ML18073A122

Management Directive 4.1, Accounting Policy and Practices.

ML18073A122
Person / Time
Issue date:	09/09/2016
From:	NRC/OCFO
To:
References
DT-17-121 MD 4.1
Download: ML18073A122 (28)

Text

U.S. NUCLEAR REGULATORY COMMISSION MANAGEMENT DIRECTIVE (MD)

For upd ates or r evisions t o policies c ontained in this M D t hat wer e issued after t he MD was signed , pleas e see t he Yellow Announcement t o Management Directive index (YA-t o-M D i ndex). M D 4.1 ACCOUNTING POLICY AND PRACTICES DT-1 Volume 4: Financial Management Approved By:

Maureen E. Wylie Chief Financial Officer Date Approved:

September 9, 2016

Issuing Office:

Office of the Chief Financial Officer Division of the Controller Contact Name:

Carl Fredericks 301-415-6285EXECUTIVE

SUMMARY

Management Directive (MD) 4.1, "Accounting Policy and Practices," is being revised to reflect organizational changes for Office of the Chief Financial Officer and the Office of the Chief Information Officer; comply with generally accepted accounting principles and standards; and makes updates to align with other Federal financial requirements. There is no handbook for this management directive; however, there is an OCFO Accounting Policy Manual for which OCFO is responsible.

TABLE OF CONTENTS I.POLICY .............................................................................................................................. 2 II.OBJECTIVES

.................................................................................................................... 2III.ORGANIZATIONAL RESPONSIBILITIES AND DELEGATIONS OF AUTHORITY

........... 3 A.Chief Financial Officer (CF O) ........................................................................................ 3 B.Inspector General (IG)

.................................................................................................. 4 C.Office of the Chief Information Officer (OCIO)

.............................................................. 5 D.Director, Office of Administration (ADM)

....................................................................... 5 E.Office Directors and Regional Administrators

............................................................... 6 F.Director, Division of the Controller (DOC), Office of theChief Financial Officer (OCFO)

..................................................................................... 6 G.Budget Director, Division of Planning and Budget (DPB), OCFO

.................................. 7 IV.APPLICABILITY

................................................................................................................ 8 MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

2 V. DIRECTIVE HANDBOOK

.................................................................................................. 8 VI.REFERENCES

.................................................................................................................

10EXHIBITS Exhibit 1 Delegations of Authority to Sign or Approve Fiscal and Accounting Documents

....................................................................

14 Exhibit 2 Guidelines for Capitalization of Information Technology Software

......................

27 I. POLICY It is the policy of the U.S. Nuclear Regulatory Commission to maintain its system of accounting and internal control in accordance with accounting principles and standards set forth in the Statements of Federal Financial Accounting Standards promulgated by the Federal Accounting Standards Advisory Board (FASAB) and to comply with the Budget and Accounting Procedures Act of 1950, as amended; the Federal Managers' Financial Integrity Act of 1982; the Chief Financial Officers Act of 1990; the Federal Financial Management Improvement Act of 1996; and the requirements of other Federal statutes and Government regulations.

II.OBJECTIVES

- Ensure compliance with financial accounting principles, standards, and relat ed requirements issued by the FASAB, the Director of the Office of Management and Budget (OMB), and the Comptroller General.

- Ensure compliance with guidance prescribed by OMB for annual financial statements, with Governmentwide information standards (e.g., the U.S. Government Standard General Ledger), and with other external financial reporting requirements.

- Maintain accounting control over all revenues, costs, expenses, appropriations, obligations, funds, property, and other assets of NRC consistent with providing reasonable assurance that all assets are safeguarded against waste, loss, unauthorized use, and misappropriation.

- Properly record and account for revenues and expenditures applicable to NRC operations so that accounts and reliable financial and statistical reports may be prepared, accountability of the assets may be maintained, and full financial disclosure of all resources managed may be provided.

MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

3 - Provide timely and reliable accounting results using the accrual basis of accounting for allocating resources; for preparation and support of budget requests; for recognizing the full cost of NRC programs, activities, and outputs; and for controlling the execution of the budget.

- Capture and produce financial information required to support the assessment of program performance, financial performance, and financial management performance.

- Provide for the maintenance, retention, and control of fiscal documents and records for management and audit purposes.

III.ORGANIZATIONAL RESPONSIBILITIES AND DELEGATIONS OF AUTHORITY A.Chief Financial Officer (CFO) 1.Establishes and maintains systems of accounting and internal controls as requiredby the Chief Financial Officers Act of 1990 (31 U.S.C. 902 (a) and 3512(b)) and theFederal Managers' Financial Integrity Act of 1982.

2.Submits to the Director of OMB an audited financial statement for the preceding fiscal year, as required by the Chief Financial Officers Act of 1990 (31 U.S.C. 3515(a) and (b) and 31 U.S.C. 3521(e)) and amended by the GovernmentManagement Reform Act of 1994.

3.Reviews, on a biennial basis, fees and other charges imposed by the agency for services and things of value it provides and makes recommendations on revising t he charges to reflect costs incurred by NRC in providing those services and things ofvalue as required by the Chief Financial Officers Act of 1990 (31 U.S.C. 902(a)(8)).

4.Establishes, maintains, and oversees the interpretation and implementation ofpolicies, standards, and general procedures of accounting and related reporting essential to financial integrity, efficient financial management, and safeguarding ofNRC funds and property.

5.Ensures that applicable accounting principles, standards, and requirements are incorporated into agency accounting systems as required by the Chief Financial Officers Act of 1990 (31 U.S.C. 902(a)(3)(A)), the Federal Financial Management Improvement Act of 1996 (31 U.S.C. 3512 note

), and Management Directive(MD)4.3, "Financial Management Systems.

"6.Provides technical accounting advice and guidance to office directors and regional administrators and their staffs on their responsibility for the direct performance ofaccounting functions and on the financial implications of proposed courses of action.

7.Establishes and maintains an internal control program for NRC program an d administrative activities, including a system that reasonably ensures NRC

's managers take the necessary action to determine that controls are functioning asintended or are modified as conditions change.

MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

4 8. Reports the financial status of NRC and the results of its operations; furnishes financial reports to those responsible for managing NRC operations; and provides data for the establishment of fees, the full cost of NRC programs, and other matters needed for the sound financial management of NRC operations.

9. Prepares and issues an annual financial management report required by the Chief Financial Officers Act of 1990 (31 U.S.C. 902(a)(6)).

10. Reviews and approves financial reports and financial statements prepared by all agency offices for transmittal to the Chairman, the Commission, OMB, the President, Congress, or external groups, to assure consistency with Federal financial accounting principles and standards.

11. Exercises authority to sign fiscal and other financial and accounting documents on behalf of NRC pursuant to the NRC Chairman

's memorandum to the CFO dated January 8, 1997, set forth in Exhibit 1 of this directive.

12. Documents financial management systems and processing instructions in either hard copy or electronic form in accordance with the requirements of OMB Circular A

-127, including the Federal Financial Management Systems Requirements. Maintains the instructions on a current basis and makes them readily available for examination.

13. Maintains an Office of the Chief Financial Officer (OCFO) Accounting Policy Manual setting forth the policies and general procedures of accounting and related reporting to be followed by NRC.

14. Establishes and oversees the implementation of policies, standards, and general procedures of accounting for internal use software development projects. Establishes policy for capitalization of information technology (IT) software set forth in Exhibit 2 of this directive.

15. Submits special purpose financial statements to the U.S. Department of the Treasury (U.S. Treasury) for the compilation of the Financial Report of the U.S. Government, as required by amendments to OMB Bulletin No. 01

-02 and U.S. Treasury Financial Manual, Volume 1, Part 2, Chapter 4700 , "Agency Reporting Requirements for the Financial Report of the U.S. Government

" (http://tfm.fiscal.treasury.gov/v1/p2/c470.pdf). B. Inspector General (IG)

In accordance with the Chief Financial Officers Act of 1990

- 1. Audits the annual financial statements in accordance with Government Auditing Standards and OMB requirements as required by 31 U.S.C. 3521(e).

2. Submits to the Chairman a report on the audit of the annual financial statements, as required by 31 U.S.C. 3521(f).

MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

5 3.Submits to the Chairman a report on management

's assertion about theeffectiveness of internal control, and a report of compliance with laws and regulations, as required by amendments to the current version ofOMB Bulletin No. 01-02.4.Audits the Closing Package financial statement in accordance with GovernmentAuditing Standards as required by amendments to the current version ofOMB Bulletin No. 01

-02 and U.S. Treasury Financial Manual, Volume 1, Part 2,Chapter 4700 , "Agency Reporting Requirements for the Financial Report of t he U.S. Government" (http://tfm.fiscal.treasury.gov/v1/p2/c470.pdf

).C.Office of the Chief Information Officer (OCIO) 1.Maintains a centralized inventory of agency IT software as required byOMB Circular A-130. The inventory captures descriptive information provided byNRC offices.

2.In support of the annual audited financial statements, provides OCFO access to a centralized (maintained by the OCIO) inventory of IT software that identifies allagency capitalized IT software purchased, developed, leased, and retired consistentwith guidelines for capitalization of IT software in Exhibit 2 of this directive.

3.Plays a significant role in IT decisions, including annual and multi

-year planning,programming, budgeting, execution, reporting, management, and oversight functions inline with OMB Memorandum M 14, "Management and Oversight of FederalInformation Technology," which provides implementation guidance for the FederalInformation Technology Reform Act (FITARA), enacted on December 19, 2014.

D.Director, Office of Administration (ADM) 1.Maintains physical inventory control of all NRC

-owned capitalized property (exceptcomputer software) and all NRC

-acquired expendable supplies and materials i n accordance with applicable accounting principles and standards.

2.Provides a report of reconciled capitalized property inventory to the Division ofController (DOC), OCFO, on the basis of periodic physical inventory of all NRC-owned property.

3.Provides a monthly report to DOC of capitalized property acquired, disposed of, orretired since the previous report.4.Coordinates the control of capitalized IT software with OCIO to ensure that NRC-funded, NRC

-owned software acquired under interagency agreement projectsis identified in accordance with Handbook 11.7, "NRC Procedures for Placement and Monitoring of Work With the U.S. Department of Energy (DOE),"Section VI II;Handbook 11.8, "Procedures for Managing Property Acquired Through "NRC/DOEProjects,"Section X; and guidelines for capitalization of IT software in Exhibit 2 ofthis directive.

MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

6 E. Office Directors and Regional Administrators

1. Ensure that accounting information (e.g., accounting classification codes) is complete and accurate on accounting documents and when entered into the agency accounting system.

2. Review and verify accounting information in agency accounting system reports for completeness and accuracy.

3. Ensure that IT project managers adhere to agency policies for internal use software development projects and follow the general guidelines set forth in Exhibit 2 of this directive and the memorandum issued by the CFO on April 26, 2005, titled "Adherence to NRC Policies and Procedures

- Accounting for Internal Use Software

." F. Director, Division of the Controller (DOC), Office of the Chief Financial Officer (OCFO) 1. Administers the fiscal and accounting functions and maintains the general ledger accounts for NRC.

2. Exercises authority to sign fiscal and accounting documents as set forth in Exhibit 1 of this directive and as otherwise delegated.

3. Approves all changes of NRC accounting principles and standards, approves revisions to the OCFO Accounting Policy Manual, and requests interpretation of and implements Statements of Federal Financial Accounting Standards issued by the FASAB. 4. Prepares reports on the financial status of NRC and the results of its operations.

5. Prepares quarterly and annual financial statements in accordance with OMB requirements and consistent with applicable accounting principles, standards, and requirements, as required by the Chief Financial Officers Act of 1990 (31 U.S.C. 3515(a) (b)).

6. Prepares quarterly submissions in accordance with the DATA Act. 7. Provides technical advice, assistance, and interpretation to agency senior managers on the NRC

's financial reporting, accounting, financial policy, financial systems, and financial operations activities, including commercial, employee, and Government payments.

8. Develops and administers policies, standards, and procedures for all financial operation activities of NRC

. 9. Provides time and labor, travel, payment, and fiscal services for NRC. Manages the NRC Central Allowance.

MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

7 10.Appoints authorized certifying officers in accordance with applicable legal a nd Department of the U.S. Treasury requirements and pursuant to the NRC Chairman

's memorandum to the CFO, dated January 8, 1997.

11.Manages the NRC Central Allowance for the agency

's small offices and the agency's travel allocations with the exception of the OIG

.12.Provides debt management services to NRC in coordination with U.S. Treasuryrequirements.

13.Develops and administers policies, standards, and procedures for all NRC financialsystems and for NRC accounting and license fee activities. Develops and maintainsfinancial systems for general accounting, cost accounting, fees, and capitaliz ed property.14.Maintains operational responsibility and oversight for the budget formulation system,time and labor system, e-travel system, task assignment control system, and th e agency core accounting system

.15.Provides technical advice and overall coordination for agency financial systems.

16.Defines requirements for, coordinates, and oversees an agency wide financialinternal controls program to comply with the Federal Managers' Financial IntegrityAct of 1982 and OMB Circular A

-123.17.Maintains liaison with U.S. Government Accountability Office (GAO), U.S. Treasury,OMB , and other agencies on accounting, financial system s, and reporting matters.

G.Budget Director, Division of Planning and Budget (DPB), OCFO 1.Manages the agency

's Planning, Budgeting, and Performance Management (PBPM)Process.2.Provides agency senior management with independent analyses of policy, program,and resource issues.

3.Manages the budget formulation and resource/performance management process.

4.Develops and maintains policies, procedures, and operations to formulate and i mplement the approved NRC budget.

5.Develops and administers NRC authorization and appropriation legislation.

6.Oversees the agency

's administrative control of funds.

7.Approves and issues advice of allowances and financial plans.

8.Administers the NRC

's licensee fee program and provides managerial oversight of NRC's license fee policy functions.

Develops and publishes the NRC

's fee rule eachyear. Formulates standards and procedures for license fee policy. Interprets licens e

MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

8 fee regulations (10 CFR Parts 170 and 171). Processes Part 170 license fee waiver and exemption requests. 9.Manages the production and publication of the agency

's annual Performanc e and Accountability Report.

10.Maintains liaison with OMB and congressional committees, as directed.

11.Exercises authority to sign fiscal and accounting documents set forth in Exhibit 1 ofthis directive and as otherwise delegated.IV.APPLICABILITYThe policy and guidance in this directive apply to all NRC employees.

V.DIRECTIVE HANDBOOKThere is no handbook associated with MD 4.1. Instead, there is an OCFO Accounting PolicyManual , available at http://drupal.nrc.gov/ocfo, for which OCFO is responsible. T heaccounting policy manual contains office procedures relevant to this directive to ensure thatapplicable agency objectives identified in Section II of this directive are met. Officeprocedures address the following specific Federal requirements

1.GAO Policy and Procedures Manual for Guidance of Federal Agencies(a)Title 4, "Claims."(b)Title 6, "Pay, Leave, and Allowances.

"(c)Title 7, "Fiscal Guidance.

"2.Office of Management and Budget (OMB) Circulars(a)A-11, "Preparation, Submission and Execution of the Budget," June 30, 2 015 (revised annually).(b)A-25, "User Charges," July 8, 1993.(c)A-102, "Grants and Cooperative Agreements with State and LocalGovernments," August 29, 1997.(d)A-123, "Management

's Responsibility for Internal Control," December 21, 2004.(e)A-127, "Financial Management Systems," January 9, 2009.(f)A-129, "Policies for Federal Credit Programs and Non

-Tax Receivables,"January 20, 2013.(g)A-130, "Management of Federal Information Resources," November 28, 2000.

MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

9 (h)A-134, "Financial Accounting Principles and Standards," May 20, 1993.(i)A-136, "Financial Reporting Requirements," August 4, 2015 (revised annually).

3.Statements of Federal Financial Accounting Concepts (SFFAC)(a)No. 1, "Objectives of Federal Financial Reporting," September 2, 1993.(b)No. 2, "Entity and Display," June 6, 1995.(c)No. 3, "Management

's Discussion and Analysis," June 8, 1999

.(d)No. 4, "Intended Audience and Qualitative Characteristics for the Consolidat ed Report of the United States Government," January 27, 2003.(e)No. 5, "Definitions and Basic Recognition Criteria for Accrual-Basis FinancialStatements," December 26, 2007.(f)No. 6, "Distinguishing Basic Information, Required Supplementary Information,and Other Accompanying Information," February 4, 2009

.(g)No. 7, "Measurement of the Elements of Accrual

-Basis Financial Statements inPeriods after Initial Recording," August 16, 2011.

4.Statements of Federal Financial Accounting Standards (SFFAS)(a)No. 1, "Accounting for Selected Assets and Liabilities," March 30, 1993.(b)No. 3, "Accounting for Inventory and Related Property," October 27, 1993.(c)No. 4, "Managerial Cost Accounting Concepts and Standards for the FederalGovernment," July 31, 1995.(d)No. 5, "Accounting for Liabilities of the Federal Government,"December 20, 1995.(e)No. 6, "Accounting for Property, Plant, and Equipment," November 30, 1995.(f)No. 7, "Accounting for Revenue and Other Financing Sources and Concepts forReconciling Budgetary and Financial Accounting," as amended October 2001.(g)No. 10, "Accounting for Internal Use Software," October 9, 1998.(h)No. 12, "Recognition of Contingent Liabilities Arising From Litigation: AnAmendment of SFFAS No. 5, Accounting for Liabilities of the FederalGovernment," February 5, 1999.(i)No. 15, "Management

's Discussion and Analysis," August 12, 1999.(j)No. 21, "Reporting Corrections of Errors and Changes in Accounting Principles,"September 30, 2001.

MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

10 (k)No. 22, "Change in Certain Requirements for Reconciling Obligations and NetCost of Operations," October 22, 2001.(l)No. 30, "Inter-Entity Cost Implementation," August 15, 2005.(m) No. 34, "The Hierarchy of Generally Accepted Accounting Principles, Includingthe Application of Standards Issued by the Financial Accounting StandardsBoard," July 28, 2009.(n)No. 39, "Subsequent Events: Codification of Accounting and Financial ReportingStandards Contained in the AICPA Statements on Auditing Standards,"August 4, 2010.(o)No. 40, "Definitional Changes Related to Deferred Maintenance and Repairs,"May 11, 2011.(p)No. 42, "Deferred Maintenance and Repairs," April 25, 2012.(q)No. 44, "Accounting for Impairment of General Property, Plant, and EquipmentRemaining in Use," January 3, 2013.(r)No. 47, "Reporting Entity," December 23, 2014.VI.REFERENCESCode of Federal Regulations5 CFR Part 1315, "Prompt Payment." 10 CFR Part 15, "Debt Collection Procedures." 10 CFR Part 16, "Salary Offset Procedures for Collecting Debts Owed by Federal Employees to the Federal Government." 10 CFR Part 170, "Fees for Facilities, Materials, Import and Export Licenses, and Other Regulatory Services under the Atomic Energy Act of 1954, As Amended."

10 CFR Part 171, "Annual Fees for Reactor Licenses and Fuel Cycle Licenses and Materials Licenses, Including Holders of Certificates of Compliance, Registrations, Quality Assurance Program Approvals and Government Agencies Licensed by the NRC." 31 CFR Parts 900

-904, "Federal Claims Collection Standards." Federal Accounting Standards Advisory Board (FASAB)

Statements of Federal Financial Accounting Concepts (SFFAC), available at http://www.fasab.gov. Statements of Federal Financial Accounting Standards (SFFAS), available at http://www.fasab.gov.

MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

11 General Services Administration Federal Acquisition Regulation, available at https://www.acquisition.gov. Federal Management Regulation, available at http://www.gsa.gov/federalmanagementregulation. Federal Property Management Regulation, available at http://www.gsa.gov/portal/category/102735. Government Accountability Office (GAO) Decisions of the Comptroller General of the United States, available at http://www.gao.gov/legal. GAO General Policy and Procedures Manual for Guidance of Federal Agencies GPPM-97-SE, available at http://www.gao.gov/products/GPPM SE. Nuclear Regulatory Commission OCFO Accounting Policy Manual, available at http://drupal.nrc.gov/ocfo. Management Directive

- 4.2, "Administrative Control of Funds." 4.3, "Financial Management Systems." 4.4, "Internal Control." 4.6, "License Fee Management Program." 9.20, "NRC Organization and Functions, Office of the Chief Financial Officer." 11.1, "NRC Acquisition of Supplies and Services." 11.7, "NRC Procedures for Placement and Monitoring of Work with the U.S. Department of Energy (DOE)." 11.8, "NRC Procedures for Placement and Monitoring of Work with Federal Agencies other than U.S. Department of Energy (DOE) Laboratory Work." 13.1, "Property Management." 14.1, "Official Temporary Duty Travel." 14.2, "Relocation Allowances." NRC Memorandum from Chairman Shirley Ann Jackson to the Acting Chief Financial Officer Ronald Scroggins , "Delegations of Authority," January 8, 1997 (ML12156A033).

MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

12 NRC Memorandum from Jessie L. Funches, Chief Financial Officer, to Those on the Attached List, "Adherence to NRC Policies and Procedures - Accounting for Internal Use Software ," April 26, 2005 (ML051170062). NRC Memorandum from Reginald W. Mitchell, Controller, Office of the Chief Financial Officer, to Those on the Enclosed List, "Adherence to U.S. Nuclear Regulatory Commission Policies and Procedures - Accounting for Internal Use Software,"

August 29, 2012 (ML12243A467

). Office of Management and Budget (OMB) Circulars OMB Bulletin No. 01-02 , "Audit Requirements for Federal Financial Statements," October 16, 2000, available at https://www.whitehouse.gov/sites/default/files/omb/assets/omb/bulletins/b01

-02.pdf. OMB Circulars, available at http://www.whitehouse.gov/omb/circulars_default/. A-123, "Management

's Responsibility for Internal Control," December 21, 2004.A-127, "Financial Management Systems," January 9, 2009.A-130, "Management of Federal Information Resources," November 28, 2000.OMB Memorandum M 14, "Management and Oversight of Federal Information Technology," June 10, 2015, available at https://www.whitehouse.gov/sites/default/files/omb/memoranda/2015/m 14.pdf. U.S. Treasury Financial Manual, Volume 1, Part 2, Chapter 4700, "Agency Reporting Requirements for the Financial Report of the U.S. Government," available at http://tfm.fiscal.treasury.gov/v1/p2/c470.pdf. United States Code Antideficiency Act (31 U.S.C. 1341

-42, 1349-51, and 1511

-19). Budget and Accounting Procedures Act of 1950, as amended (31 U.S.C. 3511

-3515 and 3521). Chief Financial Officers Act of 1990, as amended (31 U.S.C. 501

-506, 901-903, 3512(a) and (b), 3515, 3521 (e)

-(h), and 9105

-9106). Debt Collection Act of 1982, subsequently amended by Pub. L. No. 101

-552 and Pub. L. No. 104-134 (31 U.S.C. 3701

-3720). Department of the Treasury

- U.S. Treasury Financial Manual, U.S. Treasury Circulars, Bulletins, and Management Letters.

Digital Accountability and Transparency (DATA) Act (Public Law 113

-101, 128 Stat 1146). Documentary Evidence Requirement for Government Obligations (31 U.S.C. 1501).

MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

13 Economy Act of 1932, as amended (31 U.S.C. 1535).

Federal Financial Management Improvement Act of 1996 (31 U.S.C. 3512 et seq.).

Federal Managers' Financial Integrity Act of 1982 (31 U.S.C. 3512 et seq. and 31 U.S.C. Chapter 11).

Federal Property and Administrative Services Act of 1949 (40 U.S.C. 486 and 41 U.S.C. 255). General Accounting Office Act of 1996, which amends 5 U.S.C. 5584 and

31 U.S.C. 3529 (Pub. L. 104-316). Independent Offices Appropriations Act of 1952, Title V (31 U.S.C. 9701).

Omnibus Budget Reconciliation Act of 1990, as amended (42 U.S.C. 2214).

Prompt Payment Act of 1982, as amended (31 U.S.C. 3901 et seq.).

Recording Statute (31 U.S.C. 1501(a) and 1502(a)).

MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

14 EXHIBIT Exhibit 1 Delegations of Authority to Sign or Approve Fiscal and Accounting Documents ACTION DELEGATED TO REFERENCES 1.Approve transfer of appropriation to another Federal agency (SF 1151) a.Transfer withoutbenefit t o transferring account b.Transfer for establishment of transferappropriation forbenefit of advanci ng accountController, DOC 31 U.S.C. 1531(a)(1) at http://www.law.cornell.edu/uscode/search/display.html?terms=1531&url=/uscode/html/uscode31/usc_sec_31_00001531

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000-.html I TFM 2-2060.20 at http://tfm.fiscal.treasury.gov/v3/p2/c2000.html 31 U.S.C. 1532 at http://www.law.cornell.edu/uscode/search/display.html?terms=1532&url=/uscode/html/uscode31/usc_sec_31_00001532

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000-.html I TFM 2-2035.10 and 2035.20 at http://www.fms.treas.gov/TFM/vol1/v1p2c200.html 2.Issue orders revoking or suspending alicense fornonpayment of licensefees CF O Delegation by Chairman to CFO, 1-8-97 10 CFR 2.202 at http://www.nrc.gov/reading

-rm/doc-collections/cfr/part002/part002

-0202.html 10 CFR 15.29 at http://www.nrc.gov/reading

-rm/doc-collections/cfr/part015/part015

-0029.html 10 CFR 170.41 at http://www.nrc.gov/reading

-rm/doc-collections/cfr/part170/part170

-0041.html 10 CFR171.23 at http://www.nrc.gov/reading

-rm/doc-collections/cfr

/part171/part171

-0023.html MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

15 ACTION DELEGATED TO REFERENCES 3.Certifying officers (payments), Secure Payments System (SPS) security administrators, andcashiers a.Designate certifyi ng officers, SPS securityadministrators, SP S users, SPS dat a entry operators,designated agentsto receive U.S.Treasury checksand bonds for distribution, andappoint principal a nd alternate cashiers(FMS Form 2958)Controller, Deputy Controller, DOC I TFM 4-1135 & 4-1140 I TFM 4-1145 & 4-1150 I TFM 4-1155 & 4-1160 http://www.fms.treas.gov/TFM/vol1/v1p4c110.txt b.Certify payments t o other Federalagencies (SF 1081)Controller, DOC I TFM 2-2535.10 at http://www.fms.treas.gov/TFM/vol1/v1p2c250.txt c.Request decisionsregarding proprietyof payment(1)from OGC, i f payment is $10 0 or less,regardless ofpayment type(2)from GSA fortemporary duty travel , transportation,and relocatio n expenses(3)from OPM for personnel compensati on and leave(4)from U.S.Treasury forjudgmentsCertifying Officers Controller, Deputy Controller, DOC 31 U.S.C. 3529 at http://www4.law.cornell.edu/uscode/31/3529.html OMB Determination Order, 12 96 at http://www.whitehouse.gov/omb/foia/gc_dec17.pdf DOJ Order 2110.39A CG Decision B

-275605, 3-17-97 at http://redbook.gao.gov/18/fl0085060.pdf OGC opinion, 5 96 7 GAO 8.3 MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

16 ACTION DELEGATED TO REFERENCES 3.Continued(5)fromDepartment of Defense forclaims bytransportatio n carriers fo r amountscollected fromthem for loss or dam age incurred t o property incidentto shipment at Governmentexpense(6)from OGC and,if determi ned appropriate byOGC, the C G for mattersinvolving use ofappropriat ed f unds(7)from OGC for a ll other types ofclaims d.Grant relief to acertifying officer of liability for anypayment found notto be proper, t o inclu de an overpayment oftransportatio n services made to acommon carrierCG and OGC (for over $100)

OGC ($100 or less) 31 U.S.C. 3528(b) & (c) at http://www4.law.cornell.edu/uscode/31/3528.html DOJ Order 2110.39A 7 GAO 8.8 and 8.11 CG Decision B

-275605, 317

-97 at http://redbook.gao.gov/18/fl0085060.pdf OGC opinion, 5 96 MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

17 ACTION DELEGATED TO REFERENCES

3. Continued e. Approve prompt payment discounts Controller, Deputy Controller, DOC MD 11.1 at http://www.nrc.gov/reading

-rm/doc-collections/management-directives/

31 U.S.C. 3904 at http://www4.law.cornell.edu/uscode/html/uscode31/usc_sec_31_00003904

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000-.html f. Approve making payment up to 7 days prior to the required payment date , or earlier as determined by the agency to be necessary on a case-by-case basis Controller, Deputy Controller, DOC 31 U.S.C. 3903 (a)(8) at http://www4.law.cornell.edu/uscode/html/uscode31/usc_sec_31_00003903----000-.html 4. Payment of Certain Liabilities

a. Approve tort claims (1) Up to $2,500 Controller, DOC MD 7.1 at http://www.nrc.gov/reading

-rm/doc-collections/management-directives/

(2) Over $2,500 OGC MD 7.1 at http://www.nrc.gov/reading

-rm/doc-collections/management-directives/

b. Approve claims for personal property damage or loss Controller, DOC MD 7.2 at http://www.nrc.gov/reading

-rm/doc-collections/management-directives/

c. Approve amounts due deceased public creditors Controller, Deputy Controller, DOC 4 GAO 5 Sect. 35.2

d. Approve claims relating to loss or damage to shipments Controller, Deputy Controller, DOC 4 GAO 8 Sect. 53

e. Recommend payment of meritorious claims OGC 31 U.S.C. 3702(d) at http://www4.law.cornell.edu/uscode/31/usc_sec_31_00003702

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000-.html MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

18 ACTION DELEGATED TO REFERENCES 4.Continued f.Approve interestpenalties on lat e payments under th e Prompt Payment Act(1)Up to $2,500 Controller, Deputy Controller, DOC MD 11.1 at http://www.nrc.gov/reading

-rm/doc-collections/management-directives/

31 U.S.C. 3902 at http://www4.law.cornell.edu/uscode/31/usc_sec_31_00003902

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000-.html (2)Over $2,500Controller, DOC g.Approve additionalinterest penalties under the Prompt Payment ActController, Deputy Controller, DOC MD 11.1 at http://www.nrc.gov/reading

-rm/doc-collections/management-directives/

31 U.S.C. 3902(c)(3) at http://www4.law.cornell.edu/uscode/31/usc_sec_31_00003902

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000-.html 5.Debt Collection a.Terminate, suspend,or compromis e collection action 31 U.S.C. 3711(a) at http://www4.law.cornell.edu/uscode/html/uscode31/usc_sec_31_00003711----000-.html OMB Cir. A-129 at https://www.whitehouse.gov/omb/circulars_default/

(1)Up to $10,000Controller, Deputy Controller, DOC (2)Over $10,0 00 and up t o$100,000CFO (3)Over $100,000DOJ b.Approve or denywaiver of erroneousoverpayment of pay and travel allowances 5 U.S.C. 5584 at http://www4.law.cornell.edu/uscode/search/display.html?terms=5584&url=/uscode/html/uscode05/usc_sec_05_00005584

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000-.html OMB Determination Order, 12 96 DOJ Order 2210.39A OGC opinion, 5 96 O PM's OGC Opinion, 06 99 (1)Up to $1,500CFO (2)Over $1,50 0 (must be supported byOGC opinion)CFO MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

19 ACTION DELEGATED TO REFERENCES 5.Continued c.Approve options forsettlement ofemployeeindebtednessController, DOC MD 10.62, Section 037(c) at http://www.nrc.gov/reading

-rm/doc-collections/management-directives/

10 CFR 15.33 at http://www.nrc.gov/reading

-rm/doc-collections/cfr/part015/part015

-0033.html 10 CFR 16.15 at http://www.nrc.gov/reading

-rm/doc-collections/cfr/part016/part016

-0015.html d.Approve referri ng commercial debt t o credit reporti ng agenc yController, Deputy Controller, Chief, Accounts Receivable Branch, DOC OMB Cir. A

-129 at http://www.whitehouse.gov/omb/circulars_default/

e.Approve referri ng delinquent debtor t o credit reporti ng agenc yController, Deputy Controller, Chief, Accounts Receivable Branch, DOC OMB Cir. A

-129 at http://www.whitehouse.gov/omb/circulars_default/

31 U.S.C. 3711 at http://www4.law.cornell.edu/uscode/uscode31/usc_sec_31_00003711

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000-.html 31 CFR 901.5 at http://www.access.gpo.gov/nara/cfr/waisidx_03/31cfr901_03.html 10 CFR 15.26 at http://www.nrc.gov/reading

-rm/doc-collections/cfr/part015/part015

-0026.htm l MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

20 ACTION DELEGATED TO REFERENCES

5. Continued f. Approve referring uncollectible accounts to debt collection agency Controller, Deputy Controller, Chief, Accounts Receivable Branch, DOC OMB Cir. A

-129 at http://www.whitehouse.gov/omb/circulars_default/

31 U.S.C. 3718 at http://www4.law.cornell.edu/uscode/31/3718.html

10 CFR 15.32 at http://www.nrc.gov/reading

-rm/doc-collections/cfr/part015/part015

-0032.html 31 CFR 901.5 at http://www.access.gpo.gov/nara/cfr/waisidx_03/31cfr901_03.html

g. Assess a penalty charge of up to 6 percent for not paying a part of a debt more than 90 days past due Controller, Deputy Controller, Chief, Accounts Receivable Branch, DOC 31 U.S.C. 3717(e)(2) at http://www4.law.cornell.edu/uscode/html/uscode31/usc_sec_31_00003717----000-.html 10 CFR 15.37(g) at http://www4.law.cornell.edu/uscode/html/uscode31/usc_sec_31_00003717----000-.html h. Assess a charge for cost of processing a delinquent claim Controller, Deputy Controller, Chief, Accounts Receivable Branch, DOC 31 U.S.C. 3717(e)(1) at http://www4.law.cornell.edu/uscode/html/uscode31/usc_sec_31_00003717----000-.html 10 CFR 15.37(f) at http://www.nrc.gov/reading

-rm/doc-collections/cfr/part015/part015

-0037.html MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

21 ACTION DELEGATED TO REFERENCES 5.Continued i.Waive collection ofinterest, penalties, and administrativ e co st s 31 U.S.C. 3717(h) at http://www4.law.cornell.edu/uscode/html/uscode31/usc_sec_31_00003717

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000-.html 10 CFR 15.37(j) and 10 CFR 15.37(k) at http://www.nrc.gov/reading-rm/doc-collections/cfr/part015/full

-text.html#part015

-0037 31 CFR 901.9 at http://www.access.gpo.gov/nara/cfr/waisidx_03/31cfr901_03.html (1)Up to $100Accounts Receivable Contractor (2)$100.01 to $500Accounts Receivable Branch Chief (3)$500.01 t o$5,000Controller, Deputy Controller, DOC (4)Over $5,000CFO j.Furnish informati on t o OGC who willforward t o appropriate U.S.Attorney upon t he filing of a petition inbankruptcy by a debt orController, Deputy Controller, Chief, Accounts Receivable Branch, DOC 10 CFR 15.39 at http://www.nrc.gov/reading

-rm/doc-collections/cfr/part015/part015

-0039.html k.Refer claim to DOJController, DOC 10 CFR 15.67 at http://www.nrc.gov/reading

-rm/doc-collections/cfr/part015/part015

-0067.html 31 CFR 904.1 at http://www.access.gpo.gov/nara/cfr/waisidx_03/31cfr904_03.html l.Refer claim to DOJfor advice whe n there is doubtwhether collecti on action should be suspended orterminatedController, DOC 10 CFR 15.

65 at http://www.nrc.gov/reading

-rm/doc-collections/cfr/part015/part015

-0065.html 31 CFR 904 at http://www.access.gpo.gov/nara/cfr/waisidx_03/31cfr904_03.html

MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

22 ACTION DELEGATED TO REFERENCES 5.Continued m.Refer a debtor

's firmwritten offer ofcompromise that issubstantial inamount to DOJ if there is uncertainty on accepting offerController, DOC 31 CFR 904.1(b) at http://www.access.gpo.gov/nara/cfr/waisidx_03/31cfr904_03.html 10 CFR 15.65 at http://www.nrc.gov/reading

-rm/doc-collections/cfr/part015/part015

-0065.html n.Approve installmentpayment plan forrepayment of debt to

NRCController, Deputy Controller, Chief, Accounts Receivable Branch, DOC 10 CFR 15.35(b) at http://www.nrc.gov/reading

-rm/doc-collections/cfr/part015/part015

-0035.html 31 CFR 901.8 at http://www.access.gpo.gov/nara/cfr/waisidx_03/31cfr901_03.html o.Appoint hearin g official for employ ee disputing a debtCFO 10 CFR 16.9 at http://www.nrc.gov/reading

-rm/doc-collections/cfr/part016/part016

-0009.html p.Approve salaryoffset for recovery oferroneous paymentController, DOC 5 U.S.C. 5512(a) at http://frwebgate.access.gpo.gov/cgi

-bin/getdoc.cgi?dbname=2000_uscode&docid=5usc5512 10 CFR 16.15 at http://www.nrc.gov/reading

-rm/doc-collections/cfr/part016/part016

-0015.html q.Approve offset ofamount owed by a separated employe e against CSRS orFERS funds Controller, DOC 31 CFR 901.3 at http://www.access.gpo.gov/nara/cfr/waisidx_03/31cfr901_03.html 10 CFR 15.33(b) at http://www.nrc.gov/reading

-rm/doc-collections/cfr/part015/part015

-0033.html 10 CFR 16.13(a)(8) at http://www.nrc.gov/reading

-rm/doc-collections/cf r/part016/part016

-0013.html MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

23 ACTION DELEGATED TO REFERENCES

5. Continued r. Approve referral of delinquent debt to U.S. Treasury for offset against tax refund Controller, DOC 31 U.S.C. 3720A at http://www.law.cornell.edu/uscode/search/display.html?terms=3720a&url=/uscode/html/uscode31/usc_sec_31_00003720

---A00 0-.html 6. Approve MOUs under GSA contracts

a. Government Travel Card Deputy CFO MD 11.8 at http://www.internal.nrc.gov/policy/directives/toc/md11.8.htm b. Travel Management Center Deputy CFO 7. Issue standard financial reports to central agencies

a. Report on Budget Execution (SF 133)

Controller, DOC OMB Cir. A

-11 at http://www.whitehouse.gov/omb/circulars_default/

b. U.S. Treasury Report on Receivables Due From the Public (TROR) Controller, Deputy Controller, Chief, Accounts Receivable Branch, DOC OMB Cir. A

-129 at http://www.whitehouse.gov/omb/circulars_default/

U.S. Treasury Memo, 8 94 9-12-07 Memo to CFO

c. Reports on International Transactions Controller, DOC D. Comm. Dir 19

d. Statement of Transactions (SF 224) Controller, Deputy Controller, Chief, Financial Reporting and Analysis Branch, DOC I TFM 2-3300 at http://www.fms.treas.gov/TFM/vol1/v1p2c330.html 31 U.S.C. 3512 at http://www.law.cornell.edu/uscode/html/uscode31/usc_sec_31_00003512

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000-.html e. Unexpended Balances of Appropriations and Funds (FMS Form 2108) Controller, DOC 31 U.S.C. 3513 at http://www.law.cornell.edu/uscode/html/uscode31/usc_sec_31_00003513

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000-.html I TFM 2-4200 at http://www.fms.treas.gov/TFM/vol1/v1p2c420.html

f. Apportionment and Reapportionment Schedule (SF 132)

Budget Director, DPB OMB Cir. A

-11 at http://www.whitehouse.gov/omb/circulars_default/

MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

24 ACTION DELEGATED TO REFERENCES 7.Continued g.Quarterly FinancialStatement and FluxAnalysisController, Deputy Controller, DOC NRC Internal Control Procedures h.Quarterly Intra

-governmental Statusof Dispositi on Certificati on and Intra-governmentalClosing Pack age MaterialDifferences/Statusof Dispositi on Certification ReportController, Deputy Controller , Chief, Financial Reporting and Analysis Branch , DOC Federal Intra

-governmental Transactions Policy Guide i.Intra-governmentalClosing Pack age MaterialDifferences/Status of Dispositi on Certification ReportController, Deputy Controller , Chief, Financial Reporting and Analysis Branch , DOC TFM Chapter 4700 at http://tfm.fiscal.treasury.gov/v1/p2/c470.html j.Closi ng Package/GFRSController, Deputy Controller , Chief, Financial Reporting and Analysis Branch , DOC TFM Chapter 4700 at http://tfm.fiscal.treasury.gov/v1/p2/c470.html k.CFORepresentations forFederal Intra

-governmentalActivity a nd BalancesController, Deputy Controller , Chief, Financial Reporting and Analysis Branch , DOC TFM Chapter 4700 at http://tfm.fiscal.treasury.gov/v1/p2/c470.html l.GTAS Adjusted TrailBalanceController, Deputy Controller , Chief, Financial Reporting and Analysis Branch ,

DOC TFM Chapter 4700 at http://tfm.fiscal.treasury.gov/v1/p2/c470.html m.US Standar d General Ledger(USSGL) VotingBoard RepresentativeController, Deputy Controller , Chief, Financial Reporting and Analysis Branch ,

DOC USSGL Board Statement of Purpose and Bylaws at https://www.fiscal.treasury.gov/fsreports/ref/ussgl/ussgl_home.htm

MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

25 ACTION DELEGATED TO REFERENCES 8.Develop for CFOsignature proposed and final rules

, including annualrevisions to feeregulations in

10 CFR 170 and 1 71 that do not involvesignificant policy issuesBudget Director, DPB Delegation by Chairman to CFO, 2-18-97 5 U.S.C. 551(4) at https://www.gpo.gov/fdsys/pkg/USCODE

-2010-title5/pdf/USCODE

-2010-title5-partI-chap5-subchapII-sec551.pdf 9.Approve or denyrequests for exemption under 10 CF R Parts 170 and 171CFO Delegation by Chairman to CFO, 1-8-97 10 CFR Part 170.11 at http://www.nrc.gov/reading

-rm/doc-collections/cfr/part170/part170

-0011.html 10 CFR Part 171.11 at http://www.nrc.gov/reading

-rm/doc-collections/cfr/part171/part171

-0011.html MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

26 EXHIBIT 1 - NOTES Delegations of signature or approval authority are in accordance with cited reference. Limitations on further redelegations of authority that the CFO redelegates are stipulated. See MDs 14.1 and 14.2 for delegations of signature authority for travel documents. "Certifying officers" as used in this exhibit refers only to those individuals designated to certify payments to the U.S. Treasury and does not refer to "funds certifying officers" or other "certifying officials." The following abbreviations are used:

CFO Chief Financial Officer, NRC CFR Code of Federal Regulations CG Comptroller General of the United States CSRS Civil Service Retirement System D.Comm. Dir. Department of Commerce directiveDOJ Department of Justice FASB Federal Accounting Standards Advisory Board FERS Federal Employees' Retirement System FMS Cashier M FMS (U.S. Treasury Financial Management Service) Manual of Procedures and Instructions for Cashiers GAO Government Accountability Office ("4 GAO" indicates Title 4 of the GAO Policy and Procedures Manual)

GSA General Services Administration MD NRC Management Directive MOU Memorandum of Understanding OF Optional Form OGC Office of the General Counsel, NRC OMB Office of Management and Budget OMB Cir. Office of Management and Budget Circular OPM Office of Personnel Management SF Standard Form SPS Secure Payments System TFM U.S. Treasury Financial Manual ("I TFM" indicates Volume I of the TFM)

U.S. TreasuryDepartment of the Treasury U.S.C. United States Code

MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

27 Exhibit 2 Guidelines for Capitalization of Information Technology Software 1.Information technology (IT) software includes the application and operating systemprograms, procedures, rules, and any associated documentation pertaining to the operation of a computer system. The software must be intended to meet the NRC

's internal needs. The software may be purchased, internally developed, or contractordeveloped.

2.IT software with a planned estimated useful life of 2 years or more and a pl anned total cost of equal to or greater than the NRC capitalization threshold, currently$50,000, shall be capitalized, with the following exceptions:(a)"Analytical codes" represent research and development software costs an d therefore should not be capitalized.

"Analytical codes" are analytical tools and models used to research safety issues and are constantly revised as a result ofincreased understanding of the complex interactions of some aspect of nuclearregulatory activities.(b)IT efforts to take corrective or adaptive action to keep IT software performing as originally designed should not be capitalized.(c)IT efforts associated with the preliminary project stage before the IT capital planning and investment control process approval of a development project should not be capitalized.3.Leased IT software shall be classified as a capital lease if it covers 2 years or more,meets the capitalization threshold, and meets one or more of the following four criteria:(a)The lease transfers ownership of the IT software to NRC by the end of the leas e term.(b)The lease contains an option to purchase leased IT software at a bargain price.(c)The lease term is equal to or greater than 75 percent of the estimated economiclife of the leased IT software.(d)The present value of rental and other minimum lease payments, excluding that portion of the payments representing executory cost, equals or exceeds 90 percent of the fair value of the leased property.(e)The last two criteria are not applicable when the beginning of the lease term fallswithin the last 25 percent of the total estimated economic life of the leas ed IT software.

MD 4.1 ACCOUNTING POLICY AND PRACTICES Date Approved:

09/09/20 16 For the latest version of any NRC directive or handbook, see the online MD Catalog.

28 4.IT software shall be considered to be impaired, and therefore retired, for any of thefollowing reasons:(a)The software is no longer expected to possess substantive service potential and will be removed from service.(b)Significant reduction occurs in the capabilities, functions, or uses of the software.(c)A significant program change is required for the software to continue to performthe functions it performed in the past.

5.NRC staff costs and indirect costs attributable to capitalized IT software need to be separately identified and capitalized if incurred

.