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A01747 1 (2001-08-30)

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Federal Accounting  Standards Advisory  Board


                                                                             Mailstop 6K17V
                                                                      Washington, DC  20548
                                                                              (202) 512-7350
                                                                         FAX  (202) 512-7366



 August 30, 2001

 To: Heads of Agencies, Users, Preparers, and Auditors of
        Federal Financial Information

 The Federal Accounting Standards Advisory Board is requesting comments on the exposure draft
 (ED), Accounting for National Defense PP&E and Associated Cleanup Costs.

 Currently, the acquisition costs for items classified as national defense (ND) property, plant, and
 equipment (PP&E)  are expensed in the period incurred. In addition, valuation (using either a
 historical or latest acquisition cost valuation method), condition, and deferred maintenance
 information for ND PP&E are to be reported off-balance sheet. Also, the total estimated cleanup
 cost for ND PP&E is to be recognized as an expense in the period the asset is placed into service.

 The amendments   proposed in this ED would make the following changes. The definition of ND
 PP&E  would be amended.  ND  PP&E  would consist of 2 separate categories of items within the
 amended  definition: (a) Major End Items and (b) Mission Support Items. Beginning in fiscal year
 (FY) 2002, Major End Items would be subject to a reporting of the number of units and condition
 assessment information by asset type or category. Beginning in FY 2006, Major End Items would
 be capitalized but not depreciated, while Mission Support Items would be capitalized and
 depreciated. Also, beginning in FY 2006, data for the ten largest current acquisition programs
 would be disclosed. In addition, the total estimated cleanup cost per Major End Item would be
 recognized as a part of the acquisition cost as items are placed into service. For Mission Support
 Items, a portion of the total estimated cleanup cost would be recognized as an expense during each
 period that the item is in operation. The amendments proposed in this ED that affect the definition
 of ND PP&E, and unit and condition reporting would take effect in FY 2002. The remaining
 amendments  would take effect in FY2006 or upon implementation of this standard if implemented
 earlier.

 In Appendix D, the Board has posed specific questions for comment. You are encouraged to
 address some or all of these questions and to comment on any section of this document. In
 particular, however, the Board would like to bring to your attention Question 4, which addresses
 provisions for recognition of a periodic cost of ND PP&E, and Question 5, which addresses a
 difference in accounting for the cleanup cost for the two categories of ND PP&E. While most
 FASAB  members  support the standards proposed in this ED, some members believe that there
 should be some form of periodic recognition of the expense of using capital items, and greater
 consistency in accounting for environmental cleanup cost. To ensure full consideration of your
 responses by the Board, please provide your rationale for agreement or disagreement with a
 particular area, including explanations of alternative proposals in areas of disagreement.
 Respondents are encouraged to consider the issues in light of Statement of Federal Financial
Accounting Concepts  1, Objectives of Federal Financial Reporting. Responses are due by
November  29, 2001 and should be sent to:


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