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Caroline Aggestam
Copenhagen Business School, Denmark
Danny Chow
Durham University, UK
Ronald Day
University of Sydney, Australia
Raili Pollanen
Carleton University, Canada
1. Introduction
In the last two decades, significant The objective of this study is to survey
developments in public sector the literature on the use of
accounting and accountability systems consolidation in public sector
in OECD countries have culminated in accounting across five countries: the
the implementation and/or UK, Australia, New Zealand (NZ),
consideration of advanced accounting Canada and Sweden. This is the first
ideas such as consolidated accruals- stage of a two-part study that begins to
based public sector accounts. A central explore whether transparency is
idea behind the introduction of currently being achieved and whether
consolidated accounts across the entire essential user information needs are
spectrum of government is to being met. It will provide new insights
encourage greater accountability into the external drivers needed to
through greater transparency of links promote consolidated financial
between government bodies and the reporting by governments.
amalgamation of financial obligations
across the various bodies into one The following chapter summarises the
single figure. key issues from a comparative study
and suggests ideas for future research.
The notion of a single bottom-line The remaining chapters set out the
figure for consolidated public sector historical context of consolidated public
obligations such as debt and another sector accounts reforms in the five
for public sector assets has appeal for countries and present a review of the
promoters of accounting reform, in that literature.
it draws attention to reporting
transparency at a time where the
complexity of government economic
activity has made it difficult to track
what the public sector owns and/or
owes.
4
2. Summary and key findings
‘New Public Management’ (NPM) resources; better information for There is some evidence that the WGAs
reforms, which were popular with a deciding priorities; better allocation of are being reviewed by the National
number of governments in the late resources in accordance with priorities; Audit Office (NAO) and parliamentary
1980s and early 1990s, appear to be a and a better-informed public. In contrast, public accounts committee, but debates
significant driver for accounting reforms it was observed that in practice users, about WGAs’ usefulness persist.
at the macro-level across all five country such as financial markets, credit rating
case studies considered here. The rate agencies and other analysts generally Despite the publication of three years’
at which reforms were implemented make little use of WGAs. worth of UK WGAs, a significant amount
and consolidation boundaries adopted of work is still needed to remove the
for the whole of government accounts New Zealand (NZ) is broadly recognised three consecutive years’ worth of audit
(WGAs) depended upon localised and as the first national government to have qualifications. Disagreements over the
constitutionally driven structures within introduced consolidated public sector boundary of WGAs’ consolidation,
countries. accounts for the whole of central inconsistent asset valuations,
government, coupled with public sector incomplete inter-entity eliminations on
The extension of accruals accounts to reforms, therefore NZ is cited as an consolidation and timeliness of the
consolidation was primarily seen as a exemplar country by organisations such accounts undermine their usefulness.
supplementary exercise and taken-for- as the OECD. While there is some soft
granted addition to the reform of evidence from ministers, members of The implementation of government-
cash-based appropriation or budget- Parliament, chief executives, chief wide consolidated financial statements
centric accounts across most countries. financial officers and operational in Canadian governments has been an
managers that they potentially can invisible incremental process in the
Although a lot of activity and resource obtain benefits from the financial implementation of full accrual accounting.
have been invested into consolidating management and accounting reforms, The government of Canada has been
government accounts, over a there have also been some concerns reluctant to upgrade accounting for
considerable number of years in some about the costs and unidentifiable and appropriations and departmental
cases, there is little known about their unintended consequences of the financial statements to full accrual
usefulness to a broad range of users. reforms. accounting. Consequently, accrual
Where there have been studies these accounting and government-wide
have tended to focus on expected use In the UK, the previous Labour consolidated financial statements are
of WGAs rather than their usefulness for government largely drove the case for not used, or perceived useful, for
a range of users. There is a need for consolidation of accruals-based public managerial planning, decision-making
further research to ask users directly sector accounts. As in both Australia and control purposes. The major use of
about how they use WGAs, how useful and NZ, the literature is limited and government-wide consolidated financial
they are, and what type of information focuses on the use of WGAs rather than statements is accountability reporting
or report users actually require for their usefulness. Three claims were to Parliament.
decision-making and accountability made for WGAs:
purposes. We hope the second stage of The key focus of the Swedish academic
our study will help to address some of • improvements in accountability literature is on the effects of accounting
these questions. would result through greater change on public institutions and how
coverage of the public sector accounting is being used in the public
In Australia the literature on public balance sheet and other GAAP- sector. There is a mixed picture of the
sector consolidation is sparse. It has based financial statements use of accounting information in the
primarily focused on the issue of Swedish public sector. Organisations that
accounting convergence and claims and • accounting information systems rely on central government grants lean
observations about the use. The debate would improve, and towards reporting on an accountability
has focused on what WGAs can offer, as basis. Accruals accounting is less used
opposed to what they have offered. A • macro-economic decision making at the political and planning level as
number of benefits were identified, would be enhanced. budgetary processes are still very much
including increased control over all driven by cash.
This chapter describes the historical report the full costs of programmes or federation and no nationwide
context of consolidated accounting activities required for sound financial consolidation exists. Individual
reforms in all five countries individually, management, performance assessment, consolidated accounts are prepared for
starting with Australia and NZ, which determining budget priorities and the federal (commonwealth)
pioneered the use of GAAP-derived efficient management of operations government, six state governments and
and accruals-based consolidated (Barrett 2004). Treasury officials justified two government territory governments
accounts for the public sector. the calls for reform by using economic- with powers similar to the states.
centric ideas such as public choice Because each jurisdiction is responsible
3.1 AUSTRALIA theory and new institutional economics. for its own reforms, the development,
Christensen (2002, 2005) and Carlin timing and coverage of Whole of
Australia, along with NZ, claims to be a (2005) attribute much of the decision in Government Reports (WGRs) for each
leader in public sector financial reforms New South Wales (NSW) to the of the nine separate government
and at the forefront of pioneering influence of visiting private sector jurisdictions was not uniform, spanning
accrual accounting frameworks and consultants from American-based over 14 years from the first government
reporting technologies, and in professional accounting firms. These jurisdiction to prepare them in 1989
developing government-specific consultants were able to persuade until the last in 2003 (Day 2009; Walker
accounting standards to guide governments to reform by promoting 2011).
reporting in public sector and for themselves as accounting experts and
government (Funnell and Cooper 1998; selling their knowledge and experience The first consolidated WGRs were
Guthrie 1998; Carlin 2005; Day 2009). to governments by ‘offering a ready- produced in 1989 for a New South
Public demands from the mid-1980s made solution of turning the public Wales (NSW) Commission of Audit, and
onwards for more efficient and sector into private sector look-a-likes’ the first fully audited accrual WGR was
responsive provision of government (Laughlin and Pallot 1998: 396). published in 1993. This made NSW a
services was accompanied by a pioneer in developing reports for the
conceptual shift in public administration Accrual accounting and related whole of government, although NZ is
based on the view that the public sector technologies on budgeting and Whole credited as the first sovereign nation to
should be organised more like the of Government Reporting (WGR) was publish full accrual reports in 1992
private sector, a phenomenon referred said to be capable of providing a (Christensen 2003). Other Australian
to as ‘New Public Management’ (NPM) systematic record of the government’s government jurisdictions followed, with
(Hood 1995). As a result, a number of non-cash assets and non-borrowing Western Australia (WA) first preparing
‘NPM’ reforms were introduced that liabilities, as well as better them in 1995 and publishing audited
made sweeping changes to measurement and reporting to reports in 1997; the Commonwealth in
government accounting and reporting, Parliament and the public on the 1996, with published audited report in
and to public sector financial efficiency of cost control, asset and 1998; Victoria (VIC), Queensland (QLD),
management. These changes were liability management, service provision, and South Australia (SA) in 1997 with
underpinned by two major accounting rather than simply on expenditure published audited reports published in
developments from 1994 onwards, compliance with budgets. A unique 1997,1998 and 1999 respectively;
accruals accounting and the feature of the Australian definition of Tasmania (TAS) in 1999 and Northern
consolidation of accruals at a whole of ‘whole of government’ for reporting Territory (NT) in 2003 (Wines and
government level. purposes is that it is based on Scarborough 2006; Day 2009; Walker
jurisdictional rather than national 2011). Barrett (1996: 56) suggests that
Accounting reforms at the government notions of consolidation. In other words, these were decision-useful in that they:
level received wide support because consolidation boundaries reflect the ‘provide one reference source detailing
extant cash-based systems was seen as constitutional borders of individual total government resources and
being easily manipulated, and did not governments within the Australian obligations, allowing governments (and
6
others) to better assess the financial 3.2 NEW ZEALAND public sector. Simpkins (1998) and
position, enabling medium to longer McKinley (2000) identify this as the
term comparisons of major accounting NZ is broadly recognised as the first growing fiscal deficit; a desire for
aggregates’. national government to have greater transparency and accountability
introduced consolidated public sector in the provision of public services;
In addition to Australian Accounting accounts for the whole of central dissatisfaction with centralised input
Standards (AAS) requirements for WGR government, in the form of Crown controls and the dissatisfaction and
preparation and publication, the Financial Statements (Pallot 1994, 1996; frustration of Ministers that the existing
Charter of Budget Honesty Act 1998 Guthrie 1998; Lye 1998; Barrett 2001). system did not provide them with the
also required that a Final Budget The preparation of such consolidated information they needed for making
Outcome Report (FBO Report) present Crown reports is required by the Public decisions.
the budget and General Government Finance Act 1989 (Lye et. al, 2005) and
Sector (GGS) fiscal outcomes for a can be seen as a part of the wider McKinley (2000) notes that the scale of
financial year, and that these be based revolution in public sector the NZ government made reforms
on external reporting standards with administrative reforms that started in easier to implement. For example,
any departures from these to be the late 1980s. IFAC’s Public Sector differences between the structure of
identified. A Uniform Presentation Committee (now IPSAS board) the NZ government and other
Framework (UPF), was agreed to by the described the reforms as a fundamental Westminster systems, including the
Commonwealth and State/Territory improvement from dysfunctional absence of an upper house, and the
governments in 2000 resulting in the management systems based on compact size of the NZ Parliament,
FBO being presented on an accrual compliance with centralised input enabled the prime minister (who was
Government Finance Statistics (GFS) controls, cash budget appropriations concurrently the finance minister) to
framework developed by the Australian and reports. Instead, the new regime of push through a comprehensive
Bureau of Statistics (ABS 2000) based public sector management operations programme of reform in a short period
on the UN System of National was based on accountability and without significant opposition. The
Accounts(SNA, 93)). However, several responsibility. This was accompanied by support from leaders of the public
governments also provided the FBO extensive reforms to the accounting sector, both politically and within official
reports on a GAAP basis in a dual and reporting of those operations, state functions (e.g. NZ Treasury and
presentation, or highlighted one report including the implementation of full Audit Office), was seen to facilitate the
framework (and aggregates), in accrual accounting and whole of rapid agreement of the need for change
preference to the other, resulting in government reports (Public Sector and its subsequent implementation
confusion by many users (Day, 2011). Committee 1994). (Public Sector Committee 2003).
After the move to the Australian
Accounting Standards Board (AASB) As in Australia, accounting motives The Public Finance Act (1989)
standard 1049 Whole of Government were not seen as the sole driver of represents a central piece of legislation
and General Government Sector financial reporting initiatives but underpinning NZ’s NPM movement and
Financial Reporting in 2009, a constituted part of a programme of subsequent WGR publication. The
converged GFS and AAS (GAAP) public sector management reform legislation removed many of the
framework was used in the WGR and (McCulloch and Ball 1982). According to previous administrative controls
FBO Report presentation. Nonetheless, Simpkins (1998), the main driver for associated with the parliamentary
some concerns were raised in the significant accounting and budgeting appropriation process by implementing
literature on the relevance of various developments was the concern of an an output-based budgetary system that
accounting standard changes for users, incoming government about the focused on accountability of what is
which are discussed in section 4.1 of this perceived scale of inefficiency and produced (outputs) rather than on cash
report. macroeconomic mismanagement in the appropriations to produce it (inputs). It
8
In 1997, the in-coming Labour addition to retaining his historical remit 3.4 CANADA
government proposed, in the UK WGA to audit central government bodies’
scoping study (HM Treasury 1998), to individual accounts, the C&AG’s role Financial management reforms, among
link WGA explicitly to new economic was also significantly expanded by the them government-wide consolidated
policies such as the Code for Fiscal legislation to include new powers, such financial statements prepared on the
Stability. The alignment of WGA with as to audit the overall consolidation of full accrual accounting basis, were part
the Code was presented as a WGA. Nonetheless, existing auditors of wider administrative reform efforts
cornerstone policy that underpinned for non-central government bodies, by the government of Canada. Financial
the new government’s attempts to such as the Audit Commission for local management reform efforts – or at least
repair its past reputation for imprudent government and private sector auditors the associated rhetoric – have been in
macroeconomic policymaking (Chow et for public corporations, retained their progress for decades, dating back to
al. 2007). Three claims were made for existing roles as the primary auditors for the works of the Canada Royal
WGA in the scoping study: improving their respective bodies. Other Commissions on Government
accountability to parliament through stakeholders such as the media, Organization (1962) and on Financial
greater transparency; better economic academia and lay members of the Management and Accountability (1979)
decision making; and enhanced public only had a peripheral role to play (Baker and Rennie 2006; Pollanen and
accounting information systems for the in the governance arrangements as Loiselle-Lapointe 2012). Unlike other
public sector. external observers to the process, and Anglo-Saxon countries, Canadian
thus have had to rely on progress jurisdictions have been extremely slow
In the scoping study, it was envisioned reports provided by bodies monitoring in their adoptions of NPM practices.
that WGA would complement existing the reforms, such as the C&AG and his Furthermore, Canadian adoptions have
accounting information systems in team at the National Audit Office been less extensive than those in other
government, such as the National (NAO), FRAB, parliamentary special Anglo-Saxon countries (Pollitt and
Accounts, by replacing data generated committees such as the Public Accounts Bouckaert 2004).
on a statistical basis with data based on Committee and the Treasury
GAAP accounting principles. The scale Committee, and reports from HM Many reform efforts that were started
of WGA was also significantly expanded Treasury itself. under conservative governments in the
from a central government-only 1980s and early 1990s seem to have
consolidation boundary (CGA) to vanished without significant lasting
include other areas of the public sector outcomes (Pollitt and Bouckaert 2004).
such as local government and public In the late 1990s, under a liberal
corporations. This led HM Treasury government, a more moderate and
(2003, para.3.26) to claim that the UK politically centrist Canadian approach
WGA was the most comprehensive set emerged, and many reforms surviving
of public sector consolidated accounts to date were implemented during the
in the world, as it extended beyond following few years (Ohemeng 2014). As
organisational boundaries such as Canadian federal ministers do not have
central government to the whole public the same level of power to drive major
sector. reforms at the national level as do
ministers in unitary states, such as NZ
The legislation for both WGA and RAB and the UK, Canadian reforms were
(Government Resources and Accounts incremental, stressed sharing and
Act 2000) required the creation of a new cooperation between governments,
body – the Financial Reporting Advisory and often appeared to be loosely
Board (FRAB) – to provide advice on, connected and rather short-lived (Pollitt
and monitor the implementation of and Bouckaert 2004).
accounting standards for WGA. In
10
3.5 SWEDEN Before the move to accruals, public The issue of consolidation is not seen as
sector accounting practices had one that is separate and distinct from
As in most of the countries discussed remained heterogeneous for a long accruals in Sweden. In contrast, the
above, the onset of diffused ideas on time, with governments at each level literature presumes that consolidation is
NPM reforms during late 1980s and (municipality, county and national) seen as a taken-for-granted aspect of
early 1990s was spurred on by domestic developing their own accounting accruals accounts, and one that is
concerns, during the time when Sweden policies and systems (cf. Olson and integral to the implementation of
wanted to shrink the welfare state Sahlin-Andersson 1998). Local accruals at the central level of
(Olson and Sahlin-Andersson 1998). governments have, since 1980, adapted government. The submission of a whole
Unlike the developments in Anglo- corporate accounting systems for their of central government annual report is,
Saxon countries, however, NPM reforms own purposes, working closely with since 1996, stipulated in law (ESV 2001:
in Sweden were not defined by specific academia in this regard. In addition, 27). In a later document, and perhaps
accounting-based initiatives, though academics also played a particularly implicitly referring to the distinct
the country did move to accruals and crucial role in the introduction and consolidated accounts produced in the
introduced consolidation. Another implementation of consolidated UK and other countries, the ESV
unique characteristic of reforms in reporting across government tiers explains that the submission of a
Sweden is that the government has (Svenska Kommunforbundet 1989; consolidated whole of government
always had a close and cooperative Bergevärn et al. 1995; Grossi and annual report was not the aim of the
relationship with academia. Such Tagesson, 2007). reform, but rather a possibility provided
cooperation started in the 1970s, more by the reform (ESV 2013: 21).
than two decades before the adoption At the national level, the Swedish
of accrual accounting in the Swedish government set up a quasi-
public sector. independent body, the National
Financial Management Authority (ESV),
For example, academics Brorström and tasked with the management and
Olson (1985) were directly involved in compilation of financial and statistical
action research (a mixture of consulting data. In addition, the ESV was also
work with government reformers in instrumental in advising the
addition to, or resulting in, academically government on the merits/costs of
oriented research) on developing various accounting reform ideas
accounting models for local disseminated from abroad. In its 2001
government. Brorström and Olson study on accruals accounting in central
(1985) proposed accounting models government of Sweden, it noted that a
that were worked out for two ‘new accounting model makes it
organisational tiers: an accounting possible to monitor performance such
model on a consolidated level and an as total costs of government programs
accounting model at the departmental and activities. It also facilitates the
level. These models were subsequently analysis of more specific information
applied in two local governments in the such as cost per product, etc.’ (ESV
late 1970s. The models developed 2001: 6). ESV also reports that financial
through their work sparked wider management reforms have improved
interest in adapting commercial transparency and control at the central
accounting ideas to the public sector, government level (ESV 2001: 7).
leading to the adoption of accruals Nevertheless, it also highlights that one
accounting by Swedish central of the critical issues remained to be
government in 1993 (Olson and Sahlin- resolved, namely that of the link
Andersson 1998). between the budget and the
accounting.
12
4. Literature review
This section reviews the academic as and Wolnizer 1999; Carnegie and West the quality of reporting, than the choice
well as relevant practitioner literature 2003), and different accountability and of one method or the other. In addition,
on consolidated accounting reforms in constitutional objectives or judgements the directive would impose quite
the public sectors of all five countries. requiring a different approach (see significant compliance costs, with little
Newberry 2003, Robb and Newberry known about the real benefits to public
4.1 AUSTRALIA 2007, Walker 2009). In addition to this, a sector entities and users of the reports
policy of international harmonisation (Kaufman 2004; Barrett 2001; Day and
According to Walker (2009), the and convergence culminated in a Guthrie 2008) . Even after the issue of
literature on public sector consolidation Financial Reporting Council (FRC) AASB 1049, which was meant to result in
accounting and whole of government directive in June 2002 to adopt the use of a comparable converged
reporting is sparse, despite the Australian-equivalent International reporting framework by all government
experience of many governments and Financial Reporting Standards (IFRS) jurisdictions, the Commonwealth
countries in publishing such accounts, from 2005, and consequently to apply government prepared its 2008/9 GGS
including Australian government them also to the public sector using the financial reports in its Budget papers on
jurisdictions. The Australian literature sector-neutral approach. Critics of this a GFS basis, with adjustments where
has mainly focused on two areas: also argue this is inappropriate as IFRS accounting standards provided a better
standards were originally designed for financial alternative (Barton 2011).
• issues of convergence, including a the for-profit sector, and because it According to Kober et al. (2013), ‘the
trend to cohere private and public meant Australia would be pursuing a reluctance to fully commit to this
sector standards and later different pathway from most other standard suggests unresolved issues
government finance statistics (GFS) countries (Day and Guthrie, 2008; and with the appropriateness of AAS for the
and GAAP-based accounting in Day 2011). The FRC and AASB have public sector’.
WGRs; and persisted with this policy despite a
growing trend among countries towards Several commentators have debated
• claims, observations and some adoption of International Public Sector which accrual reporting framework
limited empirical research on the Accounting Standards (IPSAS), and even (GAAP or GFS) is the most useful to
use and usefulness of WGRs. though NZ has abandoned it to set users, most favouring GFS. For
national differential standards, example, Challen and Jeffrey (2003: 49)
Issues of convergence including standards for public sector observe: ‘the most serious users of
Since a new regulatory framework was entities based predominantly on IPSAS. Government financial reports, including
introduced in 2000, several the financial markets, financial
harmonisation and convergence A further convergence issue culminated commentators, ratings agencies, the
strategies have affected WGRs and in a second FRC directive to the AASB Reserve Bank of Australia and the
their users. This first was the in December 2002 to develop a Australian Bureau of Statistics, all focus
convergence of private and public standard that converged GFS and on GFS based reports’. Barrett (2004:
sector standard-setting bodies, GAAP in whole of government (WGR) 16) also suggests that GFS is more
resulting in a single set of standards and general government sector (GGS) applicable for government reporting,
applied to both profit and not-for-profit financial reports. This was an attempt to considering its different nature,
sectors using a sector-neutral approach. end the divergent use of different (cash objectives and purpose, and because it
The literature is mainly critical of this accrual GFS and/or accrual GAAP) had been specifically designed for
approach, with critics arguing that it is reporting frameworks, and reduce user government and to meet its needs for
inappropriate owing to the non- confusion over which reporting economic analysis. Barton (2009 and
identical characteristics and functions framework or aggregate they should 2011) use an analytical methodology to
of the public sector (see Walker 1989; use. At the time of this decision, there outline the role and activities of
Barton 1999, 2002, 2005; Ellwood and was little evidence that a converged government and the information that
Newberry 2006), the unique problems GAAP/GFS was the best option or that should logically be determined by
in measuring certain public sector it would cause greater comparability, these, and concluded that GFS should
transactions and assets (see Carnegie lead to less user confusion, or increase be used for the government’s
14
making, prepared under the CASH, some limited support for the converged 4.2 NEW ZEALAND
accrual GAAP, and accrual GFS bases. approach in AASB 1049.
Their results suggest that in the The public sector reforms in New
situations they examined GAAP-based Summary Zealand have been held out by other
information was mostly meeting public The review of the literature on the countries and institutions, such as the
sector users and preparers’ needs for development of WGRs and normative OECD, as an exemplar for public sector
decision making (Kober et al. 2010: 283), arguments of their use and usefulness reforms from which other countries can
which appears to contradict some indicates that the choice of reporting learn (See Ball 1994; Public Sector
previous observations that indicated a framework for use in WGRs is far from Committee 1994; Canadian Audit Office
preference for GFS. They suggest this resolved or internationally harmonised. 1995, Goldfinch 1998; Simpkins 1998;
may be because those surveyed were In addition, the normative nature and Newberry and Pont-Newby 2009). Even
still using GAAP, so their findings may limited availability of empirical research so, Goldfinch (1998) suggests that
reflect unfamiliarity with GFS, because on the use and usefulness of WGRs and although there is some evidence of
the external users in their survey, with GGS financial reports is, except for significant efficiency gains in the public
more experience with GFS, had far some recent work, inadequate and not sector, it is possible that these have
greater regard for the usefulness of sufficiently focused. There is a need for been oversold. He argues that
GFS, reflecting a ‘learning effect’. A further research to ask users directly of efficiency gains are hard to measure,
limitation of this study is that the survey their use and of the usefulness of WGR and could be partly attributed to other
examined GFS–GAAP harmonisation at and GGS financial reports, and what factors such as improvements in
a government department level, so the type of information or report they compliance, deregulation, technology
results might differ for users and require to meet their needs for decision improvements, and political will.
preparers at WGR level. In addition, making and for accountability purposes.
user perceptions were only sought on Pallot (2001) agrees that assessing any
two accrual frameworks (GAAP and differences in efficiency and
GFS), while the converged GAAP–GFS effectiveness due to the resources and
framework was not measured. Kober et budgeting reforms, even if they could
al. (2013) followed up this with a survey be measured, is difficult because the
of different public sector stakeholders effects cannot be isolated from other
on the appropriate accounting effects of wider economic reforms.
treatment and presentation of selected Nonetheless, she points to:
WGR items as a result of the application
of GFS, GAAP or the converged AASB Soft evidence [through]…a number of
1049 framework. Their results suggest studies by academics, consultants,
that respondent’s perceptions of the central agencies and the Audit office,
presentation of the government’s fiscal government appointed working parties
aggregates are largely consistent with and overseas observers…that]
those adopted by AASB 1049, and managers and politicians, on the whole,
provide support for claims that the share the view that the specification of
standard enhances the usefulness of outputs has been improving
the presentation format. The results progressively with the result that
also showed that respondents had objectives are clearer, expenditure is
different preferences for specific better targeted, and transparency is
accounting treatments of items, and no enhanced…[and] there does not seem
overall preference for GAAP or GFS. to be any support at any level for a
They conclude from this that users return to cash accounting and input
choose the most appropriate treatment controls. (Pallot 2001)
rather than have a preference for either
system, and therefore this provides
16
4.3 UNITED KINGDOM recording assets/liabilities generated Public Accounts Commission (sic), and
from past transactions. his colleague George Georgiou,
In the UK in 1998, the Labour emphasise that the 1998 WGA
government largely drove the case for However, Chow et al.’s review (2007: 34) conception, from a macroeconomic
consolidation of accruals-based public of the pre-1998 literature notes that perspective, was to go beyond the data
sector accounts. Three claims were there are considerable practical in national accounts (ie Figure 4.1) to
made for WGA – improvements in problems with trying to operate such a improve data for macroeconomic policy
accountability through greater balance sheet. Instead, the most recent and fiscal transparency (Heald and
coverage of the public sector balance plans for UK WGA has dropped the Georgiou 2011: 447).
sheet and other GAAP-based financial economic decision-making claim, so
statements, improved accounting much so that the UK’s Public Accounts One of the assumed limitations of a set
information systems, and enhanced Committee, in its review of WGA of accounts modelled as in Figure 4.1 is
macroeconomic decision-making (Chow published for 2010/11, concluded that that the focus on debt measures in
et al. 2007 and 2008; Heald and HM Treasury need to do more to move national accounts leaves out reporting
Georgiou 2009 and 2011). This third WGA from an accounting exercise to on assets (in contrast to Figure 4.2),
claim of macroeconomic potential has one that helps with the management which is important because it highlights
not been made for private sector and reporting of public finances (Public the extent to which assets are being
accounting use of consolidation. Rather, Accounts Committee 2013, para.1, p.5). impaired and need replacing. Past UK
consolidation was historically seen in governments have attempted to tackle
the private sector as a way in which to During the period in which UK WGA debt and deficits by postponing asset
increase the transparency of linkages was developed, a number of important replacement, which has led to a
between groups of companies and conceptual justifications were used to significant deterioration of
allows users to understand a group’s support expanding WGA to include not infrastructure. Heald and Georgiou
net assets and combined profits (for just past but also future liabilities. The (2011) added that WGA also helps to
fuller coverage of history, see Chow et ‘Long Term Reports’, a series of highlight the issues of capital starvation
al. 2007: 42; Walker 2009: 203). publications now discontinued, by bringing to attention the scale of the
provided insights into HM Treasury government’s procurement of assets
Plans to develop a public sector thinking on the boundaries and scope such as schools, hospitals and transport
balance sheet for economic policy of WGA coverage. Figures 4.1, 4.2 and infrastructure through off-balance sheet
considerations did not start with UK 4.3 illustrate proposals for WGA and financing programmes. The effect is to
WGA. Instead, public sector net worth beyond, showing coverage of public move debt from off to on-balance sheet
and other fiscal measures can be traced sector assets and liabilities under through the reporting of high capital
back to debates among UK accountants different accounting systems (all charts interest paid. In addition, the more
and economists in the 1980s (and reproduced from HM Treasury, 2003). complete Figure 4.2 also highlights the
probably further back, given that costs of dealing with an ageing
accountants helped to develop the Figure 4.1 highlights the coverage of population and the funding structure of
UN’s System of Nations Accounts; cf. existing government accounts, while existing pensions and other welfare
Suzuki 2003). These early macro- Figure 4.2 demonstrates the coverage arrangements that are needed to deal
economic ideas have been resurrected of the (then proposed) UK WGA with such change. Before UK WGA,
in the 1998 plans for UK WGA despite balance sheet and Figure 4.3 represents such huge pension liabilities remained
being rejected in the early 1990s projected as well as historical data that off-balance sheet and are hard to find
because the Conservative government economists would ideally like to work and interpret for public users of
then wanted to focus on developing with and report on. From a theoretical government accounts.
Resource Accounting and Budgeting. perspective, there are strong calls for
These plans considered including WGA to be used to assist economic Although three years’ worth of UK
information on future assets/liabilities planning in the way demonstrated in WGAs have now been published, a
such as pensions and the potential to the charts above. David Heald, a former significant amount of work is still
generate tax revenues, in addition to member of FRAB and adviser to the needed to remove the three
Past Future
Other assets*
Assets
Future revenue
Liquid financial assets
Future liabilities
Liabilities
18
4.4 CANADA financial dependence on the • accumulated surplus/deficit –
government, constitutes control by measures net economic resources
The government of Canada does not itself. Government organisations that (assets) and indicates the capacity to
engage in national-level consolidation meet these control tests are combined provide future services
exercises like the UK, Australia and New into a single reporting entity for
Zealand. Instead, consolidated financial government-wide consolidated financial • annual cash flow – measures the
reporting occurs separately at each of reporting. As judgement is required in change in cash in a period and
the three major levels of government: determining a reporting entity, reveals the sources and uses of
federal, provincial, and municipal. With differences in interpretation can exist funds.
provincial and federal responsibilities among jurisdictions.
established in the Constitution Act The public sector accounting standards
(Canada, Department of Justice 1867), The recommended structure and in the PSA Handbook do not, however,
each level is relatively autonomous and content of government financial apply to all government organisations.
independent. Although municipalities statements in Section 1201 of the PSA Some organisations should use the PSA
are under provincial jurisdiction, they Handbook (effective 2012) has gone Handbook, some should use the IFRS,
have also been granted a relatively high through several reviews and revisions and others are allowed some choices.
degree of operational independence over two decades. As many For accounting purposes, public
(Noe and Ross 2004). Therefore, governments ignored the reporting organisations are categorised into four
financial statements cannot legally be model approved in 1997, despite six groups:
consolidated across these three levels years of extensive consultations, this
of government. project was restarted within two years • federal, provincial, and municipal
(Jones Denning 2003). The current governments, including their
Reporting entity and accounting model contains four financial consolidated agencies
standards statements: consolidated statement of
The concept of control is integral to financial position, consolidated • government business enterprises
determining the organisations that statement of operations, consolidated (GBEs)
comprise a government reporting entity statement of change in net debt, and
and are consolidated for financial consolidated statement of cash flows. • government not-for-profit
reporting purposes. Section 1300 of the Furthermore, the following five organisations (GNFPOs), and
CPA Public Sector Accounting (PSA) measures should be explicitly reported
Handbook—subsequently referred to on these statements: • other government organisations
as the PSA Handbook (CPA Canada (OGOs).
2014), revised in 2005, defines control as • net debt – measures the difference
‘…the power to govern the financial and between financial assets and GBEs are separate legal entities that
operating policies of another liabilities and reflects future carry on business activities similar to
organization’. Indicators of control revenues required to pay for past those performed by private companies.
include: appointing members of the transactions GNFPOs are government not-for-profit
governing body; establishing its organisations established by legislation,
fundamental purpose; significantly • change in net debt – measures the which could have counterparts in the
limiting its decision-making authority; change in financial condition and non-governmental charitable sector.
directing its policies on a permanent reflects the sufficiency of revenues OGOs are any other government-
basis; and vetoing, overruling, or raised in a period to cover expenses controlled organisations, which may sell
modifying its policies. Such evidence goods/services or rely on grants from
needs to be weighed collectively in • annual surplus/deficit – measures other levels of government. The
accordance with organisational the excess/shortage of revenues accounting standards that these four
circumstances. Neither the over expenses raised in a period types of organisation should use are
government’s ability to regulate an and reflects the maintenance of the noted in Table 5.1 in the next chapter.
organisation, nor an organisation’s previous net asset position GBEs are excluded from consolidated
20
approved by the authorising legislature 4.5 SWEDEN accounting in Sweden and Norway that
(CICA 2004), they will always be looks at the way in which accounting
important. While early financial reforms The key focus of the Swedish academic itself is becoming institutionalised
focused on budgets and expenditure literature is on the effects of accounting (Bergevärn 1995). Accounting here is
management, for example, a structured change on public institutions and how understood as consisting of two
approach to ‘prudent budgeting’ in accounting is being used in the public systems: the norm system and the
1994 (Joyce 2008), more comprehensive sector. There are no specific papers action system. The relations between
results-based management tools, discussing the nature of consolidation. norms, and action and their
however, also began to emerge in the Nevertheless, it is still informative to environment are discussed in light of
late 1990s. Comprehensive result-based survey the literature to understand the ideas derived from institutional theory
tools can link estimated and actual forces acting on accounting-driven and organisational learning.
resources to activities, programmes, change in the Swedish public sector.
and strategic outcomes at It is argued that there are two modes of
departmental and government-wide Studies in the 1980s and 1990s were learning; one ideological and one
levels (Joyce 2011). As these systems are dominated by the accounting systems hierarchic. Regardless of the mode of
capable of integrating both financial of local governments, reflecting, in part, learning, the norms are closely
and non-financial information, the role the freedoms they have to set their own associated with the environment of
of financial information, such as financial reporting standards. In line accounting. Bergevärn (1985) illustrates
consolidated financial statements, for with the collaborative nature of the that in the ideological mode this
managerial planning, decision-making relationship between Swedish connection is made through the action
and control purposes, presumably academics and government institutions system while in the hierarchic mode it is
diminishes. (ie ‘action research’), Brorström and made through the norm system. One
Olson (1985) debate how the conclusion drawn is that ‘depending on
Conclusion accounting systems of local how strongly the norm system forces
The implementation of government- governments should be changed, in the action system to respond, the
wide consolidated financial statements view of their actual use and misuse. learning processes in which accounting
in Canadian governments has been an Their article examines two specific as a whole is involved will reveal a
invisible incremental process – an accounting models that had been greater or lesser degree of variation’
added-on annexe to the developed for local governments. (Bergevärn 1985: 1).
implementation of full accrual These models, through the authors’
accounting. The government of Canada own action-research studies (see In another comparative study, Mattisson
has, however, been reluctant to Brorström 1982 and Olson 1983), were and colleagues examined the
upgrade accounting for appropriations implemented by two local governments similarities and differences of the
and departmental financial statements in the late 1970s. accrual accounting reform processes in
to full accrual accounting. local governments in Sweden and
Consequently, accrual accounting, and, A few years later, Bergevärn and Olson Finland. They deduce that Swedish
by extension, government-wide explored the development of municipal local government financial report
consolidated financial statements, are accounting in Sweden from 1862 to the practices lean more towards
not used, or perceived useful, for 1980s, concentrating primarily on the accountability than those of Finnish
managerial planning, decision-making consequences of the Swedish reform. local governments (Mattisson et al.
and control purposes. Budgets, Their analysis (Bergevärn and Olson 2004). They go on to explain that in
supplemented by departmental 1989) of municipalities, federations of Sweden, the central government is one
financial statements and results-based municipalities and the Parliament of the most important stakeholders of
management tools, appear to be key focuses on how myths surrounding the local government and uses financial
financial management mechanisms. The promises of accounting had developed reporting as a monitoring device to
major use of government-wide and became institutionalised. Their ensure that local governments comply
consolidated financial statements is for study was extended in a comparative with statutory requirements to balance
accountability reporting to Parliament. and historical study of municipal their budgets as well as other demands
22
5. Discussion and research agenda
The point of consolidation under GAAP are being adapted to fit local (ie with their Australian counterparts. The
is to introduce a single bottom-line national) needs raises a number of blurring of lines is never far away, either,
figure for the whole of the organisation questions that are worthy of further in the UK, Canada and Sweden, , where
and uniformity in standards. The review exploration. strong accounting professional bodies
of the literature in the previous chapter and the fluidity of expertise interchange
suggests, however, that there are First, the balance between internal (ie between the two sectors (eg Swedish
multiple definitions of what constitutes government institutions’) conceptions academics) ensure a strong diffusion of
a government bottom line and little of adapting GAAP models of ideas from private to the public. All
uniformity in the way in which consolidation needs to be further countries rely in particular on the
consolidated accruals accounting contrasted against perceived public (unproven NPM) rhetoric that ideas
models are developed across the five demand for such elaborate models as a originating from the private sector can
countries examined in this report. Table way of improving systems of be successfully adapted for resolving
5.1 provides a quick overview of the key accountability. It appears that much of long-standing public sector issues, and
differences discussed above, drawing the demand for more complex GAAP- none more so than consolidation
attention to differences in government based consolidation accounting is accounting, which appears to be all
structures, consolidation boundaries being driven internally by government things to all people.
and parliamentary systems of reforms, but only where the politics of
accountability. resource allocation still reside at the The final contest of interest is between
budgetary level and are underpinned national and global standard-setters –
The analysis here suggests that in the by statistical notions of accounting witness the growing influence of IPSAS
context of using government values (eg the UN’s System of National and the cooperation–competition
consolidated accounts, constitutional or Accounts) rather than GAAP. tension between national standard-
jurisdictional boundaries feature setters aware of the benefits of a more
heavily, as one would expect, in This leads to the second question, harmonised approach but also wary of
determining the way in which which examines the embedded or conceding too much autonomy over
commercial sector notions of implicit contests or ‘trials of strength’ their own jurisdictions. The European
consolidation are reshaped for public between nations and/or institutions Union’s push for EPSAS is one emerging
sector application. The localisation of jockeying for influence. There are three example.
globalised or generic concepts of arenas where such contests are being
consolidation has a strong impact on played out. So who are the users of public sector
the resulting output here, and is driven consolidation accounts and how are
largely by government priorities or The first is statistical versus GAAP they affected by the various national/
preoccupations rather than necessarily notions of accounting value, which institutional/political contests outlined?
by user demand. Federated structures features in all accounting debates over This is perhaps the most important
of government found in Australia, the merits and costs of ex-ante versus question and one that is most
Canada and Sweden consolidate on the ex-post notions of value (ie the neglected, not just in the professional
basis of jurisdiction, reflecting political relevance versus reliability debate). literature but also by academics. The
notions of control and accountability academic surveys of how long-standing
boundaries rather than more economic The private versus public sector divide Australian and New Zealand WGRs are
ideals on which GAAP is based. New – many questions can be raised about used indicate limited use of accounts
Zealand and the UK, on the other hand, Australia and New Zealand’s seesaw for public accountability purposes,
adopt more expansive models of approach to the harmonisation of despite claims to the contrary.
consolidation, with a macroeconomic private/public sector accounting Anecdotally, it appears that the
emphasis on usability (for government standards, with NZ’s latest being a budgetary process in which resource
policymaking rather than public move back to separate standards for allocation decisions are taken remain
accountability). At face value, the way in the public sector after a period of the key arena in which significant
which GAAP notions of consolidation sector neutrality and close cooperation scrutiny, debate and politics take place.
Latest accounts: WGR 2012-2013 WGR 2012/2013 WGA 2012/13 Public Accounts of Annual accounts of
Canada 2012/13 government (Statens
Total assets: £1.3tr. resultaträkning, 2012)
Total assets: C$408bn.
Total liabilities: £2.6tr. Total assets: SEK
Total liabilities: C$1,011bn. 1,285,078 million
24
In the UK at least, parliament has
become more interested now that
WGAs have been published for three
years, but much remains unanswered
about how WGA will bridge the divide
with the budgetary process. This was
also a question grappled within the
Australian system where the dual
bottom line reporting caused confusion
among parliamentarians.
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