Secretary of the Treasury[Footnote 8] that obligations are 
accurate and that disbursements from the account are supported by an 
obligation and are otherwise proper.[Footnote 9] When the year-end 
reviews identify funds that are no longer needed, the services should 
deobligate the funds and make them available for other permissible 
purposes.[Footnote 10]

In our prior work on MILPERS budgets, we found that the obligations 
reported at the end of the appropriation year were not always disbursed 
as reported. In researching some of the differences, we also found that 
the services' obligation reviews for the 5 years after the obligations 
were made could not identify the changes at the same level of detail as 
that used in the budget request to Congress. Moreover, the reports used 
for the review did not provide information on where the funds were 
moved or an audit trail to the disbursements.

DOD submits its MILPERS budget request, including a report of actual 
obligations for the fiscal year just completed, at three levels of 
detail. The broadest level is the budget activity (BA), followed by 
subactivity groups (SAG) and line items.[Footnote 11] As an example, 
table 1 shows these three levels in the Air Force's fiscal year 2003 
budget request to Congress. The fiscal year 2003 budget data is the 
most recent year available for which the services have certified their 
obligations as valid and accurate.

Table 1: Examples of Levels of Budget Submission in the Air Force's 
Fiscal Year 2003 MILPERS Budget Justification Book:

Dollars in millions; 

Levels of budget submission: Budget activity; 
Title: Pay and allowance for officers; 
Actual FY 2001: $6,129.5; 
Estimate FY 2002: $6,609.0; 
Requested FY 2003: $7,204.3.

Levels of budget submission: Subactivity group; 
Title: Basic allowance for housing, officers; 
Actual FY 2001: $642.8; 
Estimate FY 2002: $717.8; 
Requested FY 2003: $778.9.

Levels of budget submission: Line item; 
Title: Domestic with dependents, officers; 
Actual FY 2001: $421.4; 
Estimate FY 2002: $473.4; 
Requested FY 2003: $517.7. 

Source: Air Force.

[End of table]

* The Air Force requested nearly $7.2 billion in the Pay and Allowance 
budget activity for officers. Within this broad budget activity were 
several SAGs, one of which was Basic Allowance for Housing. Finally, 
within this SAG were several different line items, one of which was 
Domestic with Dependents.

* The Air Force also included the amount it certified as obligated for 
each of the three levels of detail for (1) the fiscal year that was 
just completed (2001) as a point of comparison for the budget request 
and (2) the estimate of how much it planned to use for the current 
fiscal year (2002).

Table 2 shows how the military services would review their obligations 
at the three levels of budget detail for the prior-year 2001 
appropriation and the subsequent 5 years before the appropriation 
cancelled. For example, the services would track the fiscal year 2001 
obligations at all three levels of detail, but they would track the 
fiscal year 2002 to fiscal year 2006 obligations at only the budget 
activity and subactivity levels and not at the line item level. Thus, 
the way that obligations are disbursed after the initial year of 
appropriation is not transparent. For example, Congress and decision 
makers in OSD and the services would assume that the $421.4 million 
obligation for the line item "Domestic with Dependents" which was 
certified as correct at the end of the fiscal year would disburse for 
this purpose. However, because disbursements are not tracked at this 
level after the first year, the Air Force cannot determine if the 
$421.4 million obligated was actually disbursed for Domestic with 
Dependents in fiscal years 2002 through 2006. Consequently, if the 
$421.4 million is not dispersed, or is dispersed differently, the 
baseline of the budget will be incorrect and may mask true requirements 
and actual spending patterns.

Table 2: Financial Tracking of Services' Disbursements to Obligations 
for Fiscal Year 2001 Appropriations:

Levels of budget submission: Budget activity; 
Title: Pay and allowance for officers; 
Financial tracking of disbursements to obligations: 
Fiscal year of appropriation: 2001: Yes; 
Financial tracking of disbursements to obligations: 
5 years to expend (fiscal years): 2002: Yes; 
Financial tracking of disbursements to obligations: 
5 years to expend (fiscal years): 2003: Yes; 
Financial tracking of disbursements to obligations: 
5 years to expend (fiscal years): 2004: Yes; 
Financial tracking of disbursements to obligations: 
5 years to expend (fiscal years): 2005: Yes; 
Financial tracking of disbursements to obligations: 
5 years to expend (fiscal years): 2006: Yes.

Levels of budget submission: Subactivity group; 
Title: Basic allowance for housing, officers; 
Financial tracking of disbursements to obligations: 
Fiscal year of appropriation: 2001: Yes; 
Financial tracking of disbursements to obligations: 
5 years to expend (fiscal years): 2002: Yes; 
Financial tracking of disbursements to obligations: 
5 years to expend (fiscal years): 2003: Yes; 
Financial tracking of disbursements to obligations: 
5 years to expend (fiscal years): 2004: Yes; 
Financial tracking of disbursements to obligations: 
5 years to expend (fiscal years): 2005: Yes; 
Financial tracking of disbursements to obligations: 
5 years to expend (fiscal years): 2006: Yes.

Levels of budget submission: Line item; 
Title: Domestic with dependents, officers; 
Financial tracking of disbursements to obligations: 
Fiscal year of appropriation: 2001: Yes; 
Financial tracking of disbursements to obligations: 
5 years to expend (fiscal years): 2002: No; 
Financial tracking of disbursements to obligations: 
5 years to expend (fiscal years): 2003: No; 
Financial tracking of disbursements to obligations: 
5 years to expend (fiscal years): 2004: No; 
Financial tracking of disbursements to obligations: 
5 years to expend (fiscal years): 2005: No; 
Financial tracking of disbursements to obligations: 
5 years to expend (fiscal years): 2006: No. 

Source: GAO analysis of DOD information.

Note: The line item level is usually a summary level of like 
disbursements. Fiscal years 2005 and 2006 are displayed as if the 
services followed the current reporting format.

[End of table]

The Army had financial information at the line item level, but the 
information was cumbersome to crosswalk to the budget submission level 
of detail. Starting in fiscal year 2004, a new accounting structure 
will allow the Army to compare disbursement data to the budget 
submission level of detail.

Services Are Not Reviewing the Accuracy of Obligations Because OSD Has 
Not Provided Instructions, Monitored Compliance, or Ensured Access to 
Detailed Data:

The military services are not reviewing the accuracy of their MILPERS 
obligation balances, as required by the Financial Management Regulation 
and as directed by congressional conferees. OSD has not provided the 
services with explicit instruction in the Financial Management 
Regulation to guide them in their year-end reviews and has not 
effectively monitored their compliance with the regulation as it is 
currently written. Also, OSD has not ensured that the services have 
available the detailed financial data they need for their annual 
reviews. Despite this, some of the services have begun to gather the 
necessary financial reporting data. Until the services can strengthen 
their year-end review process, the actual use of MILPERS funds will 
continue to be masked and the baseline for budget requests may be 
inaccurate. Additionally, it will be difficult, if not impossible, for 
decision makers to oversee properly how the services actually use 
MILPERS funds.

OSD Has Not Provided Clear Guidance or Monitored Annual Reviews:

DOD's Financial Management Regulation sets out general instructions on 
the review process that DOD components are to follow. The services are 
responsible for conducting reviews of outstanding commitments and 
obligation transactions for timeliness, accuracy, and 
completeness.[Footnote 12] As part of this process, they are to perform 
a review of obligations that have not disbursed (unliquidated 
obligations).[Footnote 13] Even though DOD's Financial Management 
Regulation requires that the services review and match individual 
disbursements to obligations,[Footnote 14] it does not provide explicit 
instructions requiring them to review MILPERS appropriations at the 
transaction level until the appropriation cancels.

OSD officials who are responsible for the financial management 
regulation on obligation reviews told us that they are considering 
revisions that would require the services to review MILPERS obligations 
three times a year, as they require for other appropriation accounts. 
The triannual review would enhance DOD's and the services' ability to 
ensure that individual disbursements are being matched to obligations 
and are complying with DOD regulations and sound accounting and 
internal control requirements. Showing budget execution data at the 
same level of detail at which it was requested would be useful for both 
agency and congressional oversight and financial decision-making. 
However, OSD officials said that specific instructions on how MILPERS 
obligations should be reviewed are not needed because they believe the 
regulation is adequate. We found that the regulations do not 
specifically state how MILPERS obligations are to be reviewed. Specific 
language on how MILPERS obligations reviews are to be conducted would 
make clear to the services how detailed the reviews should be. But the 
officials agreed that a revision requiring DOD components to submit 
copies of their review results to OSD for monitoring purposes is 
needed.[Footnote 15] In addition, OSD officials told us they are 
considering whether to follow the congressional conferee's direction, 
which calls for providing transparency of disbursements at the same 
level (line item level) as the budget submission until the 
appropriation cancels.

OSD Has Not Ensured Availability of Detailed Financial Data, but 
Services Have Taken Steps to Obtain Data:

The financial information provided by DFAS does not provide the 
detailed information that the services need to match obligations to 
disbursements at the budget submission (or line item) level for the 
5 years after the year of appropriation, nor does it provide an audit 
trail to the individual disbursements, required for sound management 
and internal control. The services' fund holders use monthly reports 
(Accounting Report M-1002)[Footnote 16] provided by DFAS to review 
their obligation balances and disbursements. While these reports 
contain summaries of obligations and disbursements for all 6 years of 
the appropriation, they do not include data down to the line item level 
(budget submission level) for any of the years. For the first year of 
appropriation, the services have relied on other financial data 
(i.e., summaries of like items) to perform their year-end reviews to 
the line item level. However, they do not have similar data to make the 
review at the line item level for the subsequent 5 years that funds can 
be disbursed or until the appropriation cancels.[Footnote 17] Moreover, 
OSD and service officials acknowledge that there is no requirement that 
the services use funds remaining after the year of appropriation for 
the purposes obligated and reported in the budget submission. If funds 
are used differently than reported, the actual use of funds is masked, 
and the baseline for the budget requests may be inaccurate and/or 
misleading. For example, obligated MILPERS funds that are not disbursed 
for officers' basic pay in the year of appropriation could be used for 
another authorized purpose for that year of appropriation, such as 
enlisted personnel bonuses, within the next 5 years of availability. 
However, current financial reports would not show this variance. As a 
result, the reported obligations in the budget submission may not 
represent how the services actually expend the funds and may not be an 
accurate point of comparison for future budget requests.

Recently, the military services have taken steps--albeit different 
ones--to get access to the detailed financial information they need to 
strengthen their review of the accuracy of obligation balances. 
Officials in each service provided the following descriptions on what 
they are currently doing and their limitations for making a more 
detailed review.

* The Air Force has started to review the accuracy of prior-year 
obligations, but it does not yet have the financial information needed 
to make the review at the line item level. Air Force comptroller 
officials told us that DFAS will be able to provide financial reports 
at the line item level by November 2005 and will be able to match 
obligations to disbursements at this level beginning in fiscal year 
2006.

* Beginning with the fiscal year 2004 appropriations, the Army has been 
able to match disbursements to obligations at the line item level 
because the service built a data warehouse that can be used to research 
and summarize obligations and disbursements. Army officials told us 
that, starting with the fiscal 2004 MILPERS appropriation, they would 
be able to produce financial reports at the budget submission level.

* The Marine Corps has a different DFAS system than the other services. 
It has an integrated personnel and pay system and data history that 
allows it to compare disbursements to obligations at the most detailed 
level of each individual disbursement. The Marine Corps also has a data 
warehouse that can be used to research obligations and individual 
disbursement transactions that make up the financial reports. Officials 
told us that, although they do not currently get financial reports from 
DFAS at the line item level after the year of appropriation, DFAS could 
revise its reporting format to provide such detail for a one-time cost 
of about $90,000. With revised reports (M-1002) and the data warehouse, 
the Marine Corps could review and certify the accuracy of outstanding 
obligations at the line item level and research related transactions by 
matching disbursements to obligations.

* Although the Navy has taken a number of steps to improve its review 
of the accuracy of obligations in the year of appropriation, Navy 
officials told us they have no plans to request a change in the monthly 
account reports (M-1002) to show obligations and disbursements at the 
line item level for the additional 5 years. Navy comptroller officials 
do not view the improved oversight that such information would provide 
as either necessary or required.

Conclusions:

Each year, transparency over the disbursement of several billion 
dollars of MILPERS appropriations is placed at risk because the 
military services are not reviewing the accuracy of their obligation 
balances at the level of detail required by DOD's Financial Management 
Regulation and as directed by congressional conferees. Although the 
services conduct the annual reviews, it is OSD's responsibility to 
ensure that the services have clear guidance and sufficiently detailed 
data to undertake these reviews at the level of detail required. 
Although three of the four services have initiated steps to obtain 
financial data at the necessary level of detail, their efforts have 
varied. Until OSD can ensure that the services are doing the reviews as 
required, the actual use of some MILPERS funds will continue to be 
masked and the baseline for budget requests may be inaccurate.

Recommendations for Executive Action:

We are making two recommendations to ensure that the services are 
reviewing the accuracy of MILPERS obligations and disbursements as 
required. You should direct the Under Secretary of Defense 
(Comptroller/Chief Financial Officer) to require:

* the Office of Accounting, Finance, Policy and Analysis to monitor the 
services' review results and to clarify the regulation that applies to 
the review and certification of the accuracy of MILPERS obligations, by 
including MILPERS accounts in its triannual review requirements and 
providing specific guidance to the services to match obligations to 
individual disbursement transactions until the appropriation cancels 
and:

* the Defense Finance and Accounting Service to change the format in 
the monthly financial reports for MILPERS appropriations to include 
information at the line item level (budget submission level) for all 
6 years that funds can be disbursed until the appropriation cancels.

Title 31 U.S.C. § 720 requires the head of a federal agency to submit a 
written statement of the actions taken on our recommendations to the 
Senate Committee on Governmental Affairs and the House Committee on 
Government Reform no later than 60 days after the date of this letter. 
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 letter.

Agency Comments and Our Evaluation:

The Under Secretary of Defense (Comptroller) provided written comments 
to a draft of this letter. The Department of Defense's comments are 
included in enclosure II. DOD concurred with both of our 
recommendations. DOD concurs with the intent to clarify the 
requirements of the year-end certification process by requiring 
triannual reviews for MILPERS accounts. DOD stated that it will include 
MILPERS appropriations in the triannual review requirements of the 
Department of Defense Financial Management Regulation. DOD also concurs 
with the intent to ensure that the services have the financial 
information they need to conduct proper reviews of MILPERS accounts. 
DOD stated that it will direct the departments of the Navy and the Air 
Force, in conjunction with the Defense Finance and Accounting Service, 
to conduct a study of the feasibility of modifying the financial 
systems to record and report prior year disbursements at the budget 
submission level.

We are sending copies of this letter to House and Senate appropriation 
and authorization committees. We will also make copies available to 
others upon request. In addition, this letter is available at no charge 
on GAO's Web site at http://www.gao.gov. If you have any questions 
concerning this letter, please contact me on (202) 512-5559. Key 
contributors to this assignment were Don Snyder, Tom Pantelides, Gary 
Billen, Pawnee Davis, and Nancy Benco.

Sincerely yours,

Signed by: 

Derek B. Stewart, Director: 
Defense Capabilities and Management:

Enclosures:

[End of section]

Enclosure I: Scope and Methodology:

To identify the reasons why the military services were not properly 
conducting annual reviews of MILPERS obligation balances, we reviewed 
applicable Financial Management Regulations, the services' procedures 
for performing the reviews, and monthly financial reports issued by 
DFAS. We reviewed the results of our prior budget justification issue 
papers that were provided to the House and Senate appropriation and 
authorization committees. We also interviewed Air Force, Army, Navy, 
and Marine Corps comptroller officials to determine what actions they 
were taking to improve their year-end review and certification process 
and what limitations they were encountering in these efforts, including 
problems in obtaining needed financial information from DFAS. To 
determine the ability of DFAS to provide the military services with 
needed financial information, we interviewed DFAS and service officials 
responsible for financial information used in the review of obligations 
and disbursements and reviewed existing financial reports on the status 
of MILPERS appropriations and obligations. We conducted our review from 
August 2004 to October 2004 in accordance with generally accepted 
government auditing standards. We determined that the data used in the 
letter are generally reliable for the purposes for which we used them.

[End of section]

Enclosure II: Comments from the Department of Defense:

UNDER SECRETARY OF DEFENSE:

COMPTROLLER:

1100 DEFENSE PENTAGON: 
WASHINGTON, DC 20301-1100:

NOV 23 2004:

Derek B. Stewart, Director:
Defense Capabilities and Management:
United States Government Accountability Office: 
Washington, DC 20548:

Dear Mr. Stewart:

This is the Department of Defense response to the Government 
Accountability Office (GAO) draft report, "Military Personnel: Annual 
Review and Certification of Military Personnel Obligations" (GAO-05-
87R). The Department appreciates the opportunity to review the draft 
report and provide comments.

I agree with the intent of the recommendations to clarify the 
requirements applicable to the year-end certification process by 
requiring triannual reviews and to ensure that the Services have the 
financial information they need to conduct proper reviews. More 
detailed comments are at the enclosure.

My point of contact for this matter is Mr. Oscar Covell. He may be 
reached by e-mail: oscar.covell@osd.mil or by telephone at (703) 697-
6149.

Sincerely,

Signed by: 

Robert J. Henke: 
Principal Deputy:

Enclosure: As stated:

GAO DRAFT REPORT / DATED OCTOBER 28, 2004 GAO-05-87R (CODE 350489):

MILITARY PERSONNEL: Annual Review and Certification of Military 
Personnel Obligations:

DEPARTMENT OF DEFENSE COMMENTS TO THE RECOMMENDATIONS:

To ensure that the Services are reviewing the accuracy of MILPERS 
obligations and disbursements as required, you should direct the Under 
Secretary of Defense (Comptroller/Chief Financial Officer) to require:

RECOMMENDATION 1: The Office of Accounting and Finance Policy and 
Analysis to clarify the regulation that applies to the review and 
certification of the accuracy of MILPERS obligations, by including 
MILPERS accounts in its triannual review requirements and providing 
specific guidance to the Services to match obligations to individual 
disbursement transactions until the appropriation cancels, and to 
monitor the Services' review results. (p. 12/GAO Draft Report):

DoD RESPONSE: Concur. We will clarify the guidance in the Department of 
Defense Financial Management Regulation (DoDFMR) during the second 
quarter of Fiscal Year (FY) 2005 to include the Military Personnel 
appropriations in the triannual review requirements.

RECOMMENDATION 2: The Defense Finance and Accounting Service to change 
the format in the monthly financial reports for MILPERS appropriations 
to include information at the line item level (budget submission level) 
for all 6 years that funds can be disbursed until the appropriation 
cancels. (p. 12/GAO Draft Report):

DoD RESPONSE Concur. As stated in the report, the Department of the 
Army has recently modified its procedures to record and report 
disbursements for prior year entitlement obligations at the line item 
level on the DD Compt 1002, "Appropriation Status by Fiscal Year 
Program and Subaccounts," for its Military Personnel appropriations. 
Consequently, the Under Secretary of Defense (Comptroller) will direct 
the Departments of the Navy and the Air Force, in conjunction with the 
Defense Finance and Accounting Service (DFAS), to conduct a feasibility 
study of the cost and time required to modify financially related 
systems to record and report disbursements for prior year entitlement 
obligations at the line item level and forward the results to this 
office by January 31, 2005.

[End of letter]

UNDER SECRETARY OF DEFENSE:

COMPTROLLER:

1100 DEFENSE PENTAGON: 
WASHINGTON, DC 20301-1100:

NOV 23 2004:

MEMORANDUM FOR ASSISTANT SECRETARY OF THE NAVY (FINANCIAL MANAGEMENT 
AND COMPTROLLER) ASSISTANT SECRETARY OF THE AIR FORCE (FINANCIAL 
MANAGEMENT AND COMPTROLLER) DIRECTOR, DEFENSE FINANCE AND ACCOUNTING 
SERVICE:

SUBJECT: Government Accountability Office (GAO) Draft Report: "MILITARY 
PERSONNEL: DoD Needs to Strengthen the Annual Review and Certification 
of Military Personnel Obligations," dated October 28, 2004 (GAO Code 
350489/GAO 05-87R):

The attached GAO draft audit report revealed that the Military Services 
track current fiscal year obligations at the line item level for the 
military personnel appropriations while expired year obligations are 
tracked at only the budget activity level. The GAO concluded that 
disbursements made during the expired years of an appropriation are not 
matched to line item obligations. The GAO also concluded the Military 
Services are not reviewing the accuracy of their Military Personnel 
appropriations as required by Volume 3, Chapter 8, of the Department of 
Defense Financial Management Regulation (DoDFMR).

The GAO observed that the Department of the Army has developed a data 
warehouse to produce prior year financial reports at the line item 
level. This action was necessary because the Army's entitlement systems 
do not provide information regarding prior year obligation adjustments 
to accounting systems.

The Departments of the Navy and the Air Force, in conjunction with the 
Defense Finance and Accounting Service (DFAS), are to conduct a 
feasibility study of the cost and time required to modify financially 
related systems to record and report disbursements for prior year 
entitlement obligations at the line item level. I encourage you to the 
extent possible to capitalize on the Army's accomplishments in this 
matter. The results of your study are to be forwarded to this office by 
January 31, 2005.

My point of contact is Mr. Oscar G. Covell. He may be reached by e-
mail: oscar.covell@osd.mil or by telephone at (703) 697-6149.

Signed by: 

Robert J. Henke: 
Principal Deputy:

Attachment: As stated:

cc:
Deputy Comptroller (Program/Budget):
Assistant Secretary of the Army (Financial Management & Comptroller):

[End of memorandum] 

[End of section]

FOOTNOTES

[1] MILPERS appropriations are used for pay, benefits, incentives, 
allowances, housing, subsistence, travel for military personnel, and 
reserve training. 

[2] DOD 7000.14-R, vol. 3, chapter 8, paragraph 080402.B(2), November 
2000; chapter 11, paragraph 110301, January 2001.

[3] H.R. Conf. Rep. No. 108-283, 62 (2003).

[4] H.R. Rep. No. 108-553, 20 (2004).

[5] OSD and service officials referred to this as an open allotment 
where the fund manager provides DFAS with authority to make appropriate 
disbursements for transactions that meet the criteria.

[6] DOD 7000.14-R, vol. 3, chapter 8, paragraph 080401, and paragraph 
080403, November 2000.

[7] As of October 2004 (fiscal year 2005), for example, the services 
would have obligation balances subject to review for prior-year 
appropriations for fiscal years 2000, 2001, 2002, 2003, and 2004. 

[8] 31 U.S.C. § 1554(b)(1). 

[9] 31 U.S.C. § 1554(b)(2)(E). 

[10] Funds also can be released to OSD for transfer into the Foreign 
Currency Fluctuation account if they are transferred within 2 years 
after the appropriation year; this account exists to minimize the 
effect to the Operations and Maintenance and the MILPERS accounts of 
unanticipated declines in the value of the dollar vis-à-vis foreign 
currencies.

[11] The services use different terms to denote these levels. For 
example, the Air Force refers to subactivity groups as project codes 
and line items as subproject codes; the Army refers to them as 
subactivity groups and program elements; the Navy refers to them as 
subactivity groups and summary account identifiers; and the Marine 
Corps refers to them as subactivity groups and line items. We use 
budget activity, subactivity, and line item to generically describe 
these various levels within a budget request.

[12] DOD 7000.14-R, vol. 3, chapter 8, paragraph 080401, November 2000.

[13] DOD 7000.14-R, vol. 3, chapter 8, paragraph 080403, November 2000.

[14] DOD 7000.14-R, vol. 3, chapter 11, paragraph 110302(D), January 
2001.

[15] The regulation requires the services' fund managers to confirm to 
their assistant secretaries (Financial Management and Comptroller) that 
a review has been performed, but it does not require them to notify 
OSD. DOD 7000.14-R, vol. 3, chapter 8, paragraph 080405(B), November 
2000.

[16] DOD 7000.14-R, vol. 6A, chapter 4, paragraph 0406, January 2002.

[17] DOD is also working to implement a new military personnel and 
payroll system--the Defense Integrated Military Human Resource System 
(DIMHRS). DIMHRS eventually will provide uniform personnel and payroll 
services to each of the Services, the Reserves, and the Air and Army 
National Guard, but this review did not cover the extent it will 
interface with the DFAS financial systems and provide the type of 
reports discussed in this letter.