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GAO-12-830R 1 (2012-07-26)

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         Accountabiliy - Integrity - Reliability
United States Government Accountability Office
Washington, DC 20548


            July 26, 2012


            The Honorable Max Cleland, Secretary
            American Battle Monuments Commission
            Courthouse Plaza II, Suite 500
            2300 Clarendon Boulevard
            Arlington, Virginia 22201

            Subject: Management Report: Improvements Are Needed to Strengthen the American Battle
                     Monuments Commission's Internal Controls and Accounting Procedures


            Dear Mr. Secretary:


            In March 2012, we issued our report on the results of our audit of the financial statements of
            the American Battle Monuments Commission (the Commission) as of, and for the fiscal
            years ending September 30, 2011 and 2010, and on the effectiveness of its internal control
            over financial reporting as of September 30, 2011.1 We also reported our conclusions on the
            Commission's compliance with provisions of selected laws and regulations.

            Our report concluded that although certain internal controls could be improved, the
            Commission maintained, in all material respects, effective internal control over financial
            reporting as of September 30, 2011. However, we did report a significant deficiency2 in the
            Commission's internal control over its payroll processes for its non-U.S. citizen employees
            (foreign employees).3 The purpose of this report is to present additional information on the
            control issues that we identified during our audit of the Commission's fiscal year 2011
            financial statements that constituted the significant deficiency and to provide our
            recommended actions to address those issues. Also, we identified an additional internal
            control issue that while not considered to be either a material weakness or a significant
            deficiency, nonetheless warrants management's attention. This report provides our
            recommendations to address this internal control issue as well. In addition, we are providing
            an update on the status of recommendations we made to address internal control issues

            1 GAO, Financial Audit. American Battle Monuments Commission's Financial Statements for Fiscal Years 2011
            and 2010, GAO-12-404 (Washington, D.C.: Mar. 1,2012).
            2 A significant deficiency is a deficiency, or a combination of deficiencies, in internal control that is less severe
            than a material weakness, yet important enough to merit the attention of those charged with governance. A
            deficiency in internal control exists when the design or operation of a control does not allow management or
            employees, in the normal course of performing their assigned functions, to prevent, or detect and correct
            misstatements on a timely basis. A material weakness is a deficiency, or combination of deficiencies, in internal
            control such that there is a reasonable possibility that a material misstatement of the entity's financial statements
            will not be prevented, or detected and corrected on a timely basis.
            3 During fiscal year 2011, the Commission used a total of 396 full-time equivalent positions. Of these, 73
            positions were held by U.S. citizens, while the remaining 323 positions were held by non-U.S. citizens employed
            at the Commission's regional offices and at the cemeteries in the countries where the Commission operates.


GAO-12-830R ABMC 2011 Management Report

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