OMB Circular A-123, Appendix A. Adam Goldberg Office of Federal Financial Management Office of Management and Budget. “Corporation: An ingenious device for obtaining profit without individual responsibility.” Ambrose Bierce.
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OMB Circular A-123, Appendix A Adam Goldberg Office of Federal Financial Management Office of Management and Budget
“Corporation: An ingenious device for obtaining profit without individual responsibility.” Ambrose Bierce
“As a small businessperson, you have no greater leverage than the truth.” John Greenleaf Whittier
Legislative History • 1933-1935 SEC Act ’33 / ’34, Public Utilities Act ’35 • 1977 Foreign Corrupt Practices Act • 1982 FMFIA (Circular A-123) • 1990 CFO Act • 2002 Sarbanes Oxley • 2004 Circular A-123, Appendix A
Circular A-123 • A-123 was revised in December 2004 to incorporate Sarbanes-Oxley Section 404 principles into federal financial management. • Revision deals primarily with internal controls over financial reporting. • Revised A-123 effective FY2006.
Revised Guidance Management Assurance Self Assessment Enhanced Documentation Annual Reporting New Appendix A Testing for Reasonable Assurance Additional Assurance for Internal Control over Financial Reporting Original Guidance Management Assurance Self Assessment Documentation Annual Reporting OMB Circular No. A-123
Similarities (Sarbanes-Oxley/A-123) • Focus is on internal controls • Purpose is for reliable financial reporting and effective, efficient operations • Responsibility falls primarily on management
Differences (Sarbanes Oxley/A-123) • Criminal penalties • Separate audit of internal controls over financial reporting
Differences in Implementation:Federal vs. Private • All transactions in the federal government must have legal authority (prescribed by law). • Goals and motivations of federal agencies differ from their private sector counterparts. • Federal Agencies already subject to a web of laws to promote prudence and accountability (before Sarbanes-Oxley or A-123 revision)
A-123 GPRA FMFIA Clinger-Cohen Act GAO Green Book CFO Act IG Act FISMA FFMIA IPIA Single Audit Act Puzzle Pieces of Federal Internal Control Framework