Chapter 10

Accounting, Financial Reporting, and the Annual Audit

by Gregory S. Allison

Public confidence in government depends on proper stewardship of public moneys. The North Carolina Local Government Budget and Fiscal Control Act (LGBFCA)¹ sets forth requirements for fiscal control that provide a framework for ensuring accountability in a local government’s budgetary and financial operations. This chapter focuses on these requirements, which generally are equally applicable both to county governments and municipal governments.² They pertain to the appointment and the role of a unit’s finance officer, the accounting system, control of expenditures, cash management and investments, the annual audit, and audits of federal and state financial assistance.

A short discussion of the role of the North Carolina Local Government Commission and its relationship to North Carolina local government entities will facilitate understanding of references that occur throughout this chapter. Often referred to simply as the LGC, the Local Government Commission is discussed in Chapter 2, “The Local Government Budget and Fiscal Control Act,” and in Chapter 7, “Financing Capital Projects.”

The LGC, established by Chapter 159, Section 3 of the North Carolina General Statutes (hereinafter G.S.), operates as a division of the Department of State Treasurer. The commission itself consists of nine members. The state treasurer, the state auditor, the secretary of state, and the secretary of revenue serve as ex officio members; the remaining five members are appointed by the governor (three members) and the General Assembly (two members). The commission’s primary responsibility is to provide fiscal and debt management oversight to local government entities in North Carolina. The commission’s policy directives are carried out on a day-to-day basis by the staff of the LGC, who are employees of the Department of State Treasurer.

The LGC’s oversight of North Carolina counties and municipalities is extensive. A local government’s financial condition, cash management practices, and audit procurement procedures are all subject to LGC review and approval. As a general rule, counties and municipalities are not allowed to enter into most types of indebtedness without the express permission of the LGC. Counties and municipalities in North Carolina have benefited extensively from this level of oversight; their financial condition and reputation in the national debt markets are among the best in the nation.

The Finance Officer

G.S. 159-24 requires that each county and municipal government have a finance officer who is legally responsible for establishing the unit’s accounting system, controlling expenditures, managing cash and other assets, and preparing financial reports. The LGBFCA does not specify who is to appoint this official, leaving the decision to each jurisdiction. In many counties and municipalities, the manager appoints the finance officer.³ In counties and municipalities that do not have a manager, the governing body typically makes the appointment. According to G.S. 159-24, the finance officer serves at the pleasure of the appointing board or official.

In most counties, the official exercising the statutory duties of finance officer carries that title; in most municipalities, the official exercising these same duties carries the title of finance director. In some of the larger counties and municipalities, the title of chief financial officer (CFO) is used. Other titles, such as accountant or treasurer, may be used by some jurisdictions, but this is less common. There are also other derivations in some smaller counties. For example, the county manager may also be the legally designated finance officer, or the finance officer may also serve as an assistant county manager. The LGBFCA permits the duties of the budget officer and finance officer to be conferred on one person. In contrast, G.S. 105-349(e) specifies that the duties of tax collector and those of the “treasurer or chief accounting officer,” which should be understood to mean the finance officer, may not be conferred on the same person except with the written permission of the secretary of the LGC. This limitation recognizes both the hazards to internal control of one person holding the two offices and the fact that some local government entities are too small to make any other arrangement. While it is currently very rare for one person to serve as both the finance officer and the tax collector in a county, the commission has allowed a number of municipalities to operate under this arrangement. However, these approvals have typically been made with restrictions, such as suggesting that the municipality contract with the county for property tax billing and collection.

The finance officer’s duties are summarized in G.S. 159-25(a): establish and maintain the accounting records, disburse moneys, make financial reports, manage the receipt and deposit of moneys, manage the county’s or the municipality’s debt service obligations, supervise investments, and perform any other assigned duties.

Official Bonds

A unit’s finance officer must give “a true accounting and faithful performance bond” of no less than the greater of the following:

1. $50,000 or

2. an amount equal to 10 percent of the unit’s annually budgeted funds, not to exceed $1,000,000.⁴

The term “annually budgeted funds” has been interpreted by the staff of the LGC as

1. including budgeted expenditures in a unit’s or public authority’s originally adopted annual budget ordinance in the fiscal year the bond is obtained and

2. excluding expenditures for which a unit or public authority budgeted in a multi-year project ordinance.

The bond must be given on the individual, not the position. The usual public official’s bond covers faithful performance as well as true accounting. The bond insures a county or a municipality for losses it suffers as a result of the actions or negligence of its finance officer; it offers no insurance or protection to the officer. The county or the municipality must pay the bond’s premium. If a candidate for a finance officer position is unable to obtain a performance bond in accordance with these minimum guidelines, the individual is disqualified from an appointment as a local government finance officer.

G.S. 159-29 also requires that each “officer, employee, or agent . . . who handles or has in his custody more than one hundred dollars . . . at any time, or who handles or has access to [a unit’s] inventories” be bonded for faithful performance. If separate bonds for individuals are purchased, the $100 minimum should be understood to mean that the bonding requirement applies only to those persons who frequently or regularly handle that amount or more. The governing board of a county or a municipality fixes the amount of each such bond, and the unit may (and normally does) pay the premium.

In lieu of requiring a separate bond for each employee, a county or municipality may purchase a “blanket” faithful-performance bond, and nearly all counties and municipalities do (primarily for cost reasons, as blanket bonds are more economical than the total cost of separate bonds). The blanket bond does not substitute for the separate bond required for the finance officer or other county officials (tax collector, sheriff, and register of deeds) or municipal officials (tax collector), who must still be bonded individually and separately.

The Accounting System

An accounting system exists to supply information. It provides a county’s or a municipality’s manager and other officials with the data needed to ascertain financial performance and to plan and budget for future activities with projected resources. The accounting system is also an essential part of internal control procedures.

The governing board of a unit depends on accounting information in making its budgetary and program decisions and in determining whether or not they have been carried out. This kind of information is valuable also to outside organizations. The investment community and bond-rating agencies rely on it as they assess a county’s or a municipality’s financial condition. Also, in counties and municipalities where bonds have recently been issued, the local government is often required to provide various types of annual financial information to meet continuing disclosure requirements. State regulatory agencies, such as the LGC, review data generated by the accounting systems to determine whether counties and municipalities have complied with the legal requirements regulating accounting and finance. Federal and state grantor agencies use the information to monitor compliance with the requirements of the financial assistance programs they administer. The media and the public depend on the information to evaluate a local government’s activities.

County and municipal accounting practices are formed in response to the general statutory requirements set forth in G.S. 159-26, which are generally accepted accounting principles (GAAP) promulgated nationally by the Governmental Accounting Standards Board (GASB). In North Carolina, the rules and regulations of the LGC as well as the local government’s own needs and capabilities directly impact its accounting practices.

Statutory Requirements

G.S. 159-26 requires that each county and municipality maintain an accounting system, which must do the following:

1. Show in detail its assets, liabilities, equities, revenues, and expenditures.

2. Record budgeted as well as actual expenditures and budgeted or estimated revenues as well as their collection.

3. Establish accounting funds as required by G.S. 159-26(b). A fund is a separate fiscal and accounting entity having its own assets, liabilities, equity or fund balance, revenues, and expenditures. Government activities are grouped into funds to isolate information for legal and management purposes. The types of funds that are set forth in G.S. 159-26(b) for use by counties and municipalities are discussed later in this chapter.

4. Use the modified accrual basis of accounting. Basis of accounting refers to criteria for determining when revenues and expenditures should be recorded in an accounting system.⁵ The modified accrual basis requires that expenditures be recorded when a liability is incurred (time of receipt) for a good or service provided to a local government. The expenditure should be recorded then, usually before the funds are disbursed. This type of accounting also requires that revenues be recorded when the revenues are measurable and available. Measurable means that they can be reasonably estimated, and available means that they will be received within the current fiscal year or soon enough thereafter to be able to pay liabilities of the current fiscal year. In actual practice, for various reasons some revenues are recorded when they are received in cash. For example, in North Carolina, property tax revenues are generally recorded on a cash basis because taxes receivable are not considered to be collectible soon enough after the year’s end to meet the availability criterion. Permits and fees also are recorded on a cash basis because they are not considered to be measurable at year’s end. However, certain revenues collected after the fiscal year ends but soon enough thereafter to pay liabilities outstanding as of June 30 would be reflected as revenue for the year ending June 30 because they would be considered measurable and available. For example, the monthly sales tax payments received by counties and municipalities in July, August, and September are recorded by most local governments as revenue for the year ending June 30 because the payments can be measured; they are directly related to sales that occurred during the previous fiscal year (i.e., the July distribution is related to the previous April’s sales, the August distribution is related to the previous May’s sales, and the September distribution is related to the previous June’s sales); and they are received soon enough after June 30 to be able to pay liabilities at the fiscal year’s end.

   The modified accrual basis of accounting helps keep financial practices on a prudent footing: expenditures are recorded as soon as the liabilities for them are incurred, and some revenues are not recorded until they have actually been received in cash. In addition, the modified accrual basis enhances the comparability of financial reporting for counties and reduces the opportunity for manipulation of financial information.

5. Record encumbrances represented by outstanding purchase orders and contractual obligations that are chargeable against budgeted appropriations. An encumbrance is created when a contract that will require a county or a municipality to pay money is entered into or when a purchase order is issued.

   Although the LGBFCA does not explicitly mention any exceptions, in practice, expenditures for salaries and wages, fringe benefits, and utilities are usually not encumbered. Salaries, wages, and fringe benefits are not encumbered because they generally are budgeted at the full amounts expected for all positions, and this significantly reduces the risk of over-expenditure. Utilities expenditures are normally not encumbered because the amounts are generally not known in advance.

   An encumbrance exists as long as a contractor or supplier has not delivered goods or services and the contract or purchase order is outstanding. While this is the case, the local government is not yet liable to pay for the goods or the services and has not yet incurred an expenditure for them. G.S. 159-26(d) requires that a county’s or a municipality’s accounting system record encumbrances as well as expenditures. This recognizes that an encumbrance is a potential liability, and once a purchase order is filled or a contract fulfilled, a liability for payment is created and an expenditure is incurred. Although this requirement applies only to counties with more than 50,000 citizens or municipalities with more than 10,000 citizens, nearly all counties and municipalities record encumbrances in their accounting systems.

Generally Accepted Accounting Principles for Governments

Governmental accounting, as a branch of general accounting practice, shares basic concepts and conventions with commercial accounting. However, because of major differences in the governmental environment, a distinct set of national accounting and financial reporting principles has evolved in this field. They are promulgated by the GASB. Established in 1984, the GASB is responsible for the establishment of GAAP for county and municipal governments as well as state governments. The GASB succeeded the National Council on Governmental Accounting (NCGA), which had formerly established GAAP for government entities. Although the GASB at its creation accepted the existing NCGA pronouncements, it has actively set forth standards in areas of accounting and finance that the NCGA did not formally consider. Likewise, it has updated and modified much of the guidance that it initially accepted.

The LGC plays a key role in defining and interpreting accounting standards and procedures for local governments in North Carolina. It issues rules and regulations that interpret state statutes as well as national professional standards, and it provides advice about requirements and improvements in accounting and financial reporting practices. The commission’s staff has focused much attention in recent years on annual financial reports, working closely with local officials and the state’s public accounting profession to keep local government accounting systems up to date with the increasingly more rigorous reporting and disclosure standards being promulgated by the GASB.

Counties’ and Municipalities’ Own Needs and Capabilities

Counties’ and municipalities’ own needs and capabilities also shape their accounting and financial reporting systems. For example, a growing number of counties and municipalities have improved their annual financial reports to the point that they have earned the Certificate of Achievement for Excellence in Financial Reporting, awarded by the Government Finance Officers Association (GFOA) of the United States and Canada to recognize outstanding achievement in governmental financial reporting. While all North Carolina local governments issue professionally acceptable annual financial reports, those winning the Certificate of Achievement provide full disclosure above and beyond the minimum standards set by GAAP and relate current financial conditions and performance to past financial trends. Approximately five thousand local governments in the United States participate in the Certificate of Achievement program, which offers a tremendous resource to help local governments continually improve their financial reporting.

Nationwide, capital asset accounting and reporting continues to be one of the more significant challenges in state and local government accounting. In recent years, the LGC and the independent public accountants auditing local governments, as well as the aforementioned GFOA, have placed increased emphasis on capital asset records. If these records are inadequate, the annual auditor’s opinion may be modified, and this may adversely affect a county’s or a municipality’s bond rating. Also, a modified audit opinion may affect a county’s or a municipality’s ability to obtain approval from the LGC for debt issuance. In addition, an adequate capital asset accounting system can provide significant advantages. It places responsibility for the safekeeping of such assets with a unit’s management, thereby improving internal control. It also serves as a basis for establishing maintenance and replacement schedules for equipment and for determining the level of fire and hazard insurance that should be carried on buildings and other capital assets.

It should be noted that the capitalization threshold that management establishes for financial reporting purposes should not be presumed to be directly correlated to adequate internal control of government property. For years, there has often been the misconception that the lower the capitalization threshold, the less likely it is that the capital asset will be lost, misplaced, or misused. However, low capitalization thresholds simply clutter the internal capital asset records with immaterial items and actually make them less useful. The external financial statements should focus on material items, and there is a significant internal cost to maintaining unusually low capitalization thresholds. For North Carolina governments, it is recommended that capital asset thresholds be no less than $1,000, and thresholds up to $5,000 are preferable. The threshold is used only to determine where on the external financial statements capital assets will be reported. The threshold does not mitigate the need for management at the departmental level to maintain adequate internal controls and records to safeguard all government property. Also, it should be noted that, as a general rule, capitalization thresholds for financial reporting purposes are a management responsibility and there is no required official action by governing boards to establish or modify them.

The Annual Audit

Contents of the Annual Comprehensive Financial Report

G.S. 159-34 requires local governments to have their accounts audited by independent auditors after the close of each fiscal year. The auditor’s opinion is set out in an annual financial report, which must include “the [county’s/municipality’s] financial statements prepared in accordance with generally accepted accounting principles, all disclosures in the public interest required by law, and the auditor’s opinion and comments relating to [the] financial statements.”

Preparation of the report’s financial statements and their accompanying notes is the responsibility of a local government’s management. There are units that may not have the internal staff or expertise to prepare the annual financial statements. In those situations, the local government may contract with an independent third party to assist in their preparation. The independent auditor may only provide limited assistance in order not to impair their independence. Professional standards for auditors have greatly enhanced the requirements for independence in recent years, which has limited auditors’ ability to provide significant report preparation services.

More and more local governmental entities are preparing an annual comprehensive financial report (ACFR). ACFRs are not required by GAAP or by state statute, but they are very useful to external users of a government’s financial statements. These reports go above and beyond the minimum external reporting requirements and provide useful financial and nonfinancial data about a local government. An ACFR contains three primary sections: introductory, financial, and statistical. A fourth section consisting of the compliance or single-audit reports and schedules may be included, but this is not required. Table 10.1 summarizes the contents of the ACFR. If a local government does not prepare an ACFR, only the financial section, including financial statements and notes, will be found in that unit’s annual financial report.

Introductory Section

The introductory section of an ACFR includes the transmittal letter, which is primarily an overview of the report, a brief introduction of the local government, and the official transmission of the report to external users; an organization chart; and a list of principal elected and nonelected officials. The transmittal letter should provide useful information to members of the public and the business community who may not be aware of all the local government’s functions and services.

Financial Section

The financial section of an ACFR contains financial statements, which present information in various formats and levels of detail. The financial section includes the financial statements required by GAAP—known as the basic financial statements—as well as financial presentations in greater levels of detail that often are used to exhibit budgetary compliance or to provide opportunities for more detailed analysis.

An independent auditor’s opinion is the first item in the financial section of an ACFR prepared by a local government. The opinion should be printed on the auditor’s letterhead, further emphasizing that it is not a representation made by the unit’s management. The next presentation in the financial section is the management’s discussion and analysis (MD&A), a written summary and overview of the local government’s financial condition and the ways in which its financial condition has changed during the year. Governmental entities are required to prepare an MD&A even if they are not preparing an ACFR.

The basic financial statements are presented after the MD&A. As noted earlier, these statements represent the minimum information required in the external financial statements for them to be in accordance with GAAP. The basic financial statements are broken down into two main sections—the government-wide financial statements and the fund financial statements. A comprehensive set of note disclosures supports each section. The government-wide financial statements, which include a statement of net position and a statement of activities, focus on the two broad activities of a local government—the governmental activities and the business-type activities. The fund financial statements, however, focus on the funds that are reported by and are unique to local governments. The three main categories of funds—governmental, proprietary, and fiduciary—include numerous fund types. The fund types most common to counties and municipalities in North Carolina include the general fund, special revenue funds, capital projects funds, enterprise funds (e.g., utility funds), and pension trust funds.

The notes to the financial statements immediately follow the government-wide and fund financial statements and are considered an integral part of the basic financial statements. The content and form of the notes are prescribed by GAAP. Through written advisory memoranda and illustrative financial statements interpreting GAAP, the LGC provides guidance to local officials and their independent auditors on the content of the note disclosures. These disclosures contain significant information for anyone attempting to interpret the financial statements and understand the finances of a local government entity. While all disclosures are important for a good understanding of information presented in the financial statements, the note disclosures related to the definition of the reporting entity, statutory violations (if any), the collateralization of deposits and investments, capital assets, and types and terms of long-term liabilities should be of particular interest to users of the financial statements.

Statistical Section

The statistical section of an ACFR follows the financial section. It includes multi-year information on financial trends of a government, its revenue and debt capacity, relative demographic and economic information, and various operating information. The statistical section is considered an invaluable tool for bond-rating agencies and potential investors and creditors. As a general rule, the statistical tables in this section include ten years’ worth of comparative data. In a few cases, the comparisons are not for a complete ten years but are comparisons of the current year with nine years prior, thus exhibiting a ten-year spread.

The Auditor’s Opinion

The auditor’s task is to render an independent opinion on the accuracy and reliability of the basic financial statements and the related note disclosures as well as on their conformity with GAAP. The auditor opines not that the financial statements and disclosures are always exact but that they are reliable enough for a knowledgeable reader to use them to make informed judgments about a local government entity’s financial position and operations.

The auditor’s opinion most commonly takes one of two forms. First, it may be unmodified (frequently referred to as a “clean” opinion). With an unmodified audit opinion, the auditor is opining that the financial statements present fairly the unit of government’s financial position at the close of the fiscal year, in conformity with GAAP. Thus, there is no modification placed on the opinion (i.e., there are no exceptions noted). All North Carolina local governments should strive for an unmodified opinion.

A modified opinion is a second possibility. If in some way a local government’s practices materially vary from GAAP, the auditor’s opinion may state that the statements fairly present the local government’s financial position except for any such deviation. For example, the most common type of problem that may result in a modified auditor’s opinion is inadequate records supporting the valuation of a government’s capital assets in its financial statements. An opinion modification also may be due to a scope limitation. This occurs when the independent auditor is unable to perform certain tests that are an essential part of the audit. For example, a local government’s accounting system may fail to provide adequate documentation for some revenue and expenditure transactions, in which case the auditor’s ability to test such transactions would be limited.

Auditors are required to present the audited financial statements and the overall results of the audit to the local government’s governing board in an official open meeting. This presentation should occur no later than forty-five days after the audited financial statements have been submitted to the LGC. The presentation should address, if applicable, any significant deficiencies, material weaknesses, or other findings, including financial indicators of concern as defined by the LGC. Consequently, the unit’s governing board must respond to the LGC, within sixty days of the auditor’s presentation, to these findings and concerns. The response should include the board’s detailed plans of corrective action and should be signed by the majority of the board members.

In addition, the auditor normally suggests improvements to the local government entity’s internal control procedures and operations in a management letter that accompanies the audit report. This letter is a public document addressed to the unit’s governing board and typically makes various specific suggestions for improving internal control and financial procedures. These suggestions normally arise from the audit but do not meet the threshold of the aforementioned deficiencies or weaknesses. The management letter is delivered at the same time as the audited financial statements. Often the auditor’s suggestions have been informally made earlier, and some may already have been addressed at the time of the formal presentation.

In addition to providing the management letter, the independent auditor can often be an excellent source of advice on accounting system design, internal control procedures, and finance in general.

Selection of an Independent Auditor

G.S. 159-34 establishes certain requirements and procedures regarding contracting for a local government’s annual audit. First, the auditor must be selected by and report to the unit’s governing board. The auditor should not report to the unit’s manager, budget officer, or finance officer.

Second, the governing board may choose any North Carolina certified public accountant (CPA) or any accountant certified by the LGC as qualified to audit local government accounts. In practice, no non-CPA accountants have requested certification or met the requirements for certification to perform local government audits in recent years. Governing board members should assure themselves that the person or firm selected is familiar with the particular features of government accounting and auditing. Auditors should be engaged early in the fiscal year so that they can become familiar with the local government’s procedures and can complete some of the necessary testing before the fiscal year’s end. This also ensures that the auditor can plan the audit engagement and complete it in a timely manner.

Many counties and municipalities select the auditor through a request for proposals (RFP) process. Although this is not required by state statute, using an RFP is recommended by LGC staff to secure the best audit proposal. Also, selecting an independent auditor through a competitive procurement process is often required by federal regulations in many grant agreements where audit costs are chargeable to the grant. It is most common for audit agreements procured through an RFP process to range from three- to five-year terms. The RFP should cover both the technical qualifications of a potential audit firm and the firm’s cost proposals. Local officials should give more weight to an auditor’s technical skills than to the firm’s proposed audit fees. References from other local government clients should be requested from an auditor. These references should be contacted so that local government officials may obtain information on other local governments’ experiences with a potential auditor.

Contrary to popular belief, government entities are not required to rotate auditors periodically. As mentioned earlier, the LGC recommends that governments issue an RFP process at least every three to five years. This does not, however, preclude any current auditors from retaining their engagements if they continue to meet the service and price requirements established in an RFP. Many government entities have retained the same audit firm for years. Some benefits of these established relationships are the auditor’s familiarity with the government’s environment and the government’s avoidance of costs (particularly in staff time) incurred in changing auditors. On the other hand, some governing boards choose to contract with different auditors to provide a fresh look or to allocate the work to other qualified auditors in the region. Both approaches have merit, and the LGC has not encouraged or endorsed either method. It should again be noted that rotation is not statutorily required but is a policy left to the discretion of each entity’s governing board.

Finally, a local government’s contract with an auditor must be approved by the LGC. Payment may not be made for any auditor services until the secretary of the commission has approved the billing.

Audits of Federal and State Grants

Federal and state grants and other financial assistance programs provide moneys to support county and municipal programs. In the past, individual federal and state agencies providing these moneys audited the recipient government’s expenditure of them to verify that the moneys were spent for the purposes intended and in accordance with prescribed procedures. Since the mid-1980s, however, the federal government has required local governments to procure a combined financial and compliance audit, or single audit, of all federal financial assistance programs that meet certain expenditure thresholds.

To build on the federal single audit, the 1987 General Assembly, with the support of local officials, passed a law requiring state financial assistance programs to be included with federal programs in a combined single audit. In North Carolina, this combined single audit is performed in conjunction with the annual financial audit by a local government’s independent auditor. Federal and state agencies are allowed to build on single audits and perform monitoring work on the programs they administer. However, they should not duplicate the work performed by independent auditors.

The independent auditor issues a number of compliance and internal control reports to disclose findings from the single audit. These reports usually are included in the last section of a local government’s annual financial report or in a fourth section of an ACFR. The most significant items for local officials in these reports are the internal control weaknesses, findings, and questioned costs identified by the auditor. Internal control weaknesses are usually significant deficiencies and should be corrected unless corrective actions would not be cost-effective. For example, an internal control weakness commonly cited is the lack of proper segregation of duties. However, especially for small governments, complete correction of the problem could involve additional hirings, the costs of which could outweigh the benefits. In these situations, mitigating controls can be put into place to lessen the risks and weaknesses involved. Otherwise, findings and questioned costs almost always require corrective action, which may necessitate the repayment of grant funds. County and municipal officials’ formal responses to findings and questioned costs and material internal control weaknesses are included in the single-audit reports.

The LGC monitors the single audit of grant funds as part of its review of a local government’s annual financial report. If the commission determines that the single-audit reports and schedules are not prepared according to applicable standards, the independent auditor may be required to revise them before the annual financial report can be accepted. If the LGC finds that the single audit is satisfactory, then all state grantor agencies must accept the audit. If the commission determines subsequent to its approval of the annual financial report that the single audit is not reliable, it may revoke its approval. This opens a county or a municipality up to individual federal and state agency audits.

Additional Resources

Government Finance Officers Association (GFOA). 2022 eGAAFR (Governmental Accounting, Auditing, and Financial Reporting). 2022 ed. Chicago: GFOA, 2022.

Governmental Accounting Standards Board (GASB). Codification of Governmental Accounting and Financial Reporting Standards as of June 30, 2022. Norwalk, Conn.: GASB, 2022.