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Financial PolicyVolume IGeneral AccountingChapter 4Compliance with FFMIAApproved:Digitally signed byJon J.Jon J. RychalskiRychalski 1367389Date: 2021.04.261367389 10:37:57 -04'00'Jon J. RychalskiAssistant Secretary for Managementand Chief Financial Officer

Department of Veterans AffairsCompliance with FFMIAApril 2021Volume I – Chapter 40401 Overview . 20402 Revisions . 20403 Definitions . 40404 Roles and Responsibilities . 40405 Policies . 5040501 General Policies . 5040502 Compliance with Federal Financial Management SystemRequirements . 6040503 Compliance with Federal Accounting Standards. 7040504 Compliance with the Application of the USSGL at the TransactionLevel . 7040505 Annual Certification, Audit and Remediation . 8040506 Improving Financial Management Systems . 80406 Authorities and References . 100407 Rescissions . 110408 Questions . 11Appendix A: History of Revisions to this Chapter . 121

Department of Veterans AffairsCompliance with FFMIAApril 2021Volume I – Chapter 40401 OverviewThis chapter establishes the Department of Veterans Affairs’ (VA) financial policies forcompliance with the Federal Financial Management Improvement Act (FFMIA) of 1996.FFMIA and Office of Management and Budget (OMB) Circular No. A-123 Appendix Drequire Federal organizations covered by the Chief Financial Officers Act to implementfinancial management systems that substantially comply with three essentialrequirements: (1) federal financial management systems requirements as defined by theDepartment of the Treasury (Treasury), (2) Federal accounting standards as defined bythe Federal Accounting Standards Advisory Board (FASAB), and (3) utilization of theUnited States General Ledger at the transactional level. Compliance with FFMIAensures taxpayers and Federal managers receive access to accurate, reliable, andtimely financial information.Key points covered in this chapter: Annually, VA CFO and VA’s external auditor will independently assess and reportwhether financial management systems comply with FFMIA’s Section 803(a)requirements; When a system is found to be non-compliant, remediation plans must be developedand executed to bring those systems into substantial compliance; When acquiring, implementing and maintaining components of a financialmanagement system VA will adhere to policies prescribed by OMB Circular No. A130, Treasury Financial Manual (TFM) Volume I Part 6 Chapter 9500 and otherassociated financial management system guidance; and VA will leverage shared service solutions from Quality Services Management Offices(QSMOs) and other partners, when possible, for future modernization of financial ormixed systems.0402 atted to newpolicy format andcompleted five-yearupdateAdd reference to OMBCircular No. A-123Appendix D2Reason forChangeEffectiveDateOFP(047G)Reorganizedchapter layoutApril 2021OFP(047G)Rescission of OMBCircular No. A-127April 2021

Department of Veterans AffairsCompliance with FFMIASection040104040405Appendix AAppendix BApril 2021Volume I – Chapter 4RevisionRevised overview tofocus on compliancewith FFMIA and reflectreduction in targetedguidance from OMBconcerning financialmanagement systemsAdded annualassurance oncompliance with FFMIAto VA CFOresponsibilitiesAdded FFMIAresponsibilities forCFOC, OBO and OITQPR OfficeRealigned chapter tofollow current guidancefrom OMB CircularNos. A-123 and A-130as well as TFM Volume1 Part 6 Chapter 9500Updated policy onshared services toincorporate informationon QSMOsRemoved Appendix A,AccountingTransactions RequestReview ProcessOfficeReason forChangeEffectiveDateOFP(047G)Revision to OMBCircular No. A-123and rescission ofOMB Circular No.A-127April 2021OFP(047G)Updated guidanceand proceduresApril 2021OFP(047G)Revision to OMBCircular No. A-123and rescission ofOMB Circular No.A-127April 2021Rescission of OMBM-13-08 and M-1611 and issuance ofM-19-16Moved to VolumeII, Chapter 1OFP(047G)Move previous policyrevisions to anappendixRemoved Appendix B,General LedgerRequest ProcessOFP(047G)3April 2021Improve readabilityMoved to VolumeII, Chapter 1April 2021

Department of Veterans AffairsCompliance with FFMIAApril 2021Volume I – Chapter 40403 DefinitionsFinancial Management System – An agency’s overall financial operation, reflectingthe people, processes and technology used to capture, classify, summarize and reportdata in a meaningful way to support business decisions. It includes hardware andsystems software, personnel, procedures, data and reporting functions. The financialmanagement system can be fully integrated with other management informationsystems (i.e., mixed systems) where transactions automatically flow from one system toanother or non-integrated, requiring manual processes used to post transactions fromother management systems into the accounting system.Financial System – An information system or set of applications that comprise theaccounting portion of the financial management system. The system encompassesprocesses and transactions that: Maintain a record of budgetary and proprietary financial activity; Identify and record valid transactions; and Provide sufficient detail to permit proper recordation and classification oftransactions for financial reporting.Information System – The organized collection, processing, recordation, transmissionand dissemination of information in accordance with defined procedures, whetherautomated or manual. Information systems include non-financial, financial and mixedsystems.Mixed System – A system that is a hybrid of financial and non-financial portions of theoverall financial management system. Examples include: payment and invoice systems,procurement systems, receivable systems, loan systems, grants systems, payrollsystems, budget formulation systems, billing systems, property management systems,travel system, or other mission operational systems that impact a financial system.Non-financial System – A system that supports non-financial functions of the Federalgovernment or components thereof. A system that does not process data required forrecording, transmitting or reporting financial data.Shared Service Providers – Federal agencies or divisions within an agency providingservices to another agency or division.Quality Service Management Offices (QSMOs) – Shared service providers formallydesignated by OMB as governmentwide storefronts, offering multiple solutions fortechnology and services in their respective functional area (e.g. Core FinancialManagement, Grants Management, Cybersecurity Services, and CompensationManagement).0404 Roles and Responsibilities4

Department of Veterans AffairsCompliance with FFMIAApril 2021Volume I – Chapter 4Assistant Secretary for Management/Chief Financial Officer (VA CFO) isresponsible for the development, maintenance of VA’s financial management systemsin accordance with OMB Circular Nos. A-123 and A-130, as well as issuing assurance,annually that systems substantially comply with the requirements of FFMIA andassociated guidance.Chief Financial Officer Council (CFOC) is responsible for reviewing and providingrecommendations to the VA CFO with respect to approving VA’s financial policies andadvising VA CFO on issues surrounding compliance with FFMIA.Office of Business Oversight (OBO) is responsible for managing and implementingVA’s program for management’s assessment and reporting on the effectiveness of VA’sinternal controls in accordance with OMB Circular A-123 and Federal Managers’Financial Integrity Act (FMFIA) of 1982.Office of Information and Technology’s (OIT) Quality, Performance and Risk(QPR) Office oversees all aspects of quality and compliance within OIT, includingassessing for compliance with FFMIA.0405 Policies040501 General PoliciesA. VA will establish and maintain financial management systems that comply with: Generally accepted accounting principles (GAAP), standards and relatedrequirements as defined by FASAB, OMB and Treasury. Internal control standards as defined in OMB Circular No. A-123 and itsappendices. Information resources management policy as defined in OMB Circular No. A-130and any successor documents. Operational policies and related requirements as prescribed by OMB, Treasuryand VA.B. VA will ensure financial management systems substantially comply with the FederalFinancial Management Improvement Act (FFMIA) of 1996, including the threefundamental requirements in Section 803(a), compliance with: Federal FinancialManagement System Requirements; Federal Accounting Standards; and the U.S.Government Standard General Ledger (USSGL) at the Transaction Level.C. VA’s financial management systems will support financial and program managers’accountability for financial results, control over VA’s financial resources, andprotection of VA assets.5

Department of Veterans AffairsCompliance with FFMIAApril 2021Volume I – Chapter 4D. VA’s financial management systems will be in place to process and record financialevents effectively and efficiently, and to provide complete, timely, consistent, andreliable financial information for decision making, reports, and financial statements.E. VA’s financial management systems will support standardized information andelectronic data exchange to meet the requirements of sound financial management.F. VA’s financial management systems will provide reliable and useful financialinformation on VA operations to enable VA to carry out its fiduciary responsibilities;to deter fraud, waste and abuse of VA resources; and to facilitate efficient andeffective delivery of services by linking financial results to program performance.G. When modifying or replacing components of a financial system, VA will adhere to therequirements in OMB Circular No. A-130 by performing a systematic assessment ofneeds and implement cost-effective and efficient solutions.040502 Compliance with Federal Financial Management System RequirementsA. VA’s financial management systems will comply with Treasury Financial Manual(TFM) Volume I Part 6 Chapter 9500, Revised Federal Financial ManagementSystem Requirements for Fiscal Reporting.B. VA’s financial management systems will provide information in a reliable, timely andaccurate fashion to manage day-to-day operations and comply with internal andexternal reporting requirements, including, as necessary, the requirements forfinancial statements, prepared in accordance with the form and content prescribedby OMB and reporting requirements prescribed by Treasury. Reliable financialreporting includes maintaining internal control over financial reporting and financialsystem security.C. VA’s financial management system shall include a system of internal controls thatare appropriately applied to all VA system inputs, processing and outputs. Suchsystem-related controls form a portion of the management control structure requiredby OMB Circular No. A-123, including its appendices.D. VA’s design of its financial management systems will provide for effective andefficient interrelationships between software, hardware, personnel, procedures,controls and data comprising it. This includes designing systems which eliminateunnecessary duplication of transaction entry. Wherever appropriate, data needed bythe systems to support financial functions shall be entered only once and other partsof the systems shall be updated through electronic means consistent with the timingrequirements of normal business transaction cycles.6

Department of Veterans AffairsCompliance with FFMIAApril 2021Volume I – Chapter 4E. VA will use common processes for processing similar kinds of transactionsthroughout the systems to enable these transactions to be reported in a consistentmanner.F. VA’s financial management systems will ensure resources are safeguarded againstwaste, loss and misuse.G. VA’s financial management systems shall conform to existing applicable functionalrequirements for the design, development, operation and maintenance of financialmanagement systems. Functional requirements are defined in TFM Volume I Part 6Chapter 9500. Compliance objectives should ensure that financial transactions areconsistent with relevant laws, regulations and policies.H. VA will plan for and incorporate security controls in accordance with the FederalInformation Security Management Act (FISMA) of 2002, FISMA of 2014 and CircularNo. A-130 for financial management systems to ensure the adequacy andeffectiveness of information security controls.I. VA will implement new functional requirements as they are established and whenthey become effective. Additional function requirements may be established throughOMB circulars or bulletins and/or published in the TFM.040503 Compliance with Federal Accounting StandardsA. VA’s financial management systems shall maintain accounting data to permitreporting in accordance with Generally Accepted Accounting Principles (GAAP).B. VA’s financial management systems shall maintain data in a format that supports thepreparation and presentation of financial and managerial reports in accordance withapplicable standards.C. VA’s financial management systems shall be designed with flexibility to adapt tochanges in accounting standards.040504 Compliance with the Application of the USSGL at the Transaction LevelA. The recording of financial events in any component of a financial managementsystem (e.g., timing, processing rules/conditions) shall be consistent with accountingtransaction definitions and processing rules defined in the USSGL.B. Transaction detail supporting USSGL accounts shall be available in the financialmanagement systems and directly traceable to specific USSGL account codes.7

Department of Veterans AffairsCompliance with FFMIAApril 2021Volume I – Chapter 4C. Reports produced by the financial management systems, whether used internally orexternally, will provide financial data that can be traced directly to data residing inthe USSGL accounts.040505 Annual Certification, Audit and RemediationA. In accordance with OMB Circular No. A-123 Appendix D, VA will annually providemanagement assurances related to its financial management systems’ compliancewith FFMIA in the Analysis of Systems, Controls and Legal Compliance section of itsAgency Financial Report (AFR).B. VA will utilize the FFMIA Compliance Determination Framework included asAttachment 1 to OMB Circular A-123 Appendix D as its template to rate its risk (orperformance) level.C. Each audit required by 31 U.S.C. § 3521(e) will disclose whether VA’s financialmanagement systems are in compliance with FFMIA Section 803(a).D. VA will ensure each partner shared service organization (SSO) provides VA with aReport on Controls at a Service Organization Relevant to User Entities’ InternalControl over Financial Reporting (also known as a SOC 1) for consideration in theannual certification and applicable audits.E. When deficiencies are identified by VA, or an auditor, VA will establish a remediationplan identifying resources, remedies and target dates to bring the financialmanagement system into compliance.040506 Improving Financial Management SystemsA. Designs for financial systems and mixed systems shall be based on the financial andprogrammatic information and processing needs of VA. As part of any financialmanagement system design effort, VA must analyze system improvements, newtechnology supporting financial management systems and modifications to workprocesses that can enhance agency operations and improve program and financialmanagement.B. The reassessment of information and processing needs shall be an integral part ofVA’s determination of system requirements. Process redesign shall be consideredan essential step toward meeting user needs in program management, financialmanagement and budgeting. Concurrent with developing and implementingintegrated financial management systems, agencies shall consider programoperations, roles and responsibilities, and policies/practices to identify relatedchanges necessary to facilitate management systems’ operations efficiency andeffectiveness.8

Department of Veterans AffairsCompliance with FFMIAApril 2021Volume I – Chapter 4C. Financial management system development and implementation efforts shall seekcost-effective and efficient solutions, as required by OMB Circular No. A-130. ShouldVA decide to replace software to meet core financial system requirements, it willadhere to the order of preference as listed below:1. Shared Services2. Transferring of Agency Financial Management Software3. Commercial Off-the-Shelf (COTS) Software4. Developing Software Jointly5. Custom SoftwareD. VA will utilize cross-servicing of financial system support whenever feasible andcost-effective, as a solution to meet financial management system needs.E. As required by OMB Memorandum 19-16, Centralized Mission Support Capabilitiesfor the Federal Government, VA’s first consideration for shared services will be fromshared service providers designated as Quality Service Management Offices(QSMOs). A current list designations and other guidance on QSMOs is available onthe GSA Unified Shared Services Management website.F. Private servicing through commercial vendors may be used in the event solutionsavailable from the QSMOs or other SSPs will not meet VA’s need.G. In cases where VA determines that it is more efficient and effective to use or adoptthe software of another agency to meet its financial management systemrequirements, it shall ensure the following: The software meets the three FFMIA Section 803(a) requirements; A formal written agreement on the transfer of software is prepared and approvedby all parties. The agreement shall cover the full scope of support services to beprovided, including system modifications, maintenance and related costs; Any necessary support requirements not covered in the agreement shall beprovided by VA. Such support, including implementation and training, shall beassessed and determined to be adequate; and An ongoing relationship for determining future enhancements shall beestablished between the parties.H. VA will use commercial off-the-shelf (COTS) software meeting system requirementsdiscussed in this chapter unless VA’s evaluation identifies significant deficiencieswhich disqualify it as a cost-effective and efficient solution. A cost-benefit analysisthat includes the explanation of the unique nature of the system’s functions and9

Department of Veterans AffairsCompliance with FFMIAApril 2021Volume I – Chapter 4justifies the non-use of COTS software should be documented and will be madeavailable to OMB for review upon request.I. After considering shared service solutions, the adoption of another agency’ssoftware and COTS solutions,

The objective of financial management systems is to generate complete, reliable, consistent, and timely information, to include standard Federal financial statements and VA-specific reports, and to be responsive to requests regarding VA financial and performance management. The financial management

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