NASA Procedural Requirements

NPR 9220.1B Effective Date: February 09, 2017 Expiration Date: February 09, 2025

Subject: Journal Voucher Preparation and Approval and Intragovernmental Transactions Change 2, (Revalidated September 24, 2020)

Responsible Office: Office of the Chief Financial Officer

Chapter 2. Intragovernmental Transactions

2.1 Overview

2.1.1 This chapter provides the financial management requirements necessary to record, reconcile, and report intragovernmental transactions

2.1.2 In the preparation of the Federal Government-wide financial statements, the U.S. Department of Treasury eliminates intragovernmental transactions. The use of trading partner codes on intragovernmental transactions enables analysis and elimination of Federal activity in the Government-wide financial statements.

2.2 Agency Requirements

2.2.1 The intragovernmental order contains the negotiated agreement between the buyer and seller of goods or services. The order will provide information, as required by the Treasury Financial Manual (TFM) Volume I: Pt. 2, Ch. 4700, Appendix 6 Intragovernmental Transaction (IGT) Guide, to allow the buyer and seller of goods and services to perform business in accordance with the requirements in this chapter. Both the buyer and the seller will designate trading partner codes for each transaction along with the appropriate U.S. Standard General Ledger (USSGL) account and the Federal Attribute, "F." Sellers will track related cost and keep consistent, reliable evidence of performance.

2.2.2 Under an intragovernmental order, NASA will reconcile receivables and payables, advances to and advances from, and revenue and expenses (including capitalized assets) with its trading partners for transactions recorded in the same reporting period. NASA prepares a trading partner agreement in conjunction with its trading partners. Trading partner agreements are required to communicate payment and collection requirements and reconciliation needs. NASA reports intragovernmental transactions using posting models consistent with USSGL guidance and policies. NASA records transactions with the appropriate USSGL account number and trading partner code.

2.2.3 Recording Intragovernmental Transactions. The following information will be included in intragovernmental transactions, along with the other data required by the order:

a. The trading partner code of the Federal agency that is doing business with NASA.

b. The common agreement number (order number).

c. The appropriate Treasury Account Symbol (TAS) for both trading partners. If multiple TAS are included on one order, specify amounts for each TAS.

d. The business event type code (BETC) for both trading partners.

e. The amounts to accrue, advance, collect, or disburse.

2.2.4 Reconciling Intragovernmental Transactions.

2.2.4.1 The integrity of the data reported in NASA's financial records, reports, data reported in NASA's audited financial statements, and the closing package are dependent on timely and accurate reconciliations of intragovernmental activity and resulting account balances. NASA investigates and records necessary adjustments for any discrepancies between its intragovernmental account balances and the reciprocal account balances of their trading partners. NASA corrects known discrepancies in its records prior to the preparation of financial statements and the closing package submission.

2.2.4.2 The Office of Management and Budget (OMB) requires NASA to reconcile/confirm intragovernmental activity and balances quarterly with its trading partners. In order to effectively reconcile with its trading partners, NASA will:

a. Accumulate detail and summary information for each activity, by trading partner, from its accounting records.

b. Reconcile with its trading partners by providing and receiving account balances that summarize transactions with each trading partner. Detailed account activity is available as provided in the trading partner agreement and upon request of the trading partner.

c. Communicate with its trading partners to ensure the proper trading partner code is used.

d. Provide Federal transaction data files, also known as "F" transaction data files, to Treasury's Bureau of Fiscal Services (BFS) and uses the Intragovernmental Transaction (IGT) Module in Governmentwide Treasury Account Symbol Adjusted Trial Balance System (GTAS) to confirm and reconcile fiduciary transactions with its trading partners.

2.2.4.3 When both NASA and its trading partners' accounting records are accurate and current, there may be identifiable differences between the two records. Analyzing and determining the nature of the differences requires NASA to work with its trading partners to exchange detailed information and other accounting records. Types of reconciliation differences are listed and defined in the Department of Treasury, Financial Management Service Federal Intragovernmental Transactions Accounting Policy Guide.

2.2.4.4 Differences identified during the quarterly reconciliation process will be adjusted in the subsequent period for accounting errors and current year timing differences.

2.2.4.5 During the fourth quarter reconciliation process, NASA will make all adjustments before issuing the financial statements. If NASA identifies adjustments after the issuance of the financial statements, NASA will notify Treasury's BFS. BFS will determine the impact of the adjustments to the Government-wide financial statements and advise NASA on the proper treatment.

2.2.4.6 If NASA and its trading partner confirm the amounts reported, when a difference occurs, NASA will contact its trading partner to resolve the difference. Confirmed differences existing in the third quarter of the fiscal year, which are considered material, require that NASA work with its trading partner to develop and submit a plan of action to BFS on resolving the difference.

2.2.4.7 NASA will monitor the age and activity of an agreement and determine the reason for the lack of activity of any interagency obligation or payable balance that is unchanged, showing no activity for more than 180 days. NASA's financial management offices notify their procurement and contracting offices of inactive obligations and payables. Once an agreement is fulfilled, NASA will notify the seller and deobligate the agreement within 30 days. If work continues or is unbilled on an agreement, the agreement remains available for use.

2.2.4.8 NASA will reconcile intradepartmental transactions. NASA investigates and records necessary adjustments for any discrepancies between the intradepartmental account balances and the reciprocal intradepartmental account balances. NASA corrects known discrepancies prior to the preparation of financial statements and the closing package submission.

2.2.5 Resolution of Disputes and Major Differences.

2.2.5.1 The buyer may request that the seller provide documentation supporting a bill. The documentation will be provided within an agreed upon timeframe, not to exceed two weeks. If the bill or performance transaction does not include information required by the Intergovernmental Transaction Guide, the buyer may reject the transaction. NASA may not reject transactions where the bill or performance transaction complies with the IBR. The dispute resolution process will proceed in accordance with the policy below and as provided in the intragovernmental agreement.

2.2.5.2 The intragovernmental agreement includes a clause delineating an alternative dispute resolution process. Dispute resolution will involve the program offices, the accounting offices, the contracting officer, and the CFO.

2.2.5.3 Disputes will be documented in writing with clear reasons for the dispute. NASA will jointly develop a memorandum of agreement with its trading partner, signed by both agencies' CFOs, acknowledging their participation in the dispute resolution process. NASA will not chargeback, reject, or create new transactions for disputed amounts in compliance with the IBR.

2.2.5.4 Differences that remain on fiduciary transactions longer than 25 days after the close of the reporting period will go through dispute resolution. Disputes resulting from differences in accounting treatment or contractual differences require resolution 60 calendar days after the difference is identified in the Material Differences Report or a charge is disputed. If agreement cannot be reached, both types of unresolved differences are referred to the CFO Council's Intragovernmental Dispute Resolution Committee. The Committee shall render a decision within 90 days of receiving the request. NASA will coordinate with its trading partner to record adjusting transactions, as required.

2.2.5.5 The buyer may establish a threshold (in the intragovernmental agreement) not to exceed a certain amount per order before asking for contractual decisions. If the disputed amount is under the threshold and the buyer elects not to pursue a dispute, then the buyer pays the amount.

2.2.6 Reporting Requirements.

2.2.6.1 Performance Report. The performance report assists NASA and its trading partners in the recording of accrued expenses and revenues. It improves the timing and amount of the accrual, which in turn, promotes reconciliation and elimination. The intragovernmental agreement should indicate that the performance report is provided to the program office and the financial management office containing the data and due dates in compliance with the Intergovernmental Transaction Guide. NASA will provide the report to its trading partner, no later than 30 days after the accountable event or before the close of quarterly reporting, whichever occurs first. The report will include the common agreement number(s), the Treasury account symbol, the BETC, the agency location code, amount of accrual (performance amount), contact information, and other information identifying the current expense of services or goods within the reporting period. The interagency agreement delineates the frequency, the method, the points-of-contact, and the content of the required report.

2.2.6.2 Quarterly "F" Data File Submission. In support of the quarterly reconciliation process, reporting agencies are required to submit intragovernmental balances (only transactions with the "F" attribute) for all proprietary USSGL accounts to BFS. The NASA OCFO derives the submitted intragovernmental balances directly from departmental trial balances, used as the basis for constructing quarterly unaudited financial statements for OMB. Agencies will also complete the Agency Quarterly Intragovernmental Data File Submission Checklist. The NASA OCFO shall submit its checklist, with the "F" data file, to its BFS intragovernmental review accountant counterpart.

2.2.6.3 Quarterly Intragovernmental Transactions Submission. The OCFO shall use the IGT Module of GTAS to reconcile and confirm fiduciary balances and activity with central fiduciary agencies on a quarterly basis. The amounts entered into the IGT will be in agreement with NASA's quarterly "F" file submission and the audited financial statements before submission to BFS.

2.2.6.4 Material Differences/Status of Disposition Certification. The NASA OCFO shall explain the material differences with its trading partners in the amounts reported by reciprocal category. The differences are segregated into the following categories: Confirmed Reporting, Accounting Methodology Difference, Accounting/Reporting Error, Timing Difference -- CY, Timing Difference -- PY, or Unknown. Those differences are also explained on the Additional Explanations form provided by BFS. The OCFO shall submit NASA's Material Differences/Status of Disposition Certification and the additional explanations to its BFS intragovernmental review accountant counterpart. The Status of Disposition Certification is not required in the fourth quarter. BFS will use the closing package intragovernmental data (submitted by verifying agencies as part of their closing package) to consolidate agency data for year-end reporting.

2.2.6.5 CFO Representations for Federal Intragovernmental Activity and Balances. At year-end, the OCFO is required to represent that NASA has properly and completely reconciled its intragovernmental activity and balances with its trading partners, using the closing package submission and NASA's audited financial statements. This requirement is outlined in, Treasury Financial Management (TFM), Volume I, pt. 2-4700, (TFM 2-4700), 4705.70b. The representations relate to whether the reconciliation was completed, providing general intragovernmental reporting results, and the explanation of closing package differences.

2.2.6.6 Financial Reporting Requirements, OMB Circular No. A-136, Financial Reporting Requirements (OMB Circular NO. A-136). NASA will comply with this OMB circular that dictates the required elements for all Federal agencies' financial statements, footnotes, required supplementary information, and required stewardship supplementary information. NASA should record and report all transactions in the proper USSGL accounts, as well as report all USSGL accounts in accordance with the financial statement crosswalk(s). NASA reconciles and confirms intragovernmental activity and balances with its trading partners before submitting year-end data to BFS and reporting it in its audited financial statements, ensuring that the reconciled and confirmed balances for intragovernmental transactions agree to its audited financial statements and closing package reporting. NASA prepares Agency-wide consolidated financial statements and elimination entries for intradepartmental transactions.

2.2.6.7 Closing Package For Fiscal Year-End Reporting, TFM 2-4700. Treasury's BFS developed the closing package methodology to resolve material deficiencies identified by the Government Accountability Office (GAO). NASA's OCFO shall reclassify all line items and amounts on its comparative audited, consolidated, departmental level balance sheet, statement of net cost, and statement of changes in net position to the closing package financial statement formats. NASA is required to report footnotes, disclose all other information not contained in the primary financial statements required to meet generally accepted accounting principles, and submit NASA's adjusted trial balances via the GTAS. NASA identifies trading partners in the Federal Trading Partner Note Module for those closing package line items that hold intragovernmental balances. NASA reports the reconciled and agreed-upon confirmed balances quarterly in the IGT Module of GTAS, at year end in the closing package, and in its audited financial statements.

2.2.6.8 Third Quarter Inspector General Agreed-Upon Procedures (IG/AUP) for Intragovernmental Activity and Balances. OMB requires the performance of IG/AUP by agencies where there is evidence and a history of systemic or recurring problems in accounting, reporting, or reconciling intragovernmental balances. The IG/AUP will identify, analyze, and facilitate the correction of the underlying internal control or process weaknesses at those agencies. OMB will contact the applicable agencies and their respective IGs that meet the above criteria. Those agencies, their IGs, and BFS will meet to formulate IG/AUP, agreed to by the applicable parties, and in conformance with American Institute of Certified Public Accountants (AICPA) standards.

2.2.7 Year-End Requirements.

2.2.7.1 At the end of each fiscal year (September 30), all transactions and activity related to the fiscal year should be recorded in each agency's general ledger. Transactions that are incurred as of September 30 and have not been billed should be recorded as accruals in both agencies' records. These transactions may have been billed subsequent to year-end or remain unbilled at the time of accrual. The providing agency should identify these transactions and should work with the receiving agency to provide detailed information supporting the transactions and the amounts incurred as of the cut-off date (September 30) and not yet billed. The providing agency should record these transactions as receivables/revenues as of September 30. The receiving agency should record these transactions as payables/expenses or assets as of September 30. Agencies should work together to calculate and estimate accruals and to record corresponding entries in each set of records so they are in agreement or that long-term accounting policy differences can be easily identified. The providing agency is typically responsible for estimating the accrual and communicating this information to the receiving agency. Both agencies are responsible for recording the information.

2.2.7.2 NASA will not submit a Quarterly "F" Data File for fourth quarter activity. This data is included in the year-end closing package submission. BFS will use the closing package intragovernmental data (submitted by verifying agencies as part of their closing package) to consolidate Agency data for year-end reporting.

2.3 Roles and Responsibilities

2.3.1 The responsibility for recording and reconciling the intragovernmental activity and balances lies with NASA, regardless of its trading partner's involvement in the transactions. The Agency OCFO reconciles individual Agency-level account balances. Each Center is responsible for the reconciliation of individual accounts within its respective business areas. The Agency and Center DCFO shall review and approve the respective reconciliations.

2.3.2 The Agency OCFO shall:

a. Establish and maintain a structure for NASA's intragovernmental transactions that includes recording, reconciling, and reporting procedures.

b. Provide intragovernmental balances (transactions with a Federal ("F") indicator) for all required proprietary USSGL accounts to BFS each quarter to include the fiduciary account balances in IGT.

c. Ensure that the reconciled and confirmed balances for intragovernmental transactions agree with the Agency's audited financial statements and closing package reporting.

d. Submit intragovernmental closing package data by Federal line item to BFS at year-end.

e. Complete the CFO Representations for Federal Intragovernmental Activity and Balances and provide information to BFS and the GAO.

f. Perform CFO requirements for third quarter IG/AUP, if NASA meets the criteria for IG/AUPs.

g. Represent that all intragovernmental balances have been reconciled and that NASA's audited financial statements contain those balances, as instructed by OMB Circular No. A-136.

h. Establish a consistent relationship with NASA's trading partners in order to identify and resolve differences.

i. Document and maintain the data requirements agreed upon by NASA and its trading partners in the Intragovernmental Payment and Collection (IPAC) System and reconciliation process.

j. Provide NASA Centers and/or service providers with reports identifying differences between amounts reported by NASA's trading partners and NASA Centers.

k. Ensure compliance with NASA's policy and procedures over intragovernmental account processes to ensure relevant, reliable, and timely reporting to Treasury.

2.3.3 The Center OCFO and service providers shall:

a. Record trading partner codes on all transactions occurring between Federal entities.

b. Document and support the information recorded in its accounting records related to intragovernmental transactions.

c. Record activity between Federal entities at the transaction level and will not net accounting activity or intragovernmental balances, even if the activity is in the same reciprocal category.

d. Record the common agreement number provided in the intragovernmental agreement on all transactions.

e. Reconcile the intragovernmental data in its accounting records to the supporting documentation based on BFS IGT Reports and reports provided by NASA's OCFO.

f. Monitor and/or maintain customer and vendor master data with regard to the validity of the trading partner code and agency name.

g. Execute Agency policy and procedures over intragovernmental account processes.

h. Monitor the age and activity of an agreement and determine the reason for the lack of activity of any interagency obligation or payable balance that is unchanged, showing no activity for more than 180 days.

DISTRIBUTION:
NODIS

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