Exam 3 - Section 3 Internal Controls Flashcards
What is an internal control/management control? And why are they implemented?
The systems and method managers use to provide reasonable assurance that their organizations accomplish what is intended in an efficient and effective manner, while avoiding undesirable results, producing reliable reports, and comply with rules and regulations to safeguard its assets
To accomplish certain results, prevent problems or or detect problems that have occurred
What is an example of an internal control when you:
1. Want to wake up by a certain time
2. Retire by 60
Getting to work on time
- Control Objective: wake up by a certain time
- Control activity have alarm go off at that time
Retiring by 60
- control objective: to retire by 60
- control activity: contribute to 401(k) plan, or that you save a certain amount each day.
What is the expectation of a control?
To provide reasonable assurance of accomplishing the objectives
Controls are not infallible, and could be a circumvented
What did the Budget and Accounting Procedure Act of 1950 require?
Requires each federal agency head to establish and maintain internal controls
What does the Federal Managers’ Financial Integrity Act of 1982 (FMFIA) require?
- Requires GAO to prescribe standards of internal control (GAO issued Standards for Internal Control in the Federal Government?
- requires the Director of OMB to establish guidelines for the valuation agencies of their systems of internal control
- requires agency heads to evaluate controls on annual basis, report any control weaknesses and provide corrective action plans
What did the Single Audit Act of 1984 (amended in 1996) require?
- requires audit with state/local governments and NFP organizations receiving federal, financial assistance
- the objectives of the audits include the terminate whether the recipient has adequate internal accounting controls and applies with laws and regulations
What did the Sarbanes-Oxley Act of 2002 require? Why was it enacted?
- requires publicly traded companies to include an assessment of the effectiveness of controls for financial reporting in its annual report
- requires the auditor to attest to and report on management’s assessment
- it was enacted as a result of financial and accounting scandals in 2000 and 2001
Why was the Fraud Reduction and Data Analytics Act of 2015 enacted?
To improve federal agency financial and administrative controls and procedures to assess and mitigate fraud risks
- to improve federal agencies development, and use of data analytics for the purpose of identifying, preventing, and responding to fraud, including improper payments
- required OMB to establish guidelines for federal agencies to use GAO’s A Framework for Managing Fraud Risks in the Federal Programs to implement control, activities related to fraud management
- Requires agencies to based approach to design and implement controls to mitigate identified fraud risks
What did the CFO Act of 1990 (CFO Act) require?
- Requires the CFO to develop and maintain an integrated agency, accounting and financial management system, including financial reporting and internal controls
- Required a pilot of federal agencies produced an annual audited financial report and a report on internal control
What did the Government Management Reform Act of 1994 (GMRA) require?
Expanded the requirements of the CFO Act I requiring 24 CFO Act agencies to prepare audited, financial statements, and by mandating and audited annual consolidated financial statement for the executive branch of the federal government
What did the Federal Financial Management Improvement Act of 1996 (FFMIA) require?
Requires agencies to follow federal accounting standards, financial management system requirements for the federal government and the treasury, standard general ledger at the transaction level necessitating sound internal controls
What did the Accountability of Tax Dollars Act of 2002 require?
It expanded the requirement for an annual audit to virtually every federal agency
What does OMB Circular A-123 management responsibility for enterprise risk management and internal control require?
- Financial managers must establish and achieve goals and objectives, seizing opportunities to improve efficiency and effectiveness of operations, reliable, reporting, and compliance with laws and regulations
- Implementing and managing practices to identify, assess, respond, and report on risks
- Requires agencies to integrate risk management and internal control functions
What does GAO’s standards for internal controls in the federal government (green book) require?
Required and outlines processes that management must implement in order to
Assess and improve internal controls over compliance, operations, and reporting
What compliance requirements should agencies consider when implementing OMB circular A-123?
- Management is responsible for governance structure effectively implement, direct oversee the implementation of circular A 123 and all the provisions of a robust internal control and risk assessment process
- Agency should leverage existing offices for the monitor risk and the effectiveness of internal control
- should develop a maturity approach to the adoption of an ERM framework. And continually update approaches to identify new and emerging risks
- Manage must use Greene book to assess internal control
What did OMB Circular A 123 Appendix A do?
- Strengthened management’s risk assessment processes for data quality
- Align appendix A with other policies
What did OMB Circular A 123 Appendix B do?
Addresses improving management Government charge cards
What did OMB Circular A 123 Appendix C do?
Covers requirements for effective measurement and remediation of improper payments
What did OMB Circular A 123 Appendix D do?
Guides guidance for determining compliance with the CFO act and FFMIA
What does OMB circular a 130 — management of federal information resources require?
Established minimum set of controls in federal automated information Security programs and linked these to agency internal control systems (A123)
What does GAO’s standards of internal control for federal government provide?
Provides the overall framework for establishing and maintaining internal control
What should internal controls help managers do?
- achieve program objectives and organizational goals
- operate efficiently and effectively (acquire personnel and resources by reducing waste fraud and abuse)
- prepare reliable performance and financial reports (maintaining performance measures, transaction data, and the organization properly processes, records transactions, so reports can be prepared easily)
- comply with laws and regulations
- Safeguard assets
What are agencies accountable for?
- achieving program objectives
- using resources efficiently
- comply with legal requirements
- Provide accurate, reliable and relevant data on performance and financial operations
- Safeguarding assets
What type of assurance do internal controls provide?
Reasonable, not absolute, assurance
They are intended to provide a satisfactory level of confidence that an organization will achieve its programmatic goals, and minimize fraud, waste, and abuse
What are some factors outside of the control of management that can affect an entities ability to achieve all of its goals?
- human error
- judgment error
- Collusion to circumvent control
What must management consider with regard to the cost and extent of control?
- consider the cost (dollars and intangibles ) an extent of the control for the given program
- Cost cannot exceed its benefit
- Internal controls should be designed and implemented related to their cost and benefit
- can you develop an alternative control with slightly less benefit, but cost a lot less
- prevention controls cost more than detection controls
What are some examples of costs of controls?
- documented an action is inexpensive
- supervisory approval is inexpensive when the dollar amount is high
- supervisor approval is expensive when the dollar low
- Developing reports can be expensive but necessary
What are some non-financial factors that management should consider with regard to internal controls?
A control can be costly and not save that much money. However, some financial factors such as losing private data can lead to privacy concerns, litigation, loss of reputation, etc.
What did the Committee of Sponsoring Organizations (COSO) of the Treadway Commission do?
Developed the internal control framework
When was the Treadway Commission developed and why?
- 1980s
- created as a result of instances of fraudulent, financial reporting and audit failures, particularly in the private sector
What standards use the COSO framework?
- Generally Accepted Auditing Standards, developed by the AICPA
- International standards for the professional practice of internal auditing, developed by the IIA
- Government auditing standards issued by GAO
What did the May 2013 COSO update do?
- It did not change the basic structure of the framework, but it did enhance and clarify it
- 17 principles were added (to align with the five components)
- 87 points of focus were added (GAO calls these attributes)
What did GAO’s 2014 update of the standards of internal control for the federal government (green book ) do?
Mirrors, the COSO framework, but eliminates the reference to the private sector board Directors ([GAO calls them an oversight body)
What does COSO state are the three objectives that agencies must meet with their internal controls?
- Operations. — the efficiency and effectiveness of agency operations.
- Reporting. — internal and external, financial, and non-financial.
- Compliance.
What’s the first internal control component there should be considered?
Control environment
What is control environment and what does it provide?
- It’s the foundation for an internal control system
- Discipline and structure which affect the overall quality of internal control
- It’s the piece upon which other four components of internal controls rest
- People within and out that the organization is trustworthy and reports can be relied on
How many COSO principles are there for control environment and what are they?
- Oversight body and management to demonstrate a commitment to integrity and ethical values.
- Overlay body should oversee the entities internal control system.
- Management to establish organizational structure, assign responsibility, and delegate authority to achieve the entity’s objectives.
- Management to demonstrate commitment to recruit, develop, and routine, competent individuals
- Management performance and hold individual accountable for internal control responsibilities.
What should be considered with regard to integrity and ethical values?
- what is the tone at the top?
- does Top management believe in ethics and demonstrate belief
- do the organizations incentives emphasize short-term results and expense of long-term results?
- How does management communicate its moral values?
What does tone at the top refer to?
- management’s reputation for integrity, for dealing fairly with employees and customers, and for not tolerating unethical behavior
What are some indicators of management’s commitment to integrity and ethical values?
- having a code of ethics (post around premises, ensure all new employees know it, periodic training, taking action in code is violated)
- top management communicating it’s moral guidance in both in organized format and by its actions
- Informing employees how to report behavior, and they must believe management will take action when notified (sexual harassment)
- Doesn’t routinely override controls
- Emphasis on long-term goals and not just short term goals (emphasizing short term can lead people into distorting accounting or performance records, or taking inappropriate actions to accelerate short-term accomplishments)
- Actively discourages, unethical behavior when dealing with employees, customers, vendors, and creditors
What are some indicators of management’s commitment to competence?
- clear understanding of knowledge/skills/abilities needed to perform a job and is considered successful performance
- job descriptions are clear, realistic, current
- employee are periodically evaluated and counseled
- Organized training development programs
- Supervision is properly matched organization needs
- promotions are consistent with evaluation results
What are some good management and operating style philosophies?
- not overly aggressive (focuses on long-term over short term)
- Measures risk and assesses its consequences
- Not taking excessive risks
- Not making things seem better than they are
- not seeking glory or agenda conflict with organizations core values
- respect for accounting and internal controls
- Supporting internal and external audit functions and cooperating with them
- Self-discipline in accomplishing its objectives and comply with budgetary constraints
What are indicators of a good control environment regarding HR policies and procedures?
- Policies and procedures that emphasize commitment to goals
- Maintaining a competent staff
- insuring ethical behaviors of staff
- run background checks on new employees
- appraise employee performance and counsel those not meeting performance requirements
- Promote based on high-performance and encourage ethical behavior
- conduct ethical training
- take action when ethics or policies violated
How many risk assessment principles are there and what are they?
- objectives should be clearly defined to identify risks and define risk tolerances
- Identify, analyze, respond to risks related to objectives
- consider fraud when identifying, analyzing, and responding to risks
- Identify, analyze, and respond to significant changes that may impact internal control systems.
What are risk assessments and what do they provide?
- what could prevent us from achieving our objectives?
- Provide management with information on weaknesses in internal control
After identifying risks, what risk assessments consider?
- The likeliness the risk will occur
- The impact if it does occur
Which is more important: the likelihood of risk or the impact?
The impact. However, both likelihood and impact should be considered.
What are some steps that can be performed in a risk assessment process?
- List all the risk that an organization believes can impact accompany it from achieving it’s objective.
- Assess the likelihood of the risk occurring. (based on the quality of the internal controls in place.)
- Assess the impact if it were to occur
- assign a high, medium or low rating (or point value.) for both the likelihood and impact.
- Assign an overall risk two event
6.
When is an overall low rating issued, and when is an overall high rating issued?
- A low rating = low likelihood of occurring and low impact
- A high rating = both likelihood and impact are high
What is a vulnerable item? What are some examples?
Items susceptible of being stolen or misused
Examples:
- cash
- Personal data
- electronics
- Bond bears
- other property that others are willing to risk a lot to obtain it (prescription drugs)
When are companies most vulnerable to risk?
When it doesn’t install controls for inherent risk
What type of risks are more difficult to mitigate?
External risks
Internal risks are easier to mitigate
What are the biggest risks for banks?
The value of collateral received for large loans
What are the biggest risk for not for profit organizations that provide grants to the federal government?
Providing services to the wrong recipient and the federal agency, considering all costs unallowable
What type of risk is greater: programmatic or financial?
Programmatic because it can cause financial and reputational damage
What type of risk is always present?
Fraud
- Management should determine which activities are susceptible to fraud risk, and take steps to mitigate that risk
- Management cannot do his job, unless there are steps to perfect and detect fraud
What does OMB Circular A-123 state needs decided after risk is assessed?
- if the risk is accepted, and nothing will be done (low risk, or the cost is more than a benefit)
- stop doing activity because the risk is too high
- Except risk and put an internal control system in place to reduce it
What does OMB A-123 require with regard to risk?
- Agencies must establish an ERM governance structure
- The risk assessment process must be led by a high-ranking official (COO or equivalent)
- May establish a chief risk officer, but not required
- Should include a process for determining risk appetite and risk tolerance
- Integrate ERM with management evaluation of internal control
What are control activities?
Actual procedures that organizations establish to help ensure they call the schools and avoid what they want to avoid
How many principles are there for control activities and what are they?
- Management design control activities to achieve objectives and respond to risks
- Management should define the entity, information system and related control activities to achieve objectives and respond to risk.
- Management should implement control activities through policies.
What is a control activity?
- Any process put into operation to ensure that the organization succeeds
- can be a provision in a law, regulation, procedure, report, requirement to segregate duties, operating strategy, cash register, inspection process, documentation, training program
Example: lock on front door; reconciling bank statement; reviewing kids report card
What are some examples of control activities?
- Assessing annual program performance targets
- conducting top level reviews of performance
- Managing human capital
- Controls over information processing
- Physical control over vulnerable assets
- Accurately recording transactions
- Separating duties
- Establishing and reviewing performance measures and indicators
If there is a conflict between effectiveness and efficiency, which prevails?
Effectiveness virtually, always prevails over efficiency
It doesn’t make a difference how cheaply you can do something if it doesn’t achieve your goals
Controls must be efficient, effective, and cost-effective
What are the four ways that control activities can be classified?
- Efficient and effective program operations
- Validity and reliability data.
- Compliance with laws and regulations.
- Safeguarding of resources.
What does information and communication encompass?
- Written definition of an organization policy and procedures.
- It’s record of actual events.
Policy statements and procedure handbook, as well as accounting and personnel records