Auditability goes hand in glove with accountability and equipment-on-hand readiness. The tenets of our Command Supply Discipline Program (CSDP) are the foundation for ensuring we have the assets needed to be a combat-credible Army, capable of deterring and competing below the level of armed conflict and up to multi-domain conflict. These same tenets also ensure success in our annual Army audits of general equipment (GE). We all have similar reactions when an external entity comes to evaluate our processes and procedures; but if we follow our basic practices of CSDP, these audits only validate that we are good stewards of the resources required to fight and win.
The Secretary of the Army officially notified the Secretary of Defense that the Army was ready to move to a full financial statement audit in September 2017. The Army has made tremendous efforts to achieve auditable financial statements but work still remains. One critical component in achieving auditability is accurate property accountability of mission-critical assets. Independent auditors have been visiting installations for the past three years to conduct existence and completeness testing on capital assets (Class II, VII, and VIII items with an acquisition price over $250,000).
Existence testing, also known as book-to-floor, means the auditor is checking to ensure the data the Army provided from our Accountable Property System of Record (APSR) matches the data on the asset’s data plate. Completeness, or floor-to-book testing, is when auditors check that physical assets are properly documented in an APSR. Auditors randomly select assets in unit areas, record the information from the assets’ data plates, and then try to match that data in the APSR to confirm the assets are properly accounted for and the document trail is complete.
The Audit Process
Audits add some additional work to unit supply personnel, but the foundations for success are laid long before an auditor ever shows up. Commanders and Soldiers must have good CSDPs to maximize the readiness of their organizations. The past three years have shown that units whose senior leaders are actively engaged in the process have much less difficulty getting through an audit.
The audit process involves the Army providing a list of all its capital assets to the auditor in early January of each year. Auditors use statistical analysis to determine which assets, by installation, they want to test. They provide the selected testing locations, not the specific assets, to the Office of the Assistant Secretary of the Army for Financial Management and Comptroller (ASA (FM&C)) and the Deputy Chief of Staff (DCS), G-4. The ASA (FM&C) then hosts a series of synchronization sessions with impacted commands. At this point in the process, the Army does not know what equipment will be tested.
Auditors provide the final list of test assets to ASA (FM&C) 15 business days prior to visiting each location. This measure ensures the audit assesses the current state of accountable records and is designed to prevent potential fraud in the audit trail or re-creation of missing documents. ASA (FM&C) in turn provides that information to the appropriate commands for distribution.
Once the sample list is published, ASA (FM&C) hosts detailed in-progress reviews (IPRs) with the affected commands and units to review timelines and determine which assets are not available due to deployment, depot-level maintenance actions, training exercises, and etc. They also review documentation requirements and timelines for submission. Documents can be loaded in the Army Audit Reporting Tool (AART) as soon as the asset list is provided. ASA (FM&C) hosts a final synchronization session with the command, installation and unit representatives the week prior to a site visit to validate the in-brief location and time; confirm the senior unit representative who will attend the session; and answer any final questions concerning the site visits. Again, previous engagements have shown the best results when leaders take an active role in preparing for and participating in site visits.
During the in-brief, units coordinate link-ups and escort auditors to their unit locations. It is up to the escorts to guide the auditors to the assets. Once an asset is located, the audit team will compare the information on the data plate to the information on their asset listing for existence testing. Auditors need to physically see the data plate, even if it is located inside a vehicle. Units do not need to lay out supporting equipment such as Basic Issue Items or provide maintenance records as they would in an inventory. Units also should not offer any required documentation to the auditors at that time.
In addition to existence samples, auditors will also randomly select a number of assets for completeness testing. In these instances, auditors will record the nomenclature, national stock number (NSN), serial number, and manufacture date from the data plate and compare to the information recorded in the APSR. Once a completeness sample is selected, units have five duty days to upload supporting documents in AART (it is recommended that documentation be uploaded as soon as possible to avoid late submissions). The auditors determine the required documentation and provide a detailed checklist prior to arrival. Historically, the required documentation has been as follows:
- DA Form 3161 (Request for Issue or Turn-In)
- DD Form 1348 (Issue Release/Receipt Document)
- DD Form 1149 (Requisition and Invoice/Shipping Document)
- Completed forms should include all relevant information
Note: This list changes from one fiscal year to another as auditors gain a better understanding of Army GE business processes.
If an existence sample has been laterally transferred or turned in, units will provide:
- GCSS-Army screenshots showing the asset is now on the gaining unit’s Property Book Officer’s Workbench indicating ownership
- Primary hand receipts displaying the asset is now on the gaining unit’s Primary Hand Receipt indicating ownership
If the asset is deployed, units will prove existence through alternate means. This varies from year to year.
Outcomes and Trends
Audit visits have shown several trends we must address before the Army can achieve a clean audit opinion. First, serial number and NSN errors have been one of the Army’s greatest challenges. It is critical that unit commanders actually check the information on the asset, such as serial numbers and NSNs, when they conduct routine inventories to ensure the numbers match what is shown on the unit’s property book. Department of the Army Pamphlet 710-2-1, Using Unit Supply System (Manual Procedures), chapter 9, provides detailed guidance; but in general, leaders should confirm data is correct when:
- A Supply Support Activity or a program manager issues a serial numbered item
- Serial numbered items are laterally transferred
- Equipment is issued on a hand receipt or sub-hand receipt
- Conducting inventories
- PBOs change and there is unissued property
- Filling out maintenance management forms and records
- Adding equipment to maintenance automated systems
- When unit commanders change command
If the commander or hand receipt holder identifies errors, the PBO will conduct causative research and execute an Administrative Adjustment Report for obvious errors in accordance with Army Regulation 710-2, Supply Policy Below the National Level. If the error involves more than two characters, a sensitive item serial number, or indicates a loss or substitution of any item then an investigation must be initiated and proper adjustment actions taken in accordance with AR 735-5, Property Accountability Policies.
Secondly, System of Systems has created challenges for units and auditors. There have been instances where each piece of the system has a data plate with a NSN and serial number, but no data plate for the entire system. Army Materiel Command has developed procedures to follow for System of Systems with a true serial number listed in GCSS-Army (not a GCSS-Army equipment number) but missing the ‘parent’ data plate captured.
Check the appropriate technical manual (TM) to confirm the data plate has a NSN and is authorized to be ordered at field level. If the unit is authorized to directly order the data plate, they can place an order for the new plate through normal supply channels and replace data plate IAW guidance found in the TM.
If the unit is not authorized to order the data plate, the PBO will:
- Query the NSN in the Federal Logistics Information System to determine the source of supply (SOS) code and which Life Cycle Management Command (LCMC) manages the item
- Contact the local Logistics Assistance Representative (LAR) to order the new data plate.
- Provide the LAR with the following data: “Parent” end item serial number; parent Unique Item Identifier (UII); Noun; NSN; and LIN.
The LAR will contact the appropriate LCMC to receive guidance on how to replace the missing data plate and then pass this information back to the PBO.
The PBO and/or unit should compare the data on the issue document to what is shown in the APSR when the data plate arrives. The new data plate should also have a UII. Once verification is complete, the new data plate should be affixed to the main asset of the system, avoiding attachment to parts that can be easily removed or later detached and turned in separate of the system. For example, if you have a system comprised of several boxes filled with individual components, affix the system data plate to one of the boxes. Individual components can be turned in or replaced while the box remains at the unit. Affixing the new data plate aids units in ensuring audit readiness for that asset and assists in showing the auditors the correct data plate for the system in a timely manner.
Lastly, units have found it difficult to submit complete documentation on time to prove they “own” assets. Supporting documentation should be loaded into AART to prove existence or completeness within five days of the asset being selected. One common mistake units have made was waiting until the week of the audit to upload their documentation. Instead, units should start gathering documents and upload them as soon as they receive the sample lists. Command oversight of entries into AART are important to ensure the correct documentation has been uploaded.
Annual audits are here to stay. It is smart for units to understand the process and prepare ahead of time. Much of the required preparation simply requires commanders to comply with, and enforce, existing Army policies for CSDP.