ML20059H830

Comments on Draft Financial Mgt Reform Act of 1990.NRC Opposes Provisions That Would Require Chief Financial Officer to Rept to Agency Head

ML20059H830
Person / Time
Issue date:	09/11/1990
From:	Carr K NRC COMMISSION (OCM)
To:	Conyers J HOUSE OF REP., GOVERNMENT OPERATIONS
Shared Package
ML20059H834	List: ML20059H830 ML20059H837
References
NUDOCS 9009190041
Download: ML20059H830 (3)

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NUCLEAR MGULATORY COMMISSION m

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September 11, 1990 CHAIRMAN l

The Honorable John Coyers, Jr., Chairman I

Committee on Government Operations United States House of Reoresentatives Washington, D. C.

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Dear Mr. Chairman:

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Thank you for the o portunity to provide the Nuclear Regulatory Commission's (hRC's comments on the draft " Financial Manage-ment Reform Act of 1990."

The Commission supports many of the j

objectives underlying this proposal.

However, as we indicated in our April 20, 1990 letter tc you on similar legislation, the NRC already has a Chief Financial Of ficer, the Controller, who has responsibility for all budget, accounting, internal control, and other financial management initiatives.

This organizational structure has permitted the NRC to meet the major goals of this legislation and enables us to maintain an-efficient information interface between our planning / budget and accounting / financial management functions.

Given the e!fectiveness of our current program, the NRC caposes the provision in the legislation that would require the C11ef Financial Officer to report directly to the agency head.

At present, the Controller is appointed by and reports directly to the agency's Executive Director for Operations (EDO), the agency's chief operatins and administrative officer responsible l

for the day-to-day operation of the agency.

The EDO in turn l

reports directly to the NRC Chairman.

The Commission believes that day-to-day supervision of the financial functions of the agency is best aandled at the EDO level.

As you may know, the NRC has developed an integrated strategic planning / budget process to plan for our health and safety mission, and the Controller is an integral part of this process.

The EDO has the responsibility for the planning and operation of the' NRC's health and safety missions, and the effectiveness of this process could be adversely affected if-the Controller did not report to the EDO.

Of course, major financial management issues will continue to be resolve $ by the Commission itself.

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't, a The Commission also opposes the provision which provides that the Chief Financial Off-.cer shall he appointed by the President and confirmed by the Senate.

As a small, independent regulatory commission, the NRC is concerned that such a provision could resdit in the appointment of individuals not having the desired understanding-of this agency's regulatory programs and operations.

Also, it ap1 ears that one of the primary reasons for a statu-tory Chief rinancial Officer is to implement sectioi 303 of the draft lepislation.

That section would require annual egency financia statements concerning an agency's "revolvin

" trust 'unds " and " substantial commercial functions.g tunds,"

These financial statements would be audited by the Inspector General of the agency, the Comptroller General, or by an independent external auditor.

These provisions appear to be a recognition that government organizations with these types of funds should prepare financial reports and be audited'as if they were a arivate sector entity.

Because the NRC already has a Chief rinancial Officer and does not have any of these types of funds, we question the need for the NRC to be included within the scope of this legislation.

The Commission appreciates your consideration of these comments.

Sincerely, J_61 Kenneth M. Carr cc:

Rep. Frank Horton 1

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UNITED STATES NUCLEAR REGULATORY COMMISSION

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W ASMeeseTON. O. C. 21588

) pan 3, wo oppica or Tus SSCRETARY NOTE FOR:

Lacument Centrol Desk FROM:

Correspondence & Records ' Branch

("O The enclosed document (s) are to be entered into the OCS. An advanced has been sent to the Public Document Room.-

PLEASE PROCESS AS ONE DOCUMENT i

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