SFFAS 49, Public-Private Partnerships, Implementation
FASAB Contact: Domenic N. Savini, savinid@fasab.gov, 202-512-6841
Project Objective
FASAB issued SFFAS 49, Public-Private Partnerships, on April 27, 2016, and concluded the first phase of the project. The second phase of the project will address measurement and recognition of P3s. Based on the staff’s work with the P3 task force, the Board agreed to develop implementation guidance in the form of a technical release to assist preparers and auditors with implementing and complying with the SFFAS 49 disclosure requirements.
Project History
November 20, 2024
At the November 20 meeting, the Accounting and Auditing Policy Committee (AAPC or “the Committee) reviewed a revised draft Technical Release.
Some key revisions include
- providing a broad principle for dealing with the overlap of public-private partnership disclosure requirements with reporting and disclosure requirements of other standards;
- enhancing the guidance related to the coordination of disclosures due to other requirements;
- proposing that under consolidation accounting, the reporting entity is treated as a single economic entity and, thus, SFFAS 49, Public-Private Partnerships, disclosures would not apply; and
- adding an appendix that includes the side-by-side disclosure requirements for SFFAS 49, SFFAS 47, Reporting Entity, and SFFAS 54, Leases.
Members suggested improvements to several areas of the document and the AAPC chair stated that staff would begin moving towards a draft pre-ballot to be shared with the Committee once all edits and revisions have been addressed by staff.
Briefing Materials – Topic A
August 1, 2024
At the August 1 meeting, the Committee reviewed a draft Technical Release document
and suggested improvements to (1) the flowchart when addressing consolidated
entities that also meet the SFFAS 49 P3 definition and (2) the proposed question and
answer concerning alignment of disclosures considering that SFFAS 49 is a
supplemental Statement. The AAPC chair moved to further discuss the draft P3
implementation guidance at a future meeting. In the meantime, staff will (1) work with
members to make the updates suggested during the meeting and (2) consider if some
issues identified by the task force are better suited for Board deliberations (that is, the
issuance of level A or B GAAP guidance).
Briefing Materials – “Topic B
May 8, 2024
On May 8th, staff, along with several task force members briefed the AAPC regarding the Board’s decision to issue implementation guidance in the form of a Technical Release.
Specifically, the proposed questions and answers and flowchart were presented for review. The following key AAPC comments were made:
- Misconceptions regarding materiality may be contributing to presumptions of under- reporting. The Board approved addressing remote risk and materiality through training and outreach given the complexity in assessing risk and the Board’s long-standing practice concerning materiality.
- Removing the case studies and treating them as educational materials not only simplifies the draft guidance but avoids an inappropriate reliance on complex illustrations.
- It’s difficult to say that an entity has captured all of its P3s because program personnel are dealing with public-private partnerships that the financial personnel are unaware exist.
- Financial reporting should build bridges to program managers who have more of an understanding as to the agreements existing with private industry. Different definitions for P3s exist and the draft guidance will assist preparers in identifying the types of agreements that meet the SFFAS 49 criteria.
- Risk to the federal government may not be reported because of the FASAB P3 definition or application of the risk-based characteristics, or materiality. Remote risks may be best reported in RSI. P3 risks are not limited to financial risks, but entities also share reputational risks and programmatic risks. Risks should be reviewed wholistically and not isolated to the conclusive or suggestive characteristics.
- Usefulness of current disclosures to users should be considered. The draft guidance will be helpful addressing implementation issues even concerning leases.
- The Board’s approach concerning harmonizing SFFAS 49 to SFFAS 47 requires greater clarity in the draft guidance via additional Q&As.
- In some cases, auditors are issuing notice of findings and recommendations (NFRs) regarding measurement and recognition matters.
- Ascertain if any of the SFFAS 49 reporting requirements could be treated as a contingent liability.
At the conclusion of the discussion, staff summarized its next steps with which the Committee generally agreed. Staff will work with the AAPC to (1) further develop and explain the flowchart instructions (e.g., adopting a waterfall approach); (2) include additional Q&As concerning what we mean by harmonization; (3) incorporate an exposure draft question for respondents concerning continent liabilities guidance and its relationship to SFFAS 49.