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DEFERRED MAINTENANCE REPORTING FOR FEDERAL FACILITIES: Meeting the Requirements of Federal Accounting Standards Advisory Board Standard Number 6, as Amended
1
Introduction
BACKGROUND
The approximately 500,000 facilities and associated infrastructure owned by the federal government constitute a portfolio of significant durable public assets that reflect the investment of more than 300 billion tax dollars (NRC, 1998). Ownership of facilities by the federal government carries with it an obligation to act responsibly and to ensure that resources are allocated effectively to sustain that investment.
Buildings, or facilities, are complex structures with a number of separate but interrelated components, including walls, roofs, windows/doors, and critical servicing systems such as mechanical, electrical, plumbing, heating, air conditioning, ventilation, communication, and fire safety, among others. Components and systems must perform well individually and in combination with others to optimize the performance of facilities.
Inevitably, over time the performance of facilities declines due to aging and wear and tear of components and systems, functional changes, and a variety of other factors. The life of facilities can be optimized, however, through adequate and timely maintenance and repairs. Conversely, delaying or deferring maintenance and repairs can, in the short term, diminish the quality of building services and, in the long term, lead to shortened building life and reduced asset value (APWA, 1992). This concept is illustrated in Figure 1.1 .
Deferring needed maintenance indefinitely may ultimately result in significantly higher costs. For example, the steel cladding on a warehouse needs to be painted at scheduled intervals. If the painting, a relatively minor cost, is deferred continually, the cladding will eventually rust and deteriorate, necessitating significant repairs or replacement, at many times the cost of having painted it on schedule.
Apart from Federal Accounting Standards Advisory Board (FASAB) Standard Number 6, as amended, deferred maintenance 1 has been defined by the Urban Institute (1994) as “the extent of maintenance, repair, rehabilitation, etc., that is needed to bring capital assets from a sub-par condition to needed service levels”. Generally it can be
1
Deferred maintenance is also known as unfunded maintenance, backlog of maintenance and repair, or unaccomplished maintenance.
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DEFERRED MAINTENANCE REPORTING FOR FEDERAL FACILITIES: Meeting the Requirements of Federal Accounting Standards Advisory Board Standard Number 6, as Amended
1
Introduction
BACKGROUND
The approximately 500,000 facilities and associated infrastructure owned by the federal government constitute a portfolio of significant durable public assets that reflect the investment of more than 300 billion tax dollars (NRC, 1998). Ownership of facilities by the federal government carries with it an obligation to act responsibly and to ensure that resources are allocated effectively to sustain that investment.
Buildings, or facilities, are complex structures with a number of separate but interrelated components, including walls, roofs, windows/doors, and critical servicing systems such as mechanical, electrical, plumbing, heating, air conditioning, ventilation, communication, and fire safety, among others. Components and systems must perform well individually and in combination with others to optimize the performance of facilities.
Inevitably, over time the performance of facilities declines due to aging and wear and tear of components and systems, functional changes, and a variety of other factors. The life of facilities can be optimized, however, through adequate and timely maintenance and repairs. Conversely, delaying or deferring maintenance and repairs can, in the short term, diminish the quality of building services and, in the long term, lead to shortened building life and reduced asset value (APWA, 1992). This concept is illustrated in Figure 1.1 .
Deferring needed maintenance indefinitely may ultimately result in significantly higher costs. For example, the steel cladding on a warehouse needs to be painted at scheduled intervals. If the painting, a relatively minor cost, is deferred continually, the cladding will eventually rust and deteriorate, necessitating significant repairs or replacement, at many times the cost of having painted it on schedule.
Apart from Federal Accounting Standards Advisory Board (FASAB) Standard Number 6, as amended, deferred maintenance 1 has been defined by the Urban Institute (1994) as “the extent of maintenance, repair, rehabilitation, etc., that is needed to bring capital assets from a sub-par condition to needed service levels”. Generally it can be
1
Deferred maintenance is also known as unfunded maintenance, backlog of maintenance and repair, or unaccomplished maintenance.
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quantified as the estimated cost of the maintenance and repairs needed to bring a facility up to a minimum acceptable condition (NRC, 1998). The existence of deferred maintenance is significant in that it implies that the quality and reliability of service provided by infrastructure on which maintenance has been deferred are lower than they should be, and thus the infrastructure is not, or will not later be, adequately serving the public (The Urban Institute, 1994).
Figure 1.1 Effect of adequate and timely maintenance and repairs on the service life of a building. Source: NRC (1993).
FACILITIES MAINTENANCE AND REPAIR PROGRAMS
The appropriate level of maintenance and repairs expenditures for facilities can be influenced by many factors, including building size and complexity; types of finishes; current age and condition; mechanical and electrical system technologies; historic or community value; types of occupants or users; climate; tenancy turnover rates; criticality of role or function; labor, energy, and materials prices; and distances between buildings in inventories (NRC, 1990). An effective program for facilities maintenance and repair employs a combination of strategies and approaches. These include preventive maintenance, programmed major maintenance, predictive testing and inspection, routine repairs, service calls, and run-to-failure (FFC, 1996).
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Preventive maintenance has been defined as the planned scheduled periodic inspection, adjustment, cleaning, lubrication, parts replacement, and minor repair of equipment and systems for which a specific operator is not assigned (FFC, 1996). It consists of many checkpoint activities on items that, if disabled, would interfere with an essential installation operation, endanger life or property, or involve high cost or long lead time for replacement.
Programmed major maintenance includes those maintenance tasks that are planned to occur on a multiyear cycle, such as every three or five years. Examples include painting, roof maintenance, road and parking lot maintenance, and utility system maintenance.
Predictive testing and inspection refers to activities that involve the use of specialized tests, such as ultrasonic testing, infrared thermography, vibration analysis, and lubricant and wear particle analysis, to identify maintenance requirements (FFC, 1996).
Routine repairs and replacements include actions taken to restore a system or component to its original capacity. The need to replace an item or system may arise from obsolescence, cumulative effects of wear and tear, premature service failure, or destruction by fire and other hazards (NRC, 1990). Replacements do not significantly increase the capacity of the item involved and would be considered routine repairs if they are required for the continued operation of a facility (FFC, 1996). Service calls include requests for system or equipment repairs that are unscheduled and unanticipated. They are generally received when a system or component has failed.
Systems or components not included in a preventive maintenance program are candidates for run-to-failure repair (unplanned), programmed major maintenance (planned), or planned maintenance and repair based on condition and need. Typically, components included in a run-to-failure strategy are small noncritical components that can be repaired or replaced on a service call (FFC, 1996).
REASONS FOR DEFERRING MAINTENANCE AND REPAIRS
Maintenance and repairs for federal facilities are deferred for many reasons. These issues have been documented in the report Stewardship of Federal Facilities: A Proactive Strategy for Managing the Nation's Public Assets (NRC, 1998). They include:
A focus on design and construction costs, the so-called first costs of facilities ownership, as opposed to life-cycle costs, in the federal budget process.
Inadequate funding for maintenance and repairs.
Aging facilities that require increased levels of maintenance and repair to keep them operating effectively.
Lack of information that would assist facilities program managers in making compelling arguments for maintenance and repair budgets to decision makers.
Lack of accountability for stewardship. 2
2
See Appendix A for excerpts from the Stewardship of Federal Facilities report.
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As of 1998, the cost to substantially reduce total deferred maintenance for federal facilities was estimated to be in the tens of billions of dollars. 3
In the past, public officials have called into question the methodologies that federal agencies used to define building deficiencies and to calculate the costs involved in repairing them. Officials have also expressed concern that agencies included inappropriate items in the maintenance backlog to increase the overall estimate and argue for larger budget appropriations (NRC, 1998).
Several causes have been noted for these concerns. First, prior to 1996, there was no government-wide requirement to report deferred maintenance. Thus, the responsibility for developing methodologies fell to individual agencies. FASAB Standard Number 6, as amended, seeks to address this issue. Second, fundamental differences exist among accounting structures used to track expenditures for maintenance and repairs from agency to agency. These differences influence maintenance and repair practices and how deferred maintenance is quantified. For example, the General Services Administration (GSA) uses two accounts: Operations and Maintenance and Repairs and Alterations. GSA's Operations and Maintenance account includes operations, maintenance, and maintenance repairs (up to a certain dollar threshold), and the Repairs and Alterations account includes all repairs, replacements, improvements, and alterations in excess of a certain dollar threshold with no upper limit.
At the National Institutes of Health (NIH), the various institutes are assessed a given amount each year to cover the cost of maintenance by government personnel and minor repairs by contractors. NIH also receives a direct appropriation from Congress as part of the Building and Facilities Budget to cover major repairs and improvements by contractors. The Smithsonian Institution has three categories of maintenance and repair accounts, the State Department has four. The National Aeronautics and Space Administration (NASA) is funded for human space flight, science and technology, and mission support; major programs in the agency fund field installation activities, including maintenance and repair (FFC, 1996; NRC, 1998).
An example from the University of Virginia (UVA) illustrates how accounting structures can influence facilities maintenance and repair practices. Prior to 1996, if a UVA facility had a malfunctioning sprinkler system it could be identified as a deficiency, and maintenance funds could be used to repair it. However, if a facility had no sprinkler system yet needed one, it could not be paid for from maintenance funds and therefore could not be identified as a deficiency, an “all-to-common scenario [which] made for a dramatically inaccurate backlog total and campuswide FCI [facilities condition index]” (Syme and Oschrin, 1996). Similar scenarios arise in federal agencies and can lead to substantial differences in calculating dollar amounts of deferred maintenance for facilities.
Third, there are no government-wide standards for determining items that are appropriately included in maintenance and repair budgets/accounts. This stems in part from the accounting systems and from overlaps and gray areas of maintenance and repair work, operations, and alteration projects. For example, some government facilities
3
FFC sponsor agencies reported in their 1998 accountability reports the following deferred maintenance amounts: Department of Energy, $927 million; Department of the Interior, $7 billion to $16 billion; Department of State, $155 million; NASA, $1.4 billion; Department of Defense, $37 billion; Indian Health Service, $438 million.
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include a central utility plant that is staffed 24 hours a day, 365 days per year. Staff at these facilities ordinarily perform maintenance as a routine part of operations. Agencies must decide if any portion of the operations funding will be included in the maintenance and repair budget. These amounts are not trivial when multiplied over hundreds or even thousands of facilities. The Federal Facilities Council (1996) report Budgeting for Facilities Maintenance and Repair Activities and the NRC (1998) report, Stewardship of Federal Facilities: A Proactive Strategy for Managing the Nation's Public Assets both address items that are appropriately included in maintenance and repair budgets and those that are related to operations, alterations, and capital improvements.
OTHER STANDARDS IN EFFECT
Some agencies need to meet other standards that may be in conflict with or raise other issues for complying with FASAB Standard Number 6, as amended, for deferred maintenance reporting for facilities.
Agencies that operate hospitals, medical centers, or other health care organizations must be accredited by the Joint Commission for Accreditation of Healthcare Organizations (JCAHO) or the Health Care Finance Administration as a requirement to receive federal payments or by federal policy as is the case for federal health care providers. Both organizations require rigorous maintenance programs and accomplish onsite inspection as well as review of maintenance records. Agencies subject to these standards include the Department of Veterans Affairs, NIH, and several defense organizations.
The JCAHO standards lead health care organizations to include building systems in a larger category of utility systems and to determine their criticality to the organization's mission. The organization inventories each utility system's components, analyzes each components ' maintenance needs, and develops a maintenance program including scheduling, documentation, and review of their maintenance. Utility systems considered critical to a health care organization's mission must be maintained and must operate reliably to meet accreditation standards.
The power marketing administrations (PMAs) of the Department of Energy (i.e., Bonneville PMA, Southwestern PMA, Western PMA, and Southeastern PMA) are regulated to industry standards by regional utility commissions. The condition of the physical assets must meet specific criteria related to safety and reliability of operations. In meeting these standards the PMAs are not permitted to defer any maintenance.
Although all government agencies may not have to submit to the rigor of specific standards developed by accrediting agencies, mission requirements involving continuous 24 hours per day, 7 days per week, 365 days per year use, such as that found in operations centers, emergency response facilities, and air traffic control centers, may require a more rigorous standard, set by statute or by the responsible agency, that will not permit the facility to operate unless operations and maintenance are fully funded.
To meet accreditation or other standards, federal agencies may find it necessary to invest a significant portion of maintenance and repair budgets into specific types of facilities and to defer needed maintenance and repair at other facilities not subject to such standards. When considering any modifications to the reporting requirements of FASAB
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Standard Number 6, it is important to recognize that some, if not all, federal agencies must meet other internal and external regulations and statutes that directly influence how maintenance and repair funds are to be expended.
FEDERAL FINANCIAL ACCOUNTING
Since 1990 a number of laws and regulations have been enacted with the general objectives of providing greater accountability by the federal government to its citizens. 4 One such measure is FASAB Standard Number 6, Accounting for Property, Plant, and Equipment. Enacted in 1996, Standard Number 6, as amended, is the first government-wide initiative requiring federal agencies to report on deferred maintenance as part of their annual financial reporting statements.
The FASAB is responsible for developing accounting standards to enhance the financial information reported by the federal government, wherein “federal financial reporting helps to fulfill the government's duty to manage programs economically, efficiently, and effectively and to be publicly accountable” (FASAB, 1993). The FASAB has identified four objectives of federal financial reporting:
budgetary integrity, providing information on the status of budgetary resources, including how budgetary resources have been obtained and used;
operating performance, addressing the costs of providing specific programs, the efficiency and effectiveness of the government's management of its assets, and the efforts associated with federal programs;
stewardship, identifying if the government's financial position improved or deteriorated over the period, if future budgetary resources will be sufficient to sustain public services and meet obligations, and if the government's operations have contributed to the nation's current and future well-being;
systems and control, providing information on whether transactions are executed in accordance with budgetary and financial laws and requirements, if assets are properly safeguarded to deter waste, fraud, and abuse, and that performance measurement information is adequately supported (FASAB, 1993).
FASAB STANDARD NUMBER 6, AS AMENDED
The FASAB has established standards for federal agencies to follow to meet the objectives of federal financial reporting. FASAB Standard Number 6 5 is designed to meet objectives for operating performance and stewardship. To meet operating performance objectives, the FASAB has provided accounting standards intended to result in “relevant and reliable cost information for decision-making by internal users (e.g., program
4
These include the Chief Financial Officers Act of 1990, the Government Performance and Results Act of 1993, and the Government Management Reform Act of 1994, which incorporates the Federal Financial Management Act of 1994.
5
Excerpts from FASAB Standard Number 6 are contained in Appendix B. Appendix C contains amendments to Standard Number 6.
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managers, budget examiners, and officials); comprehensive, comparable cost information for decision-making and program evaluation by Congress and the public; and information to help assess the efficiency and effectiveness of asset management (e.g., condition of assets including deferred maintenance)” (FASAB, 1996). The standard also establishes accounting standards that seek to meet the stewardship objectives by requiring information on asset condition; changes in the amount and service potential of PP&E; the cost of PP&E, where applicable; and spending for acquisition of PP&E versus noncapital spending (FASAB, 1996).
Standard Number 6 seeks to provide information on asset condition by requiring agencies to report on deferred maintenance. The standard (FASAB, 1996) defines maintenance as:
the act of keeping fixed assets in acceptable condition. It includes preventive maintenance, normal repairs, replacement of parts and structural components, and other activities needed to preserve the asset so that it continues to provide acceptable services and achieves its expected life. Maintenance excludes activities aimed at expanding the capacity of an asset or otherwise upgrading it to serve needs different from, or significantly greater than, those originally intended.
Deferred maintenance is defined by FASAB as “maintenance that was not performed when it should have been or was scheduled to be and which, therefore, is put off or delayed for a future period” (FASAB, 1996).
Standard Number 6, as amended, acknowledges that facilities may differ as to the level of acceptable condition and that this level may vary across and within agencies; therefore, the standard allows facility management to determine the condition rating. Under the standard, management may estimate the amount of deferred maintenance for its agency through condition assessment surveys, a total life cycle cost method or other methods that are similar or identical to condition assessment surveys or total life-cycle cost.
To comply with FASAB Standard Number 6, as amended, federal agencies must include the following as required supplementary information for all PP&E in their annual financial reports:
Each major class of asset for which maintenance has been deferred . The standard states that major classes of assets are to be determined by the agency. Examples of major classes of assets are buildings and structures, furniture and fixtures, equipment, vehicles, and land.
The method by which the agency measured the deferred maintenance for each class of PP&E. If the agency has chosen to measure its deferred maintenance by using a condition assessment survey, it should present for each major class of PP&E:
a description of the requirements or standards for acceptable operating condition.
any changes in the condition requirements or standards.
asset condition and a range or point estimate of the dollar amount of maintenance needed to return it to its acceptable operating condition.
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Examples of condition information are averages of standardized condition rating codes; percentage of assets above, at, or below acceptable condition; or narrative information.
If the agency chooses to use the total life-cycle cost method, it should include the following for each major class of PP&E:
the original date of the maintenance forecast and an explanation for any changes to the forecast.
prior-year balance of the cumulative deferred maintenance amount.
the dollar amount of maintenance that was defined by the professionals who designed, built, or manage the PP&E as required maintenance for the reporting period.
the dollar amount of maintenance actually performed during the period.
difference between the forecast and actual maintenance.
any adjustments to the scheduled amounts deemed necessary by the managers of the PP&E.
the ending cumulative balance for the reporting period for each major class of asset experiencing deferred maintenance.
The standard states that agencies may provide as optional information the stratification between critical and noncritical amounts of maintenance needed to return each major class of asset to its acceptable operating condition. If management elects to report this information, management 's definitions of critical and noncritical maintenance must be included; Standard Number 6, as amended, does not provide definitions for critical or noncritical maintenance.
STUDY ORIGIN
The FASAB, 6 the entity that created Standard Number 6, has determined that information about deferred maintenance is of importance to users of federal financial reports and for measuring an agency's effectiveness and efficiency in managing PP&E. Recognizing that this is a new standard, specifically with regard to deferred maintenance reporting, the FASAB believed that a period of experimentation was desirable to determine the best methods to report deferred maintenance. Experience to date with implementing the standard has raised concerns by both agencies and auditors regarding the number of different interpretations of the standard, as well as cost-benefit and audit issues. The FASAB and the Office of Management and Budget (OMB) suggested that an interagency project be initiated to suggest government-wide methods to calculate
6
State and local government agencies are held accountable to accounting standards and principles established by the Governmental Accounting Standards Board. Its mission is to establish and improve standards of state and local governmental accounting and financial reporting that will result in useful information for users of financial reports and guide and educate the public, including issuers, auditors, and users of those financial reports.
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deferred maintenance as well as more detailed guidance on the preparation of deferred maintenance estimates.
In January 1999 the Federal Facilities Council (FFC) Standing Committee on Operations and Maintenance began discussing and reviewing issues of deferred maintenance reporting for facilities to meet FASAB Standard Number 6, as amended. In the summer of 1999 the Chief Financial Officers (CFO) Council initiated an interagency effort led by the Department of Defense (DoD) to review deferred maintenance reporting for real and personal property, national defense PP&E, heritage assets, and stewardship land. Because the efforts of the FFC Operations and Maintenance Committee and the CFO Council/DoD shared some common objectives, it was determined that the FFC Operations and Maintenance Committee, supplemented by staff from other federal agencies and supported by the DoD, would provide technical assistance for the interagency effort as it relates to deferred maintenance reporting for facilities (real property) and FASAB Standard Number 6, as amended.
STUDY OBJECTIVES
The work of the FFC Standing Committee on Operations and Maintenance and this report focused on fulfilling two primary objectives. The first is to identify issues related to the reporting of deferred maintenance for facilities as required by FASAB Standard Number 6, as amended. The second objective is to identify for consideration potential approaches to reporting deferred maintenance for facilities that (a) will have credibility within the facilities community, federal agencies, and Congress; (b) can be used to track trends within and across agencies; and (c) do not require an inordinate investment of time and resources to implement.
The FFC Standing Committee on Operations and Maintenance has prepared this report to identify potential issues that should be considered in any future amendments to the standard and to suggest approaches for resolving them. The committee's intent is to assist the CFO Council, federal agencies, the FASAB, and others as they consider how best to meet the objectives of federal financial reporting for facilities. It is important to note that the FFC Standing Committee on Operations and Maintenance has not made any recommendations for reporting deferred maintenance for facilities or advocated specific positions.
STUDY METHOD
The sponsor agencies of the FFC approved the study in September 1999 as a high-priority item for the calendar year 2000 Technical Activities Program. The committee met 10 times between September 1999 and September 2000. Incorporated into the study was information obtained from FFC Operations and Maintenance Committee agencies' facilities managers and personnel. Additional information was compiled from facilities management literature.
Norwood Jackson, formerly of the FASAB, met with the committee to discuss FASAB Standard Number 6, as amended, and to clarify issues that were of importance to the committee and to the completion of this study. Jay Janke, Office of the Secretary of
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Defense (Installations), met with the committee to present and discuss the DoD Facilities Sustainment Model. The final draft of the report was reviewed by the FFC Operations and Maintenance Committee, other participants in the study, and the senior representatives of the FFC sponsor agencies.
REPORT ORGANIZATION
Chapter 2 identifies issues related to definitions and some potential revisions for consideration. Chapter 3 discusses issues related to the methodologies specified in FASAB Standard Number 6 for reporting deferred maintenance as they relate to facilities and identifies other valid approaches that could be used. Chapter 4 identifies issues related to the use of deferred maintenance as an indicator of facility condition and potential approaches for increasing its utility.
Appendix A contains excerpts from the report Stewardship of Federal Facilities: A Proactive Strategy for Managing the Nation's Public Assets. Excerpts from FASAB Standard Number 6, and the amendments to FASAB Standard Number 6, are contained in Appendixe B and Appendixe C , respectively.
REFERENCES
APWA (American Public Works Association). 1992. Plan. Predict. Prevent. How to Reinvest in Public Buildings. Special Report #62. Chicago : APWA.
FASAB (Federal Accounting Standards Advisory Board). 1993. Objectives of Federal Financial Reporting. Statement of Federal Financial Accounting Concepts, Number 1. Online: www.financenet.gov/financenet/fed/fasab/pdf/sffac-1.pdf .
FASAB. 1996. Accounting for Property, Plant, and Equipment. Statement of Recommended Accounting Standards, Number 6. Online: http://www.financenet.gov/financenet/fed/fasab/concepts.htm .
FFC (Federal Facilities Council). 1996. Budgeting for Facilities Maintenance and Repair Activities. Washington, D.C. : National Academy Press.
NRC (National Research Council). 1990. Committing to the Cost of Ownership: Maintenance and Repair of Public Buildings. Building Research Board. Washington, D.C. : National Academy Press.
NRC. 1993. The Fourth Dimension in Building: Strategies for Minimizing Obsolescence. Building Research Board. Washington, D.C. : National Academy Press.
NRC. 1998. Stewardship of Federal Facilities. A Proactive Strategy for Managing the Nation's Public Assets. Board on Infrastructure and the Constructed Environment. Washington, D.C. : National Academy Press.
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Syme, Preston T. , and Jay Oschrin. 1996. How to Inspect Your Facilities and Still Have Money Left to Repair Them. Alexandria, VA : Association of Higher Education Facilities Officers (APPA).
The Urban Institute. 1994. Issues in Deferred Maintenance: The Federal Infrastructure Strategy Program. Alexandria, VA : Institute for Water Resources Publications.
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