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Questions and Answers for Statement of Federal Financial Accounting Standards (SFFAS) No. 47 Working Group review

SFFAS 47 provides the following three principles:

[20] This Statement provides three principles for determining which organizations should be included12 in the government-wide GPFFR (see paragraph 21-35). This Statement also provides an additional principle requiring inclusion of organizations if excluding them would be misleading (see paragraph 36-37). The three principles are to be applied without considering whether the relationship is temporary or permanent. However, whether the relationship is temporary or permanent would influence the likelihood that the entity exhibits the characteristics of a consolidation entity or of a disclosure entity.

[21] An organization meeting any one of the three principles below is included in the government-wide GPFFR:

  1. In the Budget
  2. Majority Ownership Interest
  3. Control with Risk of Loss or Expectation of Benefit

[Footnote12] ”Included” means the information is either consolidated or disclosed

Paragraphs 22-35 provide a detailed explanation of the three principles listed in paragraph 21. In particular, the following paragraphs should be considered regarding grant recipient organizations:

Situations Where Control Does Not Exist

[33] Because of the federal government’s broad powers and economic influence, control should not be inferred from either:

  1. authority to exercise regulatory powers over an organization; or
  2. economic dependency of the organization on the federal government.

[34] The federal government has the power to regulate many organizations by use of its sovereign and legislative powers. For example, the federal government has the power to regulate the behavior of organizations by imposing conditions or sanctions on their operations. However, the governing bodies of the regulated organizations make decisions within the regulatory framework. Regulatory powers do not constitute control for purposes of this Statement because the federal government’s interest in these organizations extends only to the regulatory aspects of the operations.

[35] Certain organizations may be economically dependent on the federal government but ultimately retain discretion as to whether to accept funding or do business with the federal government. For example, many not-for-profit organizations rely on federal government funding but that does not mean they are controlled by the federal government. Although the federal government may be able to influence organizations dependent on federal funding or business through purchasing power, the federal government typically does not govern their financial and operating policies.

Which agencies are considered consolidated?

The following agencies have been recognized as consolidated either by the agency reporting a survey determination as consolidated, or the agency concurred with the Working Group’s determination.

Consolidated Entities

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FR Entity Reporting Agency
Administrative Conference of the United States Administrative Conference of the United States
Advisory Council on Historic Preservation Advisory Council on Historic Preservation
African Development Foundation African Development Foundation
Agency for International Development Agency for International Development
American Battle Monuments Commission American Battle Monuments Commission
Appalachian Regional Commission Appalachian Regional Commission
Appraisal Subcommittee Federal Financial Institutions Examination Council
Federal Financial Institutions Examination Council Appraisal Subcommittee
Architect of the Capitol Architect of the Capitol
Botanic Garden
Architectural and Transportation Barriers Compliance Board Architectural and Transportation Barriers Compliance Board
Armed Forces Retirement Home Armed Forces Retirement Home
Barry Goldwater Scholarship & Excellence in Education Foundation Barry Goldwater Scholarship and Excellence in Education Foundation
Broadcasting Board of Governors Broadcasting Board of Governors
Bureau of Consumer Financial Protection Bureau of Consumer Financial Protection
Central Intelligence Agency Central Intelligence Agency
Chemical Safety and Hazard Investigation Board Chemical Safety and Hazard Investigation Board
Christopher Columbus Fellowship Foundation Christopher Columbus Fellowship Foundation
Commission for the Preservation of America’s Heritage Abroad Commission for the Preservation of America’s Heritage Abroad
Commission of Fine Arts Commission of Fine Arts
Commission on Civil Rights U.S. Commission on Civil Rights
Commission on International Religious Freedom - (within Temporary Commissions) United States - Commission on International Religious Freedom
Commission on Security and Cooperation in Europe Commission on Security and Cooperation in Europe
Commission to Eliminate Child Abuse and Neglect Fatalities Commission to Eliminate Child Abuse and Neglect Fatalities
Committee for Purchase from People Who Are Blind or Severely Disabled Committee for Purchase from People Who Are Blind or Severely Disabled
Commodity Futures Trading Commission Commodity Futures Trading Commission
Congressional Budget Office Congressional Budget Office
Congressional-Executive Commission on the People's Republic of China Congressional-Executive Commission on the People's Republic of China/Other Legislative Branch Boards and Commissions
Consumer Product Safety Commission Consumer Product Safety Commission
Corporation for National and Community Service Corporation for National and Community Service
Council of the Inspectors General on Integrity and Efficiency Council of the Inspectors General on Integrity and Efficiency
Court Services and Offender Supervision Agency for the District of Columbia Court Services and Offender Supervision Agency for the District of Columbia
Defense Nuclear Facilities Safety Board Defense Nuclear Facilities Safety Board
Defense Security Cooperation Agency Defense Security Cooperation Agency
Delta Regional Authority Delta Regional Authority
Denali Commission Denali Commission
Department of Agriculture Department of Agriculture
Department of Commerce Department of Commerce
National Cybersecurity Center of Excellence
Department of Defense Aerospace Federally Funded Research and Development Center
Arroyo Center
Lincoln Laboratory
Project Air Force
Software Engineering Institute
Center for Naval Analyses
Department of Defense – Air Force
Department of Defense - Army
Department of Defense – Navy/Marines
US Army Corps of Engineers
Department of Education Department of Education
Institute of Education Sciences
Department of Energy Bonneville Power Administration
Department of Energy
Federal Energy Regulatory Commission (FERC)
Southeastern Power Administration
Southwestern Power Administration
Western Area Power Administration
Ames Laboratory
Argonne National Laboratory
Brookhaven National Laboratory
Fermi National Accelerator Laboratory
Idaho National Laboratory
Lawrence Berkeley National Laboratory
Lawrence Livermore National Laboratory
Los Alamos National Laboratory
National Renewable Energy Laboratory
Oak Ridge National Laboratory
Pacific Northwest National Laboratory
Princeton Plasma Physics Laboratory
Sandia National Laboratory
Savannah River National Laboratory
SLAC National Accelerator Laboratory
Thomas Jefferson National Accelerator Facility
Department of Health and Human Services Department of Health and Human Services
National Cancer Institute
Department of Homeland Security Department of Homeland Security
Homeland Security Studies and Analysis Institute
Homeland Security Systems Engineering and Development Institute
National Biodefense Analysis and Countermeasures Center
Department of Housing and Urban Development Affordable Housing Program
Department of Housing and Urban Development
Government National Mortgage Association
Department of Justice Department of Justice
Federal Prison Industries, Inc (Unicor)
Department of Labor Department of Labor
Department of State Administration of Foreign Affairs
Department of State
International Security Assistance
Department of the Interior Department of the Interior
Department of the Treasury Department of the Treasury
Federal Financing Bank
Department of Transportation Department of Transportation
Maritime Administration
Department of Veterans Affairs Department of Veterans Affairs
District of Columbia - Defender Services/Courts District of Columbia Courts
Dwight D. Eisenhower Memorial Commission Dwight D. Eisenhower Memorial Commission
Eisenhower Exchange Fellowship Program Eisenhower Exchange Fellowship Program
Election Assistance Commission Election Assistance Commission
Environmental Dispute Resolution Fund Environmental Dispute Resolution Fund
Environmental Protection Agency Environmental Protection Agency
Executive Office of the President Executive Office of the President
Federal Drug Control Programs Federal Fund
Export-Import Bank of the United States Export-Import Bank of the United States
Farm Credit Administration Farm Credit Administration
Farm Credit System Insurance Corporation Farm Credit System Insurance Fund
Federal Communications Commission Federal Communications Commission
Universal Service Fund
Telecommunications Relay Service Fund (TRS) - the plan administered by Rolka Loube
North American Numbering Plan (NANP) - the plan administered by Welch LLP & Neustar
Federal Deposit Insurance Corporation Federal Deposit Insurance Corporation
Federal Deposit Insurance Fund and FSLIC Resolution Fund
FDIC Office of Inspector General Federal Fund
Orderly Liquidation Federal Fund
Federal Election Commission Federal Election Commission
Federal Housing Finance Agency Federal Housing Finance Agency
Federal Labor Relations Authority Federal Labor Relations Authority
Federal Maritime Commission Federal Maritime Commission
Federal Mediation and Conciliation Service Federal Mediation and Conciliation Service
Federal Mine Safety and Health Review Commission Federal Mine Safety and Health Review Commission
Federal Retirement Thrift Investment Board Federal Retirement Thrift Investment Board
Federal Trade Commission Federal Trade Commission
General Services Administration General Services Administration
Government Accountability Office Government Accountability Office
Government Printing Office Government Printing Office
Gulf Coast Ecosystem Restoration Council Gulf Coast Ecosystem Restoration Council
Harry S. Truman Scholarship Trust Fund Harry S. Truman Scholarship Foundation
House and Senate (LEG) House of Representatives
Indian Law and Order Commission Indian Law and Order Commission
Institute of Museum and Library Services Institute of Museum and Library Services
Intelligence Community Management Account Intelligence Community Management Account
Inter-American Foundation Inter-American Foundation
International Trade Commission International Trade Commission
James Madison Memorial Fellowship Foundation James Madison Memorial Fellowship Foundation
Japan-United States Friendship Commission The Japan United States Friendship Commission
JFK Center for Performing Arts JFK Center for Performing Arts
John C. Stennis Center John C. Stennis Center for Public Service Training and Development
Library of Congress Library of Congress
Marine Mammal Commission Marine Mammal Commission
Medicaid and CHIP Payment and Access Commission Medicaid and CHIP Payment and Access Commission
Medicare Payment Advisory Commission Medicare Payment Advisory Commission
Merit Systems Protection Board Merit Systems Protection Board
Military Compensation and Retirement Modernization Commission Military Compensation and Retirement Modernization Commission
Millennium Challenge Corporation Millennium Challenge Corporation
Morris K. Udall and Stewart L. Udall Foundation Morris K. Udall and Stewart L. Udall Foundation
National Aeronautics and Space Administration National Aeronautics and Space Administration
National Archives and Records Administration National Archives and Records Administration
National Capital Planning Commission National Capital Planning Commission
National Council on Disability National Council on Disability
National Credit Union Administration National Credit Union Administration
The National Credit Union Share Insurance Fund
The National Credit Union Administration Central Liquidity Facility
The National Credit Union Administration Community Development Revolving Loan Fund
Temporary Corporate Credit Union Stabilization Fund
National Endowment for the Humanities National Endowment for the Humanities
National Foundation on the Arts and the Humanities National Endowment for the Arts
National Gallery of Art National Gallery of Art
National Infrastructure Bank National Infrastructure Bank
National Labor Relations Board National Labor Relations Board
National Mediation Board National Mediation Board
National Railroad Passenger Corporation Office of Inspector General National Railroad Passenger Corporation Office of Inspector General
National Science Foundation National Science Foundation
National Transportation Safety Board National Transportation Safety Board
Neighborhood Reinvestment Corporation Neighborhood Reinvestment Corporation
Northern Border Regional Commission Northern Border Regional Commission
Nuclear Waste Technical Review Board Nuclear Waste Technical Review Board
Occupational Safety and Health Review Commission Occupational Safety and Health Review Commission
Office of Compliance Office of Compliance
Office of Government Ethics Office of Government Ethics
Office of Navajo and Hopi Indian Relocation Office of Navajo and Hopi Indian Relocation
Office of Personnel Management Office of Personnel Management
Office of Special Counsel Office of Special Counsel
Open World Leadership Center Open World Leadership Center
Overseas Private Investment Corporation Overseas Private Investment Corporation
Panama Canal Commission Panama Canal Commission
Patient-Centered Outcomes Research Trust Fund Patient-Centered Outcomes Research Trust Fund
Peace Corps Peace Corps
Pension Benefit Guaranty Corporation Pension Benefit Guaranty Corporation
Presidio Trust Presidio Trust
Privacy and Civil Liberties Oversight Board Privacy and Civil Liberties Oversight Board
Public Defender Service Federal Payment to the District of Columbia Public Defender Service
Railroad Retirement Board Railroad Retirement Board
Securities and Exchange Commission Securities and Exchange Commission
Selective Service System Selective Service System
Senate Preservation Fund Senate Preservation Fund
Small Business Administration Small Business Administration
Smithsonian Institution Smithsonian Network
Friends of the National Zoo
Smithsonian Institution
Social Security Administration Social Security Administration
Surface Transportation Board Surface Transportation Board
St. Lawrence Seaway Development Corporation St. Lawrence Seaway Development Corporation
State Justice Institute State Justice Institute
The Judiciary Administrative Office of the United States Courts
Court of Appeals, District Courts, and other Judicial Services
Judicial Retirement Fund
United States Court of Appeals for the Federal Circuit
United States Court of International Trade
Federal Judicial Center
United States Sentencing Commission
Judiciary Engineering and Modernization Center
Supreme Court of the United States
U.S. Capitol Police U.S. Capitol Police
U.S. Capitol Preservation Commission U.S. Capitol Preservation Commission
U.S. Equal Employment Opportunity Commission Equal Employment Opportunity Commission
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission
U.S. Postal Service U.S. Postal Service
U.S. Trade and Development Agency Trade and Development Agency
United States Court of Appeals for Veterans Claims United States Court of Appeals for Veterans Claims
United States Holocaust Memorial Museum United States Holocaust Memorial Museum
United States Institute of Peace United States Institute of Peace
United States Interagency Council on Homelessness United States Interagency Council on Homelessness
United States Tax Court United States Tax Court
United States-China Security Review Commission - (within Temporary Commissions) United States - China Economic Security Review Commission
Vietnam Education Foundation Vietnam Education Foundation
Woodrow Wilson International Center for Scholars Woodrow Wilson International Center for Scholars

Which agencies are considered disclosure?

The following agencies have been recognized as disclosure either by the agency reporting a survey determination as disclosure, or the agency concurred with the Working Group’s determination.

Disclosure Entities

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FR Entity Reporting Agency
Department of Education Gallaudet University
Department of the Treasury Board of Governors of the Federal Reserve System
Corporation for Travel Promotion
Federal Home Loan Mortgage Corp (Freddie Mac)
Federal National Mortgage Association (Fannie Mae)
Federal Reserve System
Securities Investor Protection Corporation
Federal Reserve Banks
Department of Transportation Amtrak (National Railroad Passenger Service Corp)
Maritime Administration/Employees Association and Regimental Activities Non-Appropriated Fund Instrumentalities
Washington Metropolitan Area Transit Authority
Center for Advanced Aviation System Development (FFRDC & administered by MITRE Corporation)
Federal Communications Commission Universal Service Administrative Company
National Aeronautics and Space Administration Jet Propulsion Laboratory
Securities and Exchange Commission Public Company Accounting Oversight Board
Securities Investor Protection Corporation
WWI Centennial Commission WWI Centennial Commission

Which agencies are considered related party?

The following agencies have been recognized as related party either by the agency reporting a survey determination as disclosure, or the agency concurred with the Working Group’s determination.

Related Party Entities

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FR Entity Reporting Agency
Department of the Treasury Multilateral Assistance
Federal Communications Commission Rolka Loube, LLC
NEUSTAR
WELCH LLP
National Credit Union Administration Federal Financial Institutions Examination Council

Which agencies are considered misleading to include/do not report?

The following agencies have been recognized as misleading to include/do not report either by the agency reporting a survey determination as such, or the agency concurred with the Working Group’s determination.

Misleading to Include/Do Not Report Entities

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FR Entity Reporting Agency Determination
Office of the Federal Coordinator for Alaska Natural Gas Transportation Projects
Office of the Federal Coordinator for Alaska Natural Gas Transportation Projects
Do not report - Entity closed on March 7, 2015 due to lack of funding.
Department of Defense National Security Engineering Center Do not report
Center for Communications and Computing Do not report
National Defense Research Institute Do not report
Systems and Analysis Center Do not report
Department of Education American Printing House for the Blind Do not report
Howard University Do not report
National Technical Institute for the Deaf Do not report
Department of Energy Electric Reliability Organization Do not report
United States Enrichment Corporation Fund Do not report
Department of the Interior/OSMRE United Mine Workers of America Benefit Funds Do not report
Department of the Treasury Federal Home Loan Banks Misleading to include
International Monetary Programs Misleading to Include
Student Loan Marketing Association Do not report
Resolution Funding Corporation Do not report - Obligation fulfilled in 2011.
Department of Veterans Affairs Center for Enterprise Modernization Do not report
Federal Housing Finance Agency The Financing Corporation Do not report
National Science Foundation National Center for Atmosphere Research Do not report
National Optical Astronomy Observatory Do not report
National Radio Astronomy Observatory Do not report
National Solar Observatory Do not report
Science and Technology Policy Institute Do not report
Office of the Nuclear Waste Negotiator   Do not report - Inactive
Public Private Investment Funds Public Private Investment Funds Do not report - 9/30/13 PPIP was dissolved. Will not report in FY2018
Recovery Accountability and Transparency Board Recovery Accountability and Transparency Board Do not report - Board is closing in Sept 2015. Will not exist in FY2018.
Securities and Exchange Commission Standard Setting Body Misleading to include
Small Business Administration SCORE Misleading to include
Tennessee Valley Authority Babcock and Wilcox Do not report

Which agencies have a determination discrepancy or have not reported a survey to the SFFAS No. 47 Working Group (WG)?

The WG made a determination for each agency and compared it to the agency’s determination. The following agencies fell into the determination discrepancy category. There is ongoing work between the agency and WG to resolve all discrepancies.

There are a few agencies that still have not provided a survey determination. If you are on this list, and have not provided a survey, please contact janis.doak@fiscal.treasury.gov.

Determination Discrepancy/Not Submitted a Survey

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FR Entity Reporting Agency Determination Status
Department of Health and Human Services CMS Alliance to Modernize Healthcare WG has not received survey.
Department of the Treasury Institute of American Indian and Alaska Native Culture and Arts Development Determination Discrepancy - FR Entity is under review.
Corporation for Public Broadcasting Determination Discrepancy - FR Entity is under review.
Legal Services Corporation Determination Discrepancy - FR Entity is under review.
Export-Import Bank of the United States Private Export Funding Corp WG has not received survey.
National Aeronautics and Space Administration Center for the Advancement of Science in Space WG has not received survey.
Space Exploration Technologies Corporation WG has not received survey.
Blue Origin WG has not received survey.
Orbital Sciences Corporation WG has not received survey.
The Boeing Company WG has not received survey.
Sierra Nevada Corporation WG has not received survey.
National Railroad Retirement Investment Trust Railroad Retirement Board Determination Discrepancy - FR Entity is under review.
Tennessee Valley Authority Tennessee Valley Authority Determination Discrepancy - FR Entity is under review.
U.S. Nuclear Regulatory Commission Center for Nuclear Waste Regulatory Analyses WG has not received survey.

Last modified 06/19/18