Which groups are charged with developing and monitoring internal control? (select all that apply).

Unlike most private sector organizations, governmental entities must be responsive to a number of different groups and organizations, including elected officials, other units of governments, investors, creditors, and citizens that are focused on monitoring their activities. All forms of monitoring include collecting and interpreting data, and this oversight function is often performed through information provided in governmental reports. Among the most important types of communication is the annual financial report, which presents the financial position, operating results, and cash flows for a particular accounting period. All governments, including school districts, develop their annual financial reports in accordance with principles established by standard-setting authorities to provide consistency and comparability for users.

For governments to achieve the objective of accountability, financial information must be both relevant and reliable for reasonably informed users. Financial reports must satisfy numerous and diverse needs or objectives, including short-term financial position and liquidity, budgetary and legal compliance, and issues having a long-term focus such as capital budgeting and maintenance. Additionally, differences exist in the amount of detail that various users need.

Following a decade of research and analysis, the GASB recently concluded that to meet the varied needs of a wide range of users, governmental reports must provide information regarding the public entity as a whole in addition to the traditional fund financial statements. Accordingly, in June 1999 GASB introduced a new financial reporting model in Statement 34, Basic Financial Statements—and Management's Discussion and Analysis—for State and Local Governments. The new model integrates the traditional focus of governmental fund financial statements relating to fiscal accountability (and the modified accrual basis of accounting) with new forms of reporting (e.g., governmentwide financial statements). The two levels of financial reporting are intended to

  • provide more relevant information that will result in greater accountability by state and local governments and
  • enhance the understandability and usefulness of the annual financial reports to users of these reports to enable them to make more informed economic, social, and political decisions.
This chapter provides an overview of governmental accounting and financial reporting, including the new requirements, as well as a discussion of current approaches used in compiling financial reports. In particular, the following elements are included:
  • Governmental GAAP Hierarchy
  • Measurement Focus and Basis of Accounting
  • Fund Structure
  • Internal Control Structure
  • Other Issues Affecting Educational Entities
It is important for governments to provide effective financial information to constituencies in a consistent and clear format. Specifically, the information provided by governments should contribute to accountability in the following areas:
  • Financial position and results of operations
  • Actual financial results compared with adopted budgets
  • Compliance with finance-related laws, rules and regulations
  • Efficiency and effectiveness of operations
  • Maintenance of governmental assets
Consistency in financial reporting by governments is provided through accounting standards. GASB is the standard-setting authority of generally accepted accounting principles (GAAP) for state and local governments, including school districts. In cases for which no GASB pronouncement is applicable, other authoritative sources of guidance exist. The following chapter presents a hierarchy of GAAP in descending order of authoritative literature for governments. The hierarchy was established in Statement of Auditing Standards (SAS) 69, The Meaning of Presents Fairly in Conformity with Generally Accepted Accounting Principles in the Independent Auditor's Report, effective March 15, 1992, and issued by the American Institute of Certified Public Accountants (AICPA).

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  • Category (a) consists of GASB Statements and Interpretations and AICPA and Financial Accounting Standards Board (FASB) pronouncements that have been specifically made applicable to state and local governmental entities by GASB Statements or Interpretations (periodically incorporated in the Codification of Governmental Accounting and Financial Reporting Standards).
  • Category (b) consists of GASB Technical Bulletins and AICPA Industry Audit and Accounting Guides and Statements of Position that have been specifically made applicable to state and local governments by the AICPA and approved by the GASB.
  • Category (c) consists of AICPA Accounting Standards Executive Committee (AcSEC) Practice Bulletins that have been specifically made applicable to state and local governments by the AICPA and approved by the GASB. Also included are consensus positions of groups of accountants organized by the GASB that attempt to reach consensus on accounting issues applicable to statement and local governmental entities. (GASB has not organized such a group as of the date this handbook was released.)
  • Category (d) includes GASB Implementation Guides published by GASB staff. Additionally, practices that are widely recognized and prevalent in state and local government are included in this category.
  • In the absence of a pronouncement covered by Rule 203 or another source of established accounting principles, other accounting literature, such as the following, may be considered, depending on its relevance to the circumstances:
  • GASB Concepts Statements
    • Pronouncements referred to in categories (a) through (d), SAS 69, paragraph 10, of the hierarchy for nongovernmental entities when not specifically made applicable to state and local governments:
    • FASB Concepts Statements
    • AICPA Issues Papers
    • Statements of the International Accounting Standards Committee
    • Pronouncements of other professional associations or regulatory agencies
    • Technical Information Service Inquiries and Replies included in AICPA Technical Practice Aids
    • Accounting textbooks, handbooks, and articles

The appropriateness of other accounting literature depends on its relevance to particular circumstances, the specificity of the guidance, and the general recognition of the issuer or author as an authority.

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Traditionally, the majority of governmental financial information has been maintained and reported in the fund financial statements on the modified accrual basis of accounting or the accrual basis for business-type activities. The recently enacted GASB Statement 34 establishes additional reporting (the governmentwide statements) that represents a major shift in the focus and content of governmental financial statements. Collecting and reporting additional financial information required by the governmentwide statements add to the complexity of financial reporting activities and have significant implications for the traditional focus and basis of accounting used in governmental financial statements.

The new governmentwide financial statements consist of a Statement of Net Assets and a Statement of Activities and are prepared using the economic resources measurement focus and the accrual basis of accounting. Thus, revenues are recognized in the accounting period in which they are earned and become measurable without regard to availability, and expenses are recognized in the period incurred, if measurable.

Governmental fund financial statements continue to be prepared using the current financial resources measurement focus and the modified accrual basis of accounting. Revenues are recognized in the accounting period in which they become available and measurable, and expenditures are recognized in the period in which the fund liability is incurred, if measurable, except for unmatured interest on general long-term debt, which should be recognized when due.1 Proprietary fund financial statements continue to be prepared using the economic resources measurement focus and the accrual basis of accounting.

Like proprietary fund financial statements, fiduciary fund financial statements are prepared using the economic resources measurement focus and the accrual basis of accounting. Table 1 summarizes the measurement focus and basis of accounting for each reporting element and type of fund.

Table 1. Measurement Focus and Basis of Accounting for Financial Statements
Financial Statements Measurement Focus Basis of Accounting
Governmentwide Financial Statements Economic Resources Accrual
Governmental Funds Financial Statements Current Financial Resources Modified Accrual
Proprietary Funds Financial Statements Economic Resources Accrual
Fiduciary Funds Financial Statements Economic Resources Accrual

GASB Statement 20, as amended by Statement 34, allows a government the option of applying FASB Statements and Interpretations issued after November 30, 1989, except for those that conflict with or contradict GASB pronouncements, to enterprise funds and governmentwide financial statements. The election is made on a fund-by-fund basis; however, consistency in the application within a particular entity fund is encouraged.

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For governmental entities to ensure the proper segregation of resources and to maintain proper accountability, an entity's accounting system should be organized and operated on a fund basis. Each fund is a separate fiscal entity and is established to conduct specific activities and objectives in accordance with statutes, laws, regulations, and restrictions or for specific purposes. A fund is defined in GASB Codification Section 1300 as a fiscal and accounting entity with a self-balancing set of accounts recording cash and other financial resources, together with all related liabilities and residual equities or balances, and changes therein, which are segregated for the purpose of carrying on specific activities or attaining certain objectives in accordance with special regulations, restrictions, or limitations.

Statement 34 modified the structure of two categories of funds used by local governmental entities. Specifically, the new reporting model introduces two new types of funds:

  • Permanent funds (in the governmental fund category). Permanent funds are required to be used to report resources that are legally restricted to the extent that only earnings (and not principal) may be used for purposes that support the reporting government programs.
  • Private-purpose trust funds (in the fiduciary fund category). Private-purpose trust funds should be used to report all other trust arrangements under which principal and income benefit individuals, private organizations, or other governments.
The new model eliminates expendable and nonexpendable trust funds to focus fiduciary reporting on resources held for parties external to the reporting government: individuals, private organizations, and other governments. Fiduciary funds, therefore, cannot be used to support the government's own programs.

With the incorporation of these changes, three categories of funds remain:

  • Governmental funds are those through which most governmental functions are accounted for. The acquisition, use, and balances of the government's expendable financial resources and the related current liabilities-except those accounted for in proprietary funds-are accounted for through governmental funds (general, special revenue, capital projects, debt service, and permanent funds).
  • Proprietary funds are used to account for a government's ongoing organizations and activities that are similar to those often found in the private sector. All assets, liabilities, net assets, revenues, expenses, and transfers relating to the government's business and quasi-business activities-in which changes in net assets or cost recovery are measured-are accounted for through proprietary funds (enterprise and internal service funds). Generally accepted accounting principles for proprietary funds are similar to those applicable to businesses in the private sector; the measurement focus is on determining operating income, financial position, and cash flows.
  • Fiduciary funds are used to account for assets held by a government in a trustee capacity or as an agent for individuals, private organizations, or other governmental units. The fiduciary fund category includes pension (and other employee benefit) trust funds, investment trust funds, private-purpose trust funds, and agency funds.
Additional information on the governmental fund structure may be found in chapter 5.

Major Funds

The concept of major fund reporting is introduced and defined by GASB Statement 34 to simplify the presentation of fund information and to focus attention on the major activities of the entity. Rather than require each type of fund to be individually presented, Statement 34 requires the individual presentation of only major funds, with all other funds combined into a single column. This reduces the number of funds presented on the face of the financial statements and directs the focus on the significant funds of the reporting entity. Major fund reporting is applied only to governmental (i.e., general, special revenue, debt service, capital projects, and permanent funds) and enterprise funds. Internal service funds are excluded from the major fund reporting requirements. Fiduciary fund information is presented by type of fund rather than by major funds.

GASB defines major funds as those meeting the following criteria:

  • Total assets, liabilities, revenues, or expenditures/expenses of the individual governmental or enterprise fund are at least 10 percent of the corresponding total (assets, liabilities, and so forth) for all funds of that category (governmental funds) or type (enterprise funds).
  • Total assets, liabilities, revenues, or expenditures/expenses of the individual governmental fund or enterprise fund are at least 5 percent of the corresponding total for all governmental and enterprise funds combined.
Both criteria must be met in the same element (assets, liabilities, etc.) for both the 10 percent and 5 percent tests for a fund to be defined as major. However, Statement 34 permits a government to designate a particular fund that is of interest to users as a major fund and to individually present its information in the basic financial statements, even if it does not meet the criteria. However, a government does not have the option to NOT report a fund as major if it meets the criteria above.

It should be noted that in applying the major fund criteria to enterprise funds, the reporting entity should consider both operating and nonoperating revenues and expenses, as well as gains, losses, capital contributions, additions to permanent endowments, and special items. When the major fund criteria are applied to governmental funds, revenues do not include other financing sources and expenditures do not include other financing uses. However, special items would be included.

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An integral part of proper accounting procedures rests in issues of controls and begins with internal accountability structures. The AICPA's Statement on Auditing Standards No. 78, Consideration of Internal Control in a Financial Statement Audit: An Amendment to Statement on Auditing Standards No. 55, (which incorporates the Committee of Sponsoring Organizations Report, Internal Control Framework) indicates that the elaborateness of the system of internal controls established within an organization is a matter of judgment on the part of management, with careful consideration for circumstances, such as the size of the organization and the number of personnel available, and the relationship between the costs and benefits of designing and implementing controls. In addition, the nature of internal control is such that even appropriate methods and systems will not guarantee that an entity's objectives will be achieved.

Internal control is a process-affected by an entity's board of trustees, management, and other personnel-designed to provide reasonable assurance regarding the achievement of objectives in the following categories:

  • Reliability of financial reporting
  • Effectiveness and efficiency of operations
  • Compliance with applicable laws and regulations
As a result, internal control consists of five interrelated components:
  • Control Environment
  • Risk Assessment
  • Control Activities
  • Information and Communication
  • Monitoring

Control Environment

The control environment is established on the basis of the attitude of management toward internal control. It is the basis for all other elements of the system of internal control. AICPA Statement on Auditing Standards No. 78 states that the control environment "sets the tone of an organization, influencing the control consciousness of its people. It is the foundation for all other components of internal control, providing discipline and structure." As such, a management philosophy that is dedicated to establishing a sound business process and operating controls would tend to create a stronger internal control environment than a philosophy that is unaware of or unconcerned with internal controls.

The collective effort of various factors affects the control environment, including the following:

  • Integrity and ethical values
  • Commitment to competence
  • Governing board or audit committee participation
  • Management's philosophy and operating style
  • Organizational structure
  • Assignment of authority and responsibility
  • Human resource policies and practices
The substance of internal controls is more important than the form because of the risk that controls may not be effectively implemented or maintained.

Risk Assessment

Risk assessment is the entity's identification and analysis of risks relevant to the achievement of its objectives and forms a basis for determining how the risks should be managed. Risks can arise or change as a result of the following factors:

  • Changes in operating environment
  • New personnel
  • New or revamped information systems
  • Rapid growth
  • New technology
  • New grant programs, building projects, or other activities
  • Organizational restructuring
  • Accounting pronouncements
  • Federal regulations
  • Finance-related statutes
Given the dynamic nature of governmental operating environments, the ability to anticipate and mitigate risks from these changes is a key factor in measuring the strength of internal controls. To the extent that the design of controls for new operations is an important aspect of planning efforts, an entity's level of internal control may be enhanced.

Control Activities

Control activities are the policies and procedures that help ensure that management directives are carried out. Control activities can be divided into four categories:

  • Performance reviews
  • Information processing
  • Physical controls
  • Segregation of duties
The application of controls, such as the segregation of duties, is affected to some degree by the size of the organization. In small entities, procedures will be less formal than in large entities. Additionally, certain types of control activities may not be relevant in small entities.

Information and Communication

Information and communication represent the identification, capture, and exchange of information in a form and time frame that enable people to carry out their responsibilities. Information systems encompass procedures and documents that do the following:

  • Identify and record all valid transactions
  • Describe, on a timely basis, transactions in sufficient detail to permit proper classification for financial reporting
  • Measure the value of transactions in a manner that permits their proper recording in the financial statements
  • Permit the recording of transactions in the proper accounting period
  • Present properly the transactions and related disclosures in the financial statements
Senior management should deliver a clear message to employees about their responsibilities and role in the internal control system. Employees should also have a means for communicating the effectiveness and efficiency of these systems to upper levels of management.

Monitoring

Monitoring is a process that assesses the quality of internal control performance over time. Ongoing monitoring activities include regular management and supervisory activities and other actions taken during the normal performance of management's responsibilities. Further, periodic reviews of internal controls and related activities, performed with internal personnel or external resources, may be undertaken. The nature and timing of these evaluations depend on the effectiveness of ongoing activities and the risk that internal controls are not performing as intended by management. Deficiencies in the system of internal controls should be reported to the appropriate level of management.

Management should clearly assign responsibility and delegate authority with sufficient care to ensure that

  • persons who perform control procedures are held accountable for their performance by those who monitor these activities, and
  • persons who monitor the performance of control procedures are held accountable by senior management, the governing board, or the audit committee.
If accounting information is routinely used in making operating decisions, management is likely to establish effective controls and hold lower-level managers and employees accountable for performance. In addition, if management routinely uses accounting information in measuring progress and operating results, significant variances between planned and actual results are likely to be investigated. This review may detect the causes of the variances and affect the steps necessary to correct procedures that failed to prevent misstatements.

Common Types of Control Procedures

Numerous control procedures and monitoring activities are performed by individuals in governmental entities to accomplish particular objectives. All these controls, however, can be classified within one of the basic categories of controls described below. Detailed control procedures or monitoring activities may be included in each of these categories, depending on the size of the entity and the sophistication of the particular control environment.

Access Controls

Certain controls prevent access to assets by unauthorized persons. Often these controls are physical in nature. For example, an organization might store inventories of supplies and commodities in locked storage areas, store currency in a vault or a locked drawer, and use alarm systems to restrict access by unauthorized individuals. If controls to prevent unauthorized access to assets are not effective, assets may be lost or stolen. If detective control procedures such as physical inventory counts are appropriately performed, shortages should be discovered in a timely manner.

In some cases, unauthorized access to assets may be gained through vulnerable accounting records-especially records maintained on computer systems. For example, if warehouse requisitions can be issued through a computer terminal, access to inventory may be gained through the system. Controls over unauthorized access to assets through computer records may be physical (e.g., terminals are kept in a locked room) or logical (e.g., access to the computer program or data files may be obtained only with the proper password or other user-identification method). Monitoring the control procedures that address unauthorized access includes observing physical control procedures, reviewing established access privileges with the manager of information systems, or reviewing reports of attempted computer access violations. Internal auditors often perform such activities.

Access controls, however, do not prevent individuals who have authorized access to assets from misappropriating them. Individuals who have authorized access to both assets and related accounting records may be in a position to conceal shortages of assets in the records. However, if duties are properly segregated, persons with access to assets will not have access to related accounting records, which may be altered to conceal shortages.

Controls over authorized access to assets are important to an organization, not only to prevent thefts, but also to ensure that assets are committed only after proper consideration by individuals who are knowledgeable and experienced. Authorization and approval are types of controls designed to prevent invalid or inappropriate transactions from occurring. An example is a procedure designed to ensure that disbursements are made only when authorized orders for goods and services have been received. In many systems, access to computerized records (e.g., shipping requests) can result in improper access to assets; therefore, procedures must be designed to limit access to computerized records.

Reconciliation and Comparison of Assets with Records

Reconciling and comparing assets with accounting records establish a system of independent verification, either through preparing an independent control document used to reconcile accounting records and assets or by directly comparing accounting records with related assets. Examples of these procedures include the reconciliation of physical inventory to accounting records and the preparation of a bank reconciliation.

Analytical Reviews

The purpose of analytical reviews is to evaluate summarized information by comparing it with expected results. Management personnel often perform analytical reviews to determine whether the entity is performing as planned. For example, a common analytical review procedure is the comparison of budgeted to actual performance, with investigation of any significant or material variances as determined by the analyst. Often, analytical reviews may be used to monitor other underlying control procedures.

Authorization and Approval

Authorization and approval procedures prevent invalid transactions from occurring. Thus, this type of control typically involves authorization or approval of transactions at specific dollar thresholds and manual (e.g., requiring signatures of authorized individuals) or automated (e.g., password protected) authorizations for computer transactions. The effectiveness of these procedures often depends on general computer controls over information security.

Reviews of Output

Reviews of output should be performed by district personnel who have the knowledge and experience to identify errors. Such reviews could be performed in both computer and manual systems. These reviews check the validity and accuracy of output by comparing it in detail with expected results. For example, a purchasing manager may compare recorded amounts or quantities purchased with separate records of purchase orders.

Transactional Reviews

Transactional reviews check the validity and accuracy of transaction processing by comparing it in detail with expected results. Reviews often use exception reports (usually computer-generated), which list items that failed to be processed because they did not meet specified criteria. For example, a computer-generated check may be rejected if it exceeds some dollar amount and requires a manual signature. Monitoring these types of control procedures involves reviews of results performed by management.

General Computer Controls

Computer systems frequently have common areas of control and related control procedures referred to as general computer controls. These controls directly or indirectly affect all systems that operate within a computer-processing environment. General computer controls include the usual elements of effective internal control, that is, an individual or group responsible for control procedures and monitoring activities. Managers of the information systems function usually monitor the performance of general computer controls. Monitoring activities include observation, exception reporting, reviews of work performed, reviews of program changes, oversight by information system steering committees, and the monitoring of user complaints. For example, the effectiveness of programmed control procedures such as edit checks and approvals depends on general computer controls that ensure that program changes are not made improperly. General computer controls include controls over computer operations; systems acquisition, development, and maintenance; information security; and information systems support, as detailed below:

  • Computer operations. The computer operations staff is responsible for the day-to-day processing activities of the entity's system. It ensures that jobs are scheduled and processed as planned, data are properly stored on the system or tapes, and reports are distributed in a timely and accurate fashion.
  • Systems acquisition, development, and maintenance. The systems acquisition, development, and maintenance staff is responsible for planning, acquiring or developing, testing, and implementing new application systems and changes to existing application systems. Such controls are usually important in larger processing environments where there is more development and maintenance activity. The systems are more complex and there is less reliance on purchased software.
  • Information security. The information security function is responsible for administering and maintaining an entity's information security program, including both physical and logical security. The primary goal of such a program is to ensure that access to program data, online transactions, and other computing resources is restricted to authorized users.
  • Information systems support. Information systems support includes such functions as system software maintenance, database administration, communications and network management, end-user computing, and other groups with technical and administrative support responsibilities.
Certain governmental entities may use external service organizations for executing and recording certain transactions, such as payroll processing. In such situations, the entity needs to ensure that the service organization has adequate controls over processing the transactions.

In the final analysis, maintaining the internal control environment and related control procedures is an integral part of management's responsibilities. In the context of governmental accounting and reporting, the control environment has a direct impact on an entity's ability to collect and present accurate financial information. Thus, the internal control environment and related procedures are key areas of concern to an entity's external auditor.

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School districts are the most common special governmental units. In some states, school districts operate as a fiscally dependent part of another local governmental entity such as a city or county; in other states, school districts are legislatively independent with authority to levy taxes and set budgets. School districts may or may not have common boundaries with another political subdivision. Regardless of whether districts are component units of another financial reporting entity, are joint ventures of several reporting entities (such as consolidated educational agencies), or meet the definition in GASB Codification, Section 2100 as separate reporting entities, many school districts prepare separate financial statements to accomplish one or more of the following:

  • Support state or federal aid applications
  • Report financial activities to parent, taxpayer, and citizen groups
  • Prepare a financial report for use in an official statement for bond issuance purposes
Although school districts are a common type of government, they face a number of unique issues that make them distinct from states, cities, counties, or other local governmental entities. These issues often result in internal control and operational challenges that district management must address. The following chapter outlines a number of unique educational issues; however, this list is not exhaustive.
  • Attendance reporting. Most school districts receive state aid on the basis of average daily membership (ADM), average daily attendance (ADA), or a similar pupil count method. ADM and ADA data typically are determined at individual school sites and then reported to a central attendance unit. That unit prepares reports for state aid and, in many cases, for federal aid, such as impact aid. Incorrect attendance reporting can lead to the allocation of too much or too little aid.
  • Student activity funds. Most school districts have cash funds or bank accounts at individual schools under the control of school principals or club advisors. These funds may be excluded from the district's normal accounting controls. These funds present a unique control challenge to school districts given their decentralized nature and the production of financial records and reports by non-accounting personnel. Additional guidance on these issues is given in chapter 8.
  • U.S. Department of Education requirements. Federal reporting requirements and others mandated by state-level education agencies are typically more detailed than the account code structures of cities and other local governments. Thus, district accounting systems must have the ability to account for transactions at a level of detail beyond that required by other governments. This issue is particularly complex for school district payroll systems, given the plurality of funding sources for district personnel and reporting requirements for personnel costs.
  • School lunch programs. Most school districts participate in the U.S. Department of Agriculture (USDA) free or reduced-price food programs. These programs require school districts to segregate food service programs from other programs. School districts that receive federal commodities during the year should recognize the fair value as revenue in the period when all eligibility requirements are met (typically, when the commodities are received). (Guide to Implementation of GASB Statement 34 and Related Pronouncements Q&A, Q152) Because the federal agricultural commodity program involves purpose restrictions in the use of the resources, the value of inventory remaining on hand at fiscal year-end should be reflected as a reservation of fund balance/restriction of net assets. (Statement 33, paragraph 14) USDA-donated commodities may also pose accounting and reporting problems because of restrictive federal rules regulating the use of these commodities.
  • Site-based management initiatives. Over the past decade, many states and school districts have implemented site-based management initiatives. These initiatives have been designed to delegate to individual schools greater levels of authority to determine the use of financial resources. As a result, local administrators may control and report on the use of financial resources, even though they may lack financial management skills. This issue creates a challenge to district management in controlling financial resources and ensuring that reported results are correct.
  • Educational accountability. Educational accountability has become a key policy issue at both state and national levels and has resulted in a number of recent reforms. Several educational accountability reforms have required school districts to collect and present school-level financial information. In addition, school-level financial information is often related to non-financial information (e.g., student achievement) in published reports and is used for comparison purposes. As a result, school districts must increasingly focus on ensuring that financial information reported by schools is accurate and consistent across the district.
In conclusion, school districts, like other governmental entities, must annually compile financial data and report on their financial position. Accounting and reporting standards for this information are set forth by a number of oversight agencies, including GASB, FASB, and AICPA. A major change in reporting requirements for governments was recently established by GASB Statement 34. This accounting standard requires governmental agencies, including school districts, to increase their financial reporting to include governmentwide financial statements as well as the traditional fund reporting. Although this new reporting model does not change the basic internal control expectations for governments, GASB Statement 34 presents new financial reporting challenges for school districts.

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Footnote

1 Codification of Governmental Accounting and Financial Reporting Standards, section 1100.110.