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QUALITY AND COMPARABILITY OF DATA v..- When providing data to the public, every effort should be made to ensure that the data is accurate and reliable. However, UCOA project reporting provisions ensure that just the opposite will occur; there will be no attempt to validate any of the data before it is posted for public viewing. This results in a high risk that the data will be inaccurate, invalid or incomplete. Reasons for this can include anything from innocent mistakes, such as misclassification of expenditures or improper cutoff, to the intentional misstatement of amounts being reported. Another issue that will have to be overcome is that government financial system users have a tendency to expense funds where the budget is located. Because it is impractical to budget at the same low level of detail as proposed for reporting by the UCOA project, it will be a challenge to make sure that expenditures are posted to the correct cost objects. This will result in either the establishment of more costly internal controls to ensure that expenditures are properly coded or, more likely in a time of scarce resources, it will result in no additional controls being established, thus increasing the risk that the data will be unreliable. Additionally, because there will be no validation of the data submitted to the state, the information presented must be disclaimed as unaudited and tell the user of the information that the state is taking no responsibility for the data that they are disseminating. Responsibility and accountability go hand in hand, and this lack of taking responsibility for the integrity of the data by the state is counterproductive to the goal of promoting transparency and accountability. In fact, it perpetuates one of the most negative stereotypes that governments have to overcome, which is the lack of taking responsibility and for holding people accountable. Further,transparency, while a worthy goal, is only valuable when the public perceives that it can get a true picture of what is going on. We question how this proposed data dump of information on the public will promote any positive perception of government. Another goal of the project is to promote comparability across government organizations. While creating a uniform chart of accounts is a necessary component of comparability, unless all organizations use the same basis of accounting,a ,NOW chart of accounts in and of itself will not result in the goal of achieving comparability across all government agencies. There are vast differences between the various bases of accounting. Take, for example, the purchase of a fixed asset. Both the cash basis and the modified accrual bases of accounting recognize the purchase of fixed assets as expenditures. However, even though the transaction represents an expenditure under both bases, comparability may still be compromised as a result of the timing of the recognition of that expenditure. The cash basis of accounting recognizes the expenditure when the cash is disbursed versus the modified accrual basis of accounting recognizing the expenditure when it is incurred. Adding to the confusion, the purchase of a fixed asset using full accrual accounting isn't an expense at all; instead, it is recorded on the balance sheet with the purchase price being depreciated over the useful life of the asset. As this example illustrates, the differences in the bases of accounting between organizations severely impacts comparability between reporting organizations. Further, organizations using the same basis of accounting are allowed to establish policies that could impair comparability between organizations. For example, GAAP allows an organization using the full accrual basis of accounting to choose its own threshold for capitalization of certain classes of assets. Let's assume that the threshold of capitalizing capital assets for one government is$100,000 and the threshold for another government is$1 million (as per the State of Florida). For a capital asset costing $90,000, both organizations would reflect the transactions as an expense. For a capital asset costing $500,000, the first organization would capitalize the cost and amortize it over time, while the second organization would expense the entire amount in the year of acquisition. Therefore, there are obstacles to comparability even between entities using the same basis of accounting. In addition, the Florida Department of Financial Services has indicated that it will be left up to each county to decide if they will report collectively with their constitutional officers or whether the constitutional officers will report separately. w 9 91