Financial Management
Audit of the White House Commission on the National Moment of Remembrance for Fiscal Years 2003 and 2002 Gao ID: GAO-04-497R May 20, 2004The White House Commission on the National Moment of Remembrance (Commission) was created on December 28, 2000, by the National Moment of Remembrance Act (Act). The Commission received appropriated funds in fiscal years 2003 and 2002. Its purpose is to sustain the American spirit through acts of remembrance for those who died serving their country, not only on Memorial Day, but also throughout the year. We are required by the Act to audit the financial transactions of the Commission, and this report covers our work on its fiscal years 2003 and 2002 financial transactions.
We found that the Commission's financial records for fiscal years 2003 and 2002 were incomplete and that its financial record keeping lacked basic internal controls. As a result, we were unable to audit the Commission's financial transactions, and the Commission does not have reasonable assurance that its records are accurate, that it has adequate information for decision making, or that its funds are being spent as intended. The Commission's records of financial transactions for fiscal years 2003 and 2002, including receipts and expenditures, were incomplete and not regularly reconciled to the statements produced by the Department of Veterans Affairs (VA) or General Services Administration (GSA), agencies that provided the Commission with administrative and financial processing services. In addition, significant amounts of the Commission's expenditures for fiscal years 2003 and 2002 were not supported by documentation. Without such basic internal controls as documentation to support transactions and the reconciliation of transactions recorded by the Commission to the actual receipts and expenditures processed by VA and GSA, the Commission does not have reasonable assurance that its financial information is complete and accurate, that its funds are being spent as intended, and that financial and programmatic decisions are based on complete and accurate information. The Commission's difficulties in financial record keeping and internal controls result, in part, from the Commission's lack of staffing and financial expertise. When the Commission received its initial appropriations in 2002, the Commission assumed several program activities of No Greater Love, a nonprofit organization founded in 1971. The Commission also shares office space, services, and personnel with No Greater Love. Although the Act allows the Commission to enter into cooperative agreements with private entities in carrying out its duties, the respective program sponsorship costs borne by the Commission and No Greater Love have not been accounted for and documented clearly. Without clear accountability and transparency of activities and related costs for each entity, donors and Congress are at risk of not knowing which programs they are supporting.
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Director: Team: Phone:GAO-04-497R, Financial Management: Audit of the White House Commission on the National Moment of Remembrance for Fiscal Years 2003 and 2002
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May 20, 2004:
The Honorable Orrin G. Hatch:
Chairman:
The Honorable Patrick J. Leahy:
Ranking Minority Member:
Committee on the Judiciary:
United States Senate:
The Honorable F. James Sensenbrenner, Jr.
Chairman:
The Honorable John Conyers, Jr.
Ranking Minority Member:
Committee on the Judiciary:
House of Representatives:
Subject: Financial Management: Audit of the White House Commission on
the National Moment of Remembrance for Fiscal Years 2003 and 2002:
The White House Commission on the National Moment of Remembrance
(Commission) was created on December 28, 2000, by the National Moment
of Remembrance Act (Act).[Footnote 1] The Commission received
appropriated funds in fiscal years 2003 and 2002. Its purpose is to
sustain the American spirit through acts of remembrance for those who
died serving their country, not only on Memorial Day, but also
throughout the year. We are required by the Act to audit the financial
transactions of the Commission, and this report covers our work on its
fiscal years 2003 and 2002 financial transactions.
Results in Brief:
We found that the Commission's financial records for fiscal years 2003
and 2002 were incomplete and that its financial record keeping lacked
basic internal controls. As a result, we were unable to audit the
Commission's financial transactions, and the Commission does not have
reasonable assurance that its records are accurate, that it has
adequate information for decision making, or that its funds are being
spent as intended.
The Commission's records of financial transactions for fiscal years
2003 and 2002, including receipts and expenditures, were incomplete and
not regularly reconciled to the statements produced by the Department
of Veterans Affairs (VA) or General Services Administration (GSA),
agencies that provided the Commission with administrative and financial
processing services. In addition, significant amounts of the
Commission's expenditures for fiscal years 2003 and 2002 were not
supported by documentation.
Without such basic internal controls as documentation to support
transactions and the reconciliation of transactions recorded by the
Commission to the actual receipts and expenditures processed by VA and
GSA, the Commission does not have reasonable assurance that its
financial information is complete and accurate, that its funds are
being spent as intended, and that financial and programmatic decisions
are based on complete and accurate information.
The Commission's difficulties in financial record keeping and internal
controls result, in part, from the Commission's lack of staffing and
financial expertise. The Commission depends on temporary and part-time
detailees from other agencies, and has never had the full level of
staffing called for in its authorizing legislation.
When the Commission received its initial appropriations in 2002, the
Commission assumed several program activities[Footnote 2] of No Greater
Love, a nonprofit organization founded in 1971 by the Commission's
current White House Liaison and Executive Director. The Commission also
shares office space, services, and personnel with No Greater Love.
Although the Act allows the Commission to enter into cooperative
agreements with private entities in carrying out its duties, the
respective program sponsorship costs borne by the Commission and No
Greater Love have not been accounted for and documented clearly.
Without clear accountability and transparency of activities and related
costs for each entity, donors and Congress are at risk of not knowing
which programs they are supporting.
Congress may wish to consider amending the National Moment of
Remembrance Act to make the Commission an independent entity within VA.
Retaining the Act's provisions regarding the Commission's duties and
powers but placing the Commission within VA would require VA to assume
responsibility for the Commission's administrative functions. These
would include maintaining the Commission's accounting records,
processing the Commission's transactions, and performing personnel and
payroll services. The Commission currently has an interagency agreement
with VA for administrative services, but making the Commission an
entity within VA could streamline this arrangement and make it more
efficient. In addition, the Commission's mission of remembering those
who have served the country is related to that of VA, and the two
organizations could achieve synergy by working together on their
complementary missions.
If Congress chooses not to act upon the matter for congressional
consideration discussed above, we are recommending that the Commission
develop and implement basic financial record keeping and internal
controls; consider hiring accounting or bookkeeping assistance; and
clearly account for its finances separately from those of No Greater
Love. The Commission agreed with our recommendations for executive
action and is taking initial steps to implement some of the
recommendations. However, the Commission expressed concerns regarding
the matter for congressional consideration. We continue to believe that
making the Commission an independent entity within VA presents a viable
and practical alternative for resolving the Commission's internal
control and financial reporting weaknesses described in this report.
Objective, Scope, and Methodology:
Our objective was to audit the Commission's financial transactions
(donations and expenditures) recorded during fiscal years 2003 and 2002
for proper supporting documentation and management approval. Because
the Commission did not maintain complete accounting records, we were
unable to perform an audit. Instead, our work was limited to a review
of those transactions recorded for the Commission by VA and GSA.
Therefore there is a risk that there could be unrecorded transactions
for services that the Commission purchased but for which it did not
forward invoices to VA or GSA for payment. When possible, we traced the
recorded transactions to supporting documentation, including
contracts, invoices, credit card statements, and travel vouchers.
However, because the Commission lacked supporting documentation for a
significant portion of its transactions, we were unable to perform an
audit of the Commission's transactions.
We obtained an understanding of the accounting procedures and related
internal controls of the Commission and the financial accounting and
other services provided by VA and GSA.
We performed our work in Washington, D.C., from November 2003 through
March 2004 in accordance with U.S. generally accepted government
auditing standards. We requested comments on a draft of this report
from the White House Liaison and Executive Director of the White House
Commission on the National Moment of Remembrance and from the Secretary
of Veterans Affairs. We received written responses from both the
Commission and VA. Those comments are addressed in a later section of
this report and included in enclosures I and II, respectively.
Background:
Section 6 of the Act[Footnote 3] states that the Commission's duties
are to:
(1) encourage the people of the United States to give something back to
their country, which provides them so much freedom and opportunity;
(2) encourage national, state, local, and tribal participation by
individuals and entities in commemoration of Memorial Day and the
National Moment of Remembrance, including participation by:
a) national humanitarian and patriotic organizations,
b) elementary, secondary, and higher education institutions,
c) veterans' societies and civic, patriotic, educational, sporting,
artistic, cultural, and historical organizations,
d) federal departments and agencies, and:
e) museums, including cultural and historical museums; and:
(3) provide national coordination for commemorations in the United
States of Memorial Day and the National Moment of Remembrance.
In fiscal year 2003, Congress appropriated $250,000 directly to the
Commission.[Footnote 4] In fiscal year 2002, Congress provided that
$500,000 of a larger appropriation was available for the
Commission.[Footnote 5]
We met with the Commission's Executive Director and staff on several
occasions late in 2002 to gain an understanding of the financial
records and internal control environment. We held discussions with the
Executive Director on key accounting issues and internal controls that
should be established in order to achieve accountability over
operations and to facilitate future audits. In January 2003, we issued
a letter to the Commission stating that the fiscal year 2002 audit
would be delayed until the end of fiscal year 2003, so that the
Commission could get its financial records in order.
Although administrative support services were provided by other
agencies, the Commission's management is responsible for preparing
accurate and reliable financial reports reflecting its activities. The
Commission is also responsible for establishing, maintaining, and
assessing internal control[Footnote 6] to provide reasonable assurance
that internal control objectives are met. The Commission engaged VA in
fiscal year 2003 and GSA in fiscal year 2002 for administrative support
services, including payment of the Commission's bills and personnel and
payroll services. VA processed the Commission's obligations,
expenditures, and cash donation transactions recorded during fiscal
year 2003. GSA processed the Commission's obligation and expenditure
transactions during fiscal year 2002. The Commission entered into
interagency agreements with both VA and GSA for their services. The
interagency agreements provided the terms of payment for the services.
When the Commission was funded in 2002, it assumed several of the
program activities of No Greater Love, a nonprofit established in 1971,
and the founder of No Greater Love was appointed as the Commission's
White House Liaison and Executive Director. The founder resigned her
position with No Greater Love in April 2002. According to No Greater
Love's 2002 financial statements, the organization's primary program is
to sponsor programs of friendship for and care of children of
servicemen missing or killed in action, hospitalized veterans,
servicemen overseas, and senior citizens without families.
The Act allows for the Commission's close involvement with other
entities. Section 8(f) of the Act explicitly authorizes the Commission
to enter into cooperative agreements that involve private, as well as
government, entities in assisting the Commission to carry out its
duties. The Act further authorizes the Commission to accept program
support from nonprofit organizations.[Footnote 7] While the Commission
may accept assistance and support from other entities, and in so doing
engage in jointly funded activities, the Act does not provide for the
Commission to use its appropriations for anything other than carrying
out its statutory duties.
The Act also provides that the Commission will receive six employees--
one each from the Army, Air Force, Navy, Marines, VA, and Department of
Education--detailed to assist the Commission in carrying out the Act.
During fiscal years 2003 and 2002, the assignment and service of the
details was inconsistent. The Commission never had more than two
detailees at one time except for 30 working days in 2002 and 2003, and
most of the staff detailed from the other agencies did not complete
their full terms.
Commission Financial Records Were Incomplete and Lacked Supporting
Documentation:
We found that the Commission's financial records for fiscal years 2003
and 2002 were incomplete. The Commission also lacked basic
documentation for its expenditures. As a result, it does not have
reasonable assurance that its financial records are accurate or that
its funds are being spent as intended. (See table 1.):
Table 1: White House Commission on National Moment of Remembrance
Schedule of Management and Documentation Support for Fiscal Years 2003
and 2002 Expenditures (Unaudited):
[See PDF for image]
Sources: VA, GSA, and the White House Commission on National Moment of
Remembrance.
[A] For fiscal year 2003, VA records showed salary and benefits of
$164,366, and for fiscal year 2002, GSA records showed salary and
benefits of $111,953; however, the Commission did not maintain support
for salary and benefits.
[B] For fiscal year 2003, the program and administration amount
presented is from VA records of amounts processed, which showed $7,105
more than the recorded expenditures in the Commission's database. For
fiscal year 2002, the amount presented is from GSA records of amounts
processed, which showed $29,204 more than the recorded expenditures in
the Commission's database.
[C] The Commission's contract with VA to provide payroll and accounting
services for fiscal year 2003 totaled $34,237; however, the Commission
did not maintain support for the actual amounts paid.
[D] The Commission's contract with GSA to provide payroll and
accounting services for fiscal year 2002 totaled $46,513; however, the
Commission did not maintain support for the actual amounts paid.
[End of table]
Fiscal Year 2003:
In fiscal year 2003, the Commission received an appropriation of
$250,000. According to VA, the Commission also received cash donations
of $5,140 during fiscal year 2003. According to the Commission, it also
received various in-kind donations--such as calendars, phone service,
and Web site design and hosting at a value estimated by the Commission
as approximately $43,149 during fiscal year 2003. Office space was also
donated, but the Commission did not provide an estimated value. The
Commission did not record the cash donations or completely record in-
kind donations received in fiscal year 2003.
We also found that the Commission did not reconcile its recorded
expenditures to those processed by VA on behalf of the Commission. As a
result, the Commission lacks assurance that its recorded expenditures
are complete and accurate. Of the Commission's $276,965 expenditures
processed by VA for fiscal year 2003, $164,366 was for the White House
Liaison and Executive Director's salary and benefits. Of the remaining
$112,599 recorded by the Commission as spent on programs and
administration for fiscal year 2003, $61,320 was supported by
documentation and $51,279 lacked supporting documentation. Of the
$61,320 in supported transactions, $13,075 did not have documentation
indicating approval by management. (See table 1.) During our review, we
noted expenditure transactions that were recorded more than once in the
Commission's financial records and transactions that were not recorded
at all.
Fiscal Year 2002:
In fiscal year 2002, the Commission similarly lacked basic supporting
documentation and reconciliation procedures for its expenditure
transactions. For fiscal year 2002, the Commission received an
appropriation of $500,000. Because the funding was provided in January
2002, the Commission was operational for approximately 9 months of the
fiscal year (January 10, 2002, through September 30, 2002). According
to the Commission, it received no cash donations for fiscal year 2002
but did receive various in-kind donations--including office supplies,
phone service, and Web site design and hosting at a value estimated by
the Commission as approximately $91,353. The Commission did not record
the in-kind donations received in 2002 in its financial records. Of the
$235,205 in expenditures processed by GSA during fiscal year 2002,
$111,953 was for the White House Liaison and Executive Director's
salary and benefits. Of the remaining $123,252 recorded by the
Commission for programs and administration, $56,284 was supported by
documentation and the remaining $66,968 lacked documentation. Of the
$56,284 in supported transactions, $10,415 did not have documentation
indicating approval by management. (See table 1.):
Fiscal Years 2003 and 2002:
For both fiscal years 2003 and 2002, basic internal controls did not
exist for recording transactions and reconciling recorded transactions
to funds received and expenditures. In addition, the majority of the
Commission's fiscal year 2002 expenditures were not coded by expense
category or obligation number. As a result, VA or GSA had to designate,
without knowledge of the nature of the transactions, what type of
expenditure was being made in each transaction. For both fiscal years
2003 and 2002, we noted that the Commission's financial records were
not reconciled to the VA and GSA records, respectively. Without such
basic internal controls as documentation, management approvals,
complete transaction records, and reconciliation, the Commission does
not have reasonable assurance that its financial information is
complete and accurate, that its funds are being spent as intended, and
that financial and programmatic decisions can be based on complete and
accurate information. Retaining supporting documentation, such as
invoices for goods or services purchased; management approval; and
recording transactions are all basic internal control activities.
Because the financial records and documentation for fiscal years 2003
and 2002 were incomplete, unsupported, and not reconciled, we were not
able to audit the Commission's financial records.
The Commission's difficulties in maintaining its financial records
result, in part, from the lack of staffing and financial expertise. The
only full-time employee is the White House Liaison and Executive
Director. The Commission has had the assistance of several detailees
from the military service branches and VA, as authorized by
legislation; however, it has never had its full authorized staffing
levels called for in its authorizing legislation, and except for one,
the detailees assigned to the Commission did not serve the full period
to which the military service branch or VA had committed. No Greater
Love has loaned staff to the Commission, but the staff were generally
short term and did not have a financial background.
Commission's Mission, Operations, and Use of Resources Overlap with
Those of a Related Organization:
The Commission lacks accountability for and internal control over its
own transactions, as well as accountability and internal control over
resources and activities it shares with No Greater Love. The Commission
operates in the same location and with a similar purpose as No Greater
Love. Both organizations share personnel and services and have
cosponsored programs. However, the respective costs born by each entity
in sponsoring programs have not been accounted for and documented
clearly.
Even though the Act allows the Commission to be closely involved with
entities in carrying out its duties, because the Commission receives
federal appropriations, there is an increased fiduciary responsibility
for all parties to account for the funds received and activities
conducted. Without the clear accountability of each entity for its own
activities and costs and without transparency in those activities and
costs, donors and Congress are at risk of not knowing which programs
their funds are supporting.
Matter for Congressional Consideration:
Congress may wish to consider amending the National Moment of
Remembrance Act to make the Commission an independent entity within VA.
Retaining the Act's current provisions regarding the Commission's
duties and powers, but placing the Commission within VA, would require
VA to assume responsibility for the Commission's administrative
functions. This would include maintaining the Commission's accounting
records, processing the Commission's transactions, and performing
personnel and payroll services. The Commission currently has an
interagency agreement with VA for administrative services, but making
the Commission an entity within VA could streamline this arrangement
and make it more efficient. In addition, the Commission's mission of
remembering those who have served the country is related to that of VA,
and the two organizations could achieve synergy by working together on
their complementary missions.
Recommendations for Executive Action:
If Congress chooses not to act on the matter for congressional
consideration, then in order to achieve basic accountability for, and
internal control over, its transactions and properly account for
related-party activities, we recommend that the White House Liaison and
Executive Director of the Commission:
consider hiring a bookkeeping service on a part-time basis to help
maintain the Commission's financial records, including producing year-
end summaries and reconciliations;
maintain a complete record or log of Commission financial transactions,
including all appropriations, donations, revenues, obligations, and
expenditures;
develop and implement procedures to properly approve all invoices prior
to payment;
require that all invoices are properly coded to indicate type of
expense on a timely basis;
develop procedures to ensure that all transactions are supported by
appropriate documentation;
reconcile, at least monthly, the Commission's financial records or logs
to the statements showing obligations and expenditures that were
actually processed; and:
develop a clear accountability for expenditures[Footnote 8] related to
the Commission's operations, including transactions with No Greater
Love.
Agency Comments and Our Evaluation:
We received written comments from the Executive Director and White
House Liaison of the Commission and the Secretary of Veterans Affairs.
These comments are reprinted in enclosures I and II, respectively. The
Commission agreed with our recommendations for executive action and is
taking initial steps to implement some of the recommendations. For
example, the Commission is working to finalize procedures for
processing, reviewing, and approving financial transactions and plans
to retain an accountant to perform monthly financial reconciliations.
In addition, the Commission has stated that in order to achieve better
accountability for the two organizations, it will no longer cosponsor
any programs with No Greater Love, and as of the end of June 2004, the
Commission will no longer share office space with No Greater Love.
The Commission did not agree with the matter we raised for
congressional consideration, that the Commission be made an independent
entity within VA. The Commission stated that its mission requires it to
work with numerous departments throughout the government and becoming
an entity within VA might create the appearance of a conflict of
interest. The Commission's Executive Director also believes that making
the Commission an entity within VA would be limiting to the
Commission's unique and specific mission and detrimental to its ability
to meet changing demands and priorities. The Commission also expressed
concern that the matter for congressional consideration does not ensure
that it will receive resources--funds and people--necessary to
accomplish its mission. The Commission also suggested that Congress may
want to consider alternative methods for providing the Commission with
resources and funding.
We agree that there are alternative methods for strengthening the
Commission and providing resources to the Commission. We continue to
believe that the alternative presented in this letter--making the
Commission an independent entity within VA--is a viable and practical
alternative. We believe that the Commission should work with both VA
and its congressional stakeholders to arrive at mutually agreeable
solutions for achieving accountability, streamlined administrative
processes, appropriate staffing levels, and the autonomy needed to
achieve the Commission's mission.
VA deferred to the Commission's views in regards to the matter for
congressional consideration.
We are sending copies of this report to the Chairmen and Ranking
Minority Members of the Senate Committee on Appropriations and the
House Committee on Appropriations; the Chairman of the White House
Commission on the National Moment of Remembrance; the Secretary of
Veterans Affairs; and other interested parties. This report will also
be available on our home page at http://www.gao.gov.
If you or your staff have any questions, please contact me at (202)
512-9471 or by e-mail at franzelj@gao.gov or Julie T. Phillips,
Assistant Director, at (202) 512-5121 or by e-mail at
phillipsjt@gao.gov. Key contributors to this report were Kimberley A.
McGatlin and Kara M. Scott.
Signed by:
Jeanette M. Franzel:
Director:
Financial Management and Assurance:
Enclosures - 2:
Enclosure I: Comments from the White House Commission on the National
Moment of Remembrance:
THE WHITE HOUSE:
COMMISSION ON REMEMBRANCE
Established by the Congress of the United States:
April 15, 2004:
Ms. Jeanette Franzel
Acting Director
Financial Management and Assurance
U.S. General Accounting Office
Washington, DC 20548:
Dear Ms. Franzel:
We appreciate the opportunity to comment on the draft report containing
the results of your review on the financial transactions of the White
House Commission on the National Moment of Remembrance for fiscal years
2002 and 2003.
The Commission generally concurs with GAO's recommendations. We
particularly agree with GAO's recommendation emphasizing that the
Commission must develop and implement "basic financial record keeping
and internal controls consider hiring accounting or bookkeeping
assistance..., " and "a clear accountability for expenditure...
including transactions with No Greater Love ":
The Commission already has taken initial steps to achieve improved
accountability over transactions and accounts for related-party
activities. Besides working to finalize policies and procedures for
processing, reviewing and approving transactions, the Commission will
retain an accountant to perform monthly financial reconciliations. In
addition, as of the end of June 2004, the White House Commission will
not share the same office space as No Greater Love. Finally, while some
No Greater Love staff will continue to donate time to support the
Commission, No Greater Love will not co-sponsor any Commission
programs.
We remain concerned that the matters identified for Congressional
consideration are not adequate to ensure that the Commission receives
the resources necessary to accomplish the mission outlined by the
United States Congress. As noted in the report, the Commission's
authorizing legislation specifies that six personnel, above the
military rank of 03 or civilian grade GS-12, be detailed "to assist the
Commission in carrying out this act." Nevertheless, the Commission has
never been able to operate with a full authorization of staff. In fact,
since its inception, the Commission has only had 1 of 6 detailees
present full time. Despite repeated requests for detailees, the support
envisioned by Congress has not been forthcoming.
For this reason, we feel the United States Congress may want to
consider alternative methods for detailing resources or funding
alternatives. For example, the Commission's authorizing legislation
could be amended to provide that each military service branch, the
Department of Veterans Affairs and Department of Education shall each
detail a commissioned officer/employee, or may provide the Commission
with an annual transfer of funds equivalent to salaries and benefits of
a detail ee. This would enable the Commission to be in a position to
obtain full-time, committed personnel to accomplish its mission.
Finally, the Commission does not agree with the recommendation that:
"Congress may wish to consider amending the National Moment of
Remembrance Act to make the Commission an independent entity within VA
... placing the Commission as an entity within VA could... make it more
efficient. " Public Law 106-579, establishes the Commission to be
independent and requires it to work with numerous departments
throughout the government, including, but not limited to, the
Department of Defense, Department of Interior, Department of Education,
and Department of Transportation. One of the primary reasons the
Commission was established involves the over-arching nature of its
mission and the fact that Memorial Day is not the responsibility of any
single agency. Because of that fragmentation and due to the many other
constituencies that other federal agencies serve, national polls have
repeatedly demonstrated that focused efforts are necessary to enhance
the Nation's understanding and commemoration of those who fought and
died for our freedom. Accordingly, there could appear to be a conflict
of interest if the Commission becomes an entity within the Department
of Veterans Affairs, as it could be conceived as both limiting to our
unique and specific mission, and detrimental to our ability to meet
changing demands and priorities.
We would also like to note that the White House Commission on the
National Moment of Remembrance is not the only Commission that has been
established for similar reasons. For example, independent commissions
have been established to guide and commemorate such important national
events as the celebration of the discovery of North America, the
development of important memorials, including the WWII Memorial, and
the investigation of national disasters. Many, if not most, of these
events could have been placed within existing federal agencies.
However, as Congress did with the White House Commission on the
National Moment of Remembrance, it chose to ensure that these
activities were protected from special interests in favor of the
broader concerns of all Americans.
Sincerely,
Signed by:
Carmella LaSpada:
Executive Director and White House Liaison:
[End of section]
Enclosure II: Comments from the Department of Veterans Affairs:
THE SECRETARY OF VETERANS AFFAIRS
WASHINGTON:
April 15, 2004:
Ms. Jeanette Franzel
Director:
Financial Management and Assurance Team
U. S. General Accounting Office:
441 G Street, NW
Washington, DC 20548:
Dear Ms. Franzel:
The Department of Veterans Affairs (VA) has reviewed your draft report,
Financial Management: Audit of the White House Commission on the
National Moment of Remembrance for Fiscal Years 2003 and 2002 (GAO-04-
497R) and offers these comments.
VA and the Commission have complementary missions. VA's mission is to
provide benefits and services to veterans. The Commission's mission is
broader in scope, requiring it to work not only with VA, but with
numerous departments throughout the government, including, but not
limited to, the Department of Defense, Department of Interior,
Department of Education, and Department of Transportation. It is VA's
understanding that the White House Commission has serious concerns with
any proposal for a statutory change that could potentially affect its
independence. VA defers to the views of the Commission on this issue.
VA supports the spirit of GAO's recommendations for executive action.
These recommendations, if implemented, would strengthen the
Commission's financial records and improve its internal controls.
Regarding the suggestion that Congress consider making the Commission
an "independent entity within VA," the expression of any official
departmental views would require prior coordination within the
Executive branch.
VA appreciates the opportunity to review your draft report.
Sincerely yours,
Signed by:
Anthony J. Principi:
[End of section]
(194381):
FOOTNOTES
[1] Pub. L. No. 106-579, 114 Stat. 3078 (2000).
[2] The activities assumed are "remembrance programs," which have as
their purpose promoting remembrance of those who have died for our
country, those who have served our country, and those who continue to
serve our country.
[3] 114 Stat. at 3080.
[4] Pub. L. No. 108-7, 117 Stat. 11, 460 (2003).
[5] Pub. L. No. 107-117, Stat. 2230, 2299 (2002).
[6] According to our Standards for Internal Control in the Federal
Government, management's internal control responsibility encompasses
controls related to (1) the effectiveness and efficiency of operations,
including the use of resources; (2) the reliability of financial
reporting, including internal and external reports on the use of
resources and financial statements; and (3) compliance with applicable
laws and regulations. Within each of these categories, management is
responsible for establishing controls to prevent or promptly detect
unauthorized acquisition, use, or disposition of assets. See U.S.
General Accounting Office, Standards for Internal Control in the
Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November
1999).
[7] Pub. L. No. 106-579, 114 Stat. at 3084.
[8] Expenditures related to office space, personnel, office equipment,
and joint remembrance projects.
