keeping stateNASACT fiscal officials informed news Volume 32, Number 12 December 2013 NASACT 2013: Year-End Review of Major Initiatives ASACT has focused on a number of major initiatives NASACT responded to the proposed reforms at the end of Nof importance to members in 2013. Each of these topics May 2013. While comments were generally supportive, several has been covered in past newsletters, business and committee state audit offi ces thought the threshold could have been raised meetings, and email updates this year. higher and reiterated the need for the compliance supplement to be issued earlier. OMB has stated that the fi nal notice will be Continuing Disclosure released before the end of the year. An area of concern and focus for NASACT members for many years, continuing interim disclosure became a top priority SF-SAC Change and New Clearinghouse Data Entry System in 2013. Last January, a task force was formed to examine OMB has also proposed changes to Form SF-SAC, or the continuing disclosure in the municipal market. The main goal of “Data Collection Form,” for the 2013 audit year. The Data the task force was to develop a list of recommendations on how Collection Form is an important required part of an audit and what kinds of information could be made available to current submission under OMB Circular A-133, Audits of States, Local and future municipal bond investors on an interim basis. Governments, and Non-Profi t Organizations. Additionally, In August, the task force’s work culminated in the release of the Federal Audit Clearinghouse has launched a new website “Voluntary Interim Financial Reporting: Best Practices for for the collection of Circular A-133 audits which will affect State Governments.” This document outlined ten best practices how both auditors and entity management submit data to the intended to augment states’ existing disclosure programs. The clearinghouse. document was endorsed by the National Federation of Municipal NASACT conducted a webinar discussing the changes on Analysts and received a favorable reception from Securities and November 21. A recording is available for purchase in the Exchange Commission staff at a meeting in September. bookstore at www.nasact.org/bookstore/index.cfm. The document can be found at www.nasact.org/nasact/ publications/papers/best_practices_document.pdf. An GASB Agenda-Setting Process implementation task force is being formed and will be working in In February, the Financial Accounting Foundation released the coming year to implement the recommended best practices. a proposal outlining changes to the agenda-setting process of the Governmental Accounting Standards Board. The proposed Grant Reform Initiatives changes were the result of an academic study commissioned by In February the U.S. Offi ce of Management and Budget the FAF in 2012. This proposal gave FAF trustees fi nal authority released a proposal to reform grant policies. The proposal covered to determine whether projects would fall under the GASB’s three areas: administrative requirements, cost principles and the agenda-setting mandate, which was a signifi cant change from single audit process. The proposal was a follow up to previously past practice. NASACT responded to the proposal with several circulated ideas and a request for comment distributed in the concerns and expressed the desire that if the FAF moved forward spring of 2012 that resulted from a series of work groups covering with the proposal that the three government trustees on the FAF improper payments, single audit and cost circulars. Several board play a more prominent role in making decisions about NASACT members participated in the OMB work groups whose recommendations served as the impetus for the 2012 draft. (continued, next page) NASACT Members: Provide Your Input! NASACT will soon be issuing several surveys to gather input from members: • Membership Satisfaction Survey: Will be distributed in mid-January. • NASACT Annual Conference Topics Survey: Will be distributed in mid-January. • Washington Issues Survey: Will be distributed in mid-February. NASACT News December 2013 page 1 Association Notes (continued from previous page) agenda items for the GASB. wide reporting for all grants and contracts. While a pilot to assess Subsequently, the FAF issued a revised proposal that would the costs and burdens of Recovery Act type reporting on all maintain the GASB’s independence by changing involvement by grants and contracts was a welcome change from the 2011 House the FAF trustees from the agenda-setting process to a pre-agenda version, the new language seems to sidestep normal due process, consultation. NASACT responded to the revised proposal on giving OMB wide latitude to impose government-wide reporting. September 30 with general approval of the approach. In November, the Senate Homeland Security and Government In November, the FAF adopted a fi nal policy which became Affairs Committee passed an amended version which does not effective immediately. The fi nal policy revised the original include the unwelcome House language. proposal so that the GASB will consult with the Standard- Setting Process Oversight Committee in the pre-agenda phase. Money Market Fund Proposal The policy also clarifi ed that the trustees’ authority lies in their This summer, the SEC proposed rules aimed at reforming the oversight responsibility and their authority to determine whether operation of money market funds to avoid the types of runs information constitutes “fi nancial accounting and reporting that occurred at the height of the fi nancial crisis in 2008. The information.” It also reiterates that the trustees will have no proposals offer two alternative reforms that could be adopted involvement in setting the GASB’s agenda or otherwise being together or alone. One would require a fl oating net asset value involved in the GASB’s independent standard-setting process. (NAV) for prime institutional money market funds. The second alternative would use liquidity fees and redemption gates during DATA Act times of stress. The Digital Accountability and Transparency Act, also known NASACT and other market groups continue to oppose as the DATA Act, was introduced in both the House and Senate moving from a fi xed to a fl oating NAV, stating concerns over in May. The DATA Act would essentially continue the oversight the effect of such a move on local government investment established by the Recovery Accountability and Transparency pools. NASACT responded to the proposed rules in September Board and would require quarterly reporting of expenditure data in a letter that can be found at www.nasact.org/downloads/CRC/ for all grants and contracts. LOC/09_13_SEC_MMF_Final.pdf. A fi nal rule is expected in The bill passed the House Committee on Oversight and the fi rst quarter of 2014. Government Reform. The substitute language that was offered and accepted was not part of the original version introduced More Information on May 21. The new language would allow the U.S. Offi ce of For more information about NASACT’s activities in 2013, Management and Budget, at the conclusion of the recipient view past issues of NASACT News at www.nasact.org or call reporting pilot, to ask the Recovery Board to initiate government- (859) 276-1147 or (202) 624-5451. New Members in 2013 State Comptrollers • Karen Benincasa, State Comptroller, New Hampshire State Auditors (replacing Ed Carter, effective April 2013) • Pola Buckley, State Auditor, Maine (replacing Neria • Suzanne Crouch, State Auditor, Indiana (replacing Douglass, effective January 2013) Dwayne Sawyer, effective January 2, 2014) • Eugene DePasquale, Auditor General, Pennsylvania, • Julie Feldman, State Accounting Administrator, Montana (replacing Jack Wagner, effective January 2013) (replacing Paul Christofferson, effective January 2013) • John Dougall, State Auditor, Utah (replacing Auston • DeAnn Hill, Chief Financial Offi cer, Kansas (replacing Johnson, effective January 2013) Martin Eckhardt, effective August 2013) • Doug Hoffner, State Auditor, Vermont (replacing Tom • Robert Jaros, State Controller, Colorado (replacing Salmon, effective January 2013) David McDermott, effective May 2013) • Paul Joyce, State Examiner, Indiana (replacing Bruce • David Schumacher, Director, Offi ce of Financial Hartman, effective November 2013) Management, Washington (replacing Marty Brown, • Troy Kelly, State Auditor, Washington (replacing Brian effective February 2013) Sonntag, effective January 2013) State Treasurers • Martha Mavredes, Auditor of Public Accounts, (replacing Walt Kucharski, effective February 2013) • Charles Robinson, State Treasurer, Arkansas • Mary Mosiman, State Auditor, Iowa (replacing David (replacing Martha Shoffner, effective May 2013) Vaudt, effective May 2013) • Sheila Hogan, Director, Department of Administration, • Jan Yamane, State Auditor, Hawaii (replacing Marion Montana (replacing Janet Kelly, effective January 2013) Higa, effective January 2013) Find information for all NASACT members in the online directory at www.nasact.org/nasact/directory/index.cfm. NASACT News December 2013 page 2 News From Washington MA Deputy Comptroller Testifies the effort that has gone into simplifying the reporting to the extent possible. Ms. Sheppard then explained some of the cost Before the IRS on ACA Provisions implications inherent in the new reporting, including signifi cant start-up implementation and system costs for modifi cations athy Sheppard, deputy comptroller of Massachusetts, as well as supporting vendor contracts, possible carrier