SUNY Oswego Administration and Finance

Internal Control

Congratulations to Robert Vaccarelli, Linda Rae Markert, and Barbara Streets. Winners of $100 gas cards for participating in the 2013 Internal Control survey.

The Internal Control Act, more specifically referred to as the New York State Governmental Accountability, Audit and Internal Control Act (originated in Chapter 814 of the Laws of 1987, then made permanent in Chapter 510 of the Laws of 1999), is the basis for the SUNY-OSWEGO Internal Control Program. The Internal Control Act requires that all state agencies, including SUNY institute a formal internal control program. There are six requirements of the Internal Control Act of 1987 as shown below:

  1. Maintain written internal control guidelines.
  2. Maintain an internal control system for continuous review of operations.
  3. Make a concise statement of policy and standards available to all employees.
  4. Designate an Internal Control Officer.
  5. Educate and train all employees on internal controls.
  6. Evaluate the need for an internal audit function.


Basic Definitions

Internal Controls
Internal Controls are an integral part of each system used to regulate and guide
operations. Internal controls are designed to promote performance leading to the effective accomplishment of an organization's goals and objectives.

Internal Control Systems
Internal controls with a common purpose are grouped together and referred to as internal control systems. Basically, internal control systems are the laws, policies and procedures that affect the daily operations and management of SUNY-OSWEGO.

Examples of internal control systems include, but are not limited to:

  • External (federal, state, university) laws, regulations, policies, and procedures
  • Policies of the University Board of Trustees
  • College handbook, catalog, and other statements of policy and procedure
  • Academic curricular and course outlines
  • Student registration system
  • Financial and personnel procedures
  • College long-range plan
  • Bargaining contracts
  • Financial and operational audits
  • Employee performance programs and evaluations
  • Accreditations (Middle States, etc.)
  • Time and attendance reporting
  • Property (equipment) control
  • Electronic data and network security
  • Public safety, environmental safety, code compliance practices
  • Faculty Senate governance process
  • Service contracts, revocable permits
  • Building door lock systems and key control
  • Student and employee identification cards, etc.

Reasonable Assurance
All internal control systems must provide reasonable assurance that the objectives of the campus will be met in a cost effective manner. Reasonable assurance provides sufficient confidence that internal controls are functioning to ensure the organization will meet its goals and objectives.

The Cost of Internal Controls
Internal control systems should remain cost effective and not exceed the benefit derived.


Internal Control Program

Objectives
SUNY-OSWEGO's Internal Control Program is based upon existing internal controls which are a part of our everyday operations. SUNY-OSWEGO's Internal Control Program provides us with a formal mechanism to help identify existing controls and evaluate their effectiveness.

There are five specific objectives to SUNY-OSWEGO's Internal Control Program. CARES stands for these objectives as described below:

  • Compliance with applicable laws and policies
  • Accomplishment of the campus' mission
  • Relevant and reliable data
  • Economical and efficient use of resources
  • Safeguard assets


Internal Control Foundations

The foundations of SUNY-OSWEGO's internal control systems are the various policies and procedures applicable to its daily operations. Below are samples of basic foundations that affect all employees of SUNY-OSWEGO:

  • SUNY Procedures Manual
  • Public Officers Law
  • Campus Purchasing Procedures
  • Time and Attendance Policy
  • Policy Handbook
  • Hiring Practices
  • Transaction Processes


Segmentation

The first step in the Internal Control Process is to segment the organization. Segmentation is the process of identifying the program and administrative functions necessary for the campus to carry out its mission. Functions identified through this process are called "assessable units" and provide the framework for the Internal Control Program.


Risk Assessment

After the campus is segmented into assessable units, each unit's risk is assessed. This process may be done through a self assessment survey or a one-on-one discussion with the unit manager and the Internal Control Officer. By means of this evaluation, the campus evaluates its susceptibility to conscious or unintended abuses and reduced operational efficiencies. Some of the factors examined in the risk assessment are: inherent risk of the unit, management's attitude toward internal controls, physical location, frequency of review, and the rate of personnel turnover.

Upon completing a risk assessment, a rating of low, average or high risk is assigned to the assessable unit. These ratings are considered when scheduling internal control reviews.

Internal Control Review
The internal control review analyzes procedures and policies to insure they are functioning as intended and that they assist the unit in meeting its goals and objectives. Examples of procedures and policies that may be reviewed include planning activities, program evaluations, the budget cycle, personnel transactions, information systems, cash activities, contract management and capital programs.

Upon completion of the internal control review, recommendations may be made. The recommendations may require adding, deleting or changing internal controls or procedures for the unit. If recommendations are accepted, a timetable for implementation is agreed upon.

Follow-Up
The final component in the internal control process is follow-up. This step is performed to verify that the recommended actions have been properly implemented and that the unit continues to function as intended.


Preventative and Detective Controls

Preventative Controls
You will recall that internal controls are actions taken to make sure the right things happen and the wrong things don't. There are two types of internal controls: preventative controls and detective controls.

Preventative controls are designed to keep errors or irregularities from occurring in the first place. They are built into internal control systems and require a major effort in the initial design and implementation stages. However, preventative controls do not require significant ongoing investments.

Detective Controls
Detective controls are designed to detect errors and irregularities, which have already occurred and to assure their prompt correction. These controls represent a continuous operating expense and are often costly, but necessary. Detective controls supply the means with which to correct data errors, modify controls or recover missing assets.

Internal Control Standards
Internal controls must meet basic standards to ensure that adequate internal control systems are established and maintained. There are two types of internal control standards: general and specific. General internal control standards describe what we want to achieve while specific internal control standards tell us how to achieve those objectives. Below are examples of general and specific internal control standards. Each example is followed by a brief explanation.


General Standards

Reasonable Assurance
Internal control systems should provide reasonable assurance that the objectives of the organization will be accomplished.

Supportive Attitude
Managers and employees should maintain and demonstrate a positive and supportive attitude toward internal controls at all times.

Competent Personnel
Managers and employees should have personal and professional integrity and maintain a level of competence that allows them to accomplish their assigned duties, as well as understand the importance of developing and implementing good internal controls.

Control Objectives
Internal control systems should help to assure compliance with laws and that the campus meets its goals and objectives.

Control Techniques
These are the means to accomplishing the objectives of the internal control systems (i.e. Specific Internal Control Standards).


Specific Standards

Documentation
Adequate records of all internal control systems, transactions and events should be maintained.

Records
All transactions and events should be recorded promptly and accurately.

Authorization
All transactions and events should be authorized and executed by persons within the scope of their authority.

Structure
Key duties and responsibilities in authorizing, processing, recording and reviewing transactions should be separated.

Supervision
Adequate supervision must be provided to ensure that internal control objectives are achieved.

Security
Access to and accountability for assets and records should be limited to authorized individuals.


Who's Responsible and For What?

Our competence and professional integrity are essential components of a sound internal control program. By knowing what our responsibilities are, we can help to provide reasonable assurance that our internal control systems are adequate and operating in an efficient manner. This section will identify the relationship between the theories and definitions presented thus far and your responsibilities as an employee.

Employee responsibilities:

  • Fulfilling the duties and responsibilities established in one's job description. Meeting applicable performance standards.
  • Attending education and training programs as appropriate to increase awareness and understanding.
  • Taking all reasonable steps to safeguard assets against waste, loss, unauthorized use and misappropriation.
  • Reporting breakdowns in internal control systems to your supervisor.
  • Refraining from the use of your official position to secure unwarranted privileges.

Managers have these additional responsibilities:

  • Maintaining an office environment that encourages the design of internal controls.
  • Documenting policies and procedures that are to be followed in performing office functions.
  • Identifying the control objectives for the functions and implementing cost effective controls designed to meet those objectives.
  • Regularly testing the controls to determine if they are performing as intended.

The Internal Control Officer spearheads the campus' Internal Control Program and is responsible for the following:

  • Monitor and evaluate the organization's overall internal control system.
  • Coordinating the development and implementation of the campus' Internal Control Program.
  • Monitoring identified weaknesses and required corrective actions.
  • Ensuring that employees are informed of applicable policies and receive appropriate training in internal control.
  • Complete Central Administration required reporting requirements.


Positive Attitude

Commitment of Top Management
Employee attitude affects the quality of job performance and, as a result, the quality of internal controls. A positive attitude is initiated and fostered when internal controls are a consistent priority. Members of top management must demonstrate commitment to the campus' Internal Control Program.

Statements of policies and standards were developed at each campus and made available to all employees. These statements identify the basic policies common to all employees and encourage adherence to these for the benefit of the campus. These statements demonstrate the commitment of top management to the campus' Internal Control Program.


Training

Another factor essential to the success of SUNY-OSWEGO's Internal Control Program is adequate training in the area of internal controls. Training should familiarize employees with the objectives of the internal control program, how it operates and the benefits it provides.

Adequate training will help all employees understand the importance of their role in the campus' system of internal controls.

In addition, management should be open to employee suggestions concerning the campus' internal control systems. Users are the best source of improvements to a system.


Summary

Internal controls are already part of our daily operations. The controls developed and exercised by managers and their staff are the substance of the internal control program. SUNY-OSWEGO's Internal Control Program helps to ensure that the controls are properly documented and that they are functioning as intended.

The goal is not to make each person an expert in internal controls, but to increase our awareness and understanding of internal controls. In fact, the single most important success factor of the Internal Control Program is a high level of individual awareness and understanding. Internal controls are everyone's responsibility; therefore, it is critical that each person is able to identify the internal controls that exist in their unit. We are all responsible to know what internal controls exist and how to evaluate their effectiveness.

A successful Internal Control Program will help to streamline our processes and improve the level and quality of our services. The result of SUNY-OSWEGO's Internal Control Program will be a better, more enjoyable work place and a quality institution of higher education.

For more information on internal controls or the status of SUNY-OSWEGO's internal control program, please contact SUNY-OSWEGO's internal control officer.

Adapted from the following documents: Understanding Internal Controls Within STATE UNIVERSITY OF NEW YORK Internal Controls Handbook, SUNY Optometry's and SUNY Cortland's Internal Control Programs.


Additional References:

Fraud Policy Item of the current SUNY Administrative Procedures Manual.
https://www.suny.edu/sunypp/documents.cfm?doc_id=79

Fraud Policy Form

https://www.suny.edu/sunypp/documents.cfm?doc_id=80


Standards for Internal Control in New York State Government
http://www.osc.state.ny.us/agencies/ictf/index.htm

Listing of Contracts and Expenditures Bulletins (G-Bulletins)
http://www.osc.state.ny.us/agencies/gbull/index.htm

Listing of Accounting Bulletins (A-Bulletins)
http://www.osc.state.ny.us/agencies/abulls/index.htm

New York State Accounting System User Procedures Manual Controls and Special Procedures - Table of Contents
http://www.osc.state.ny.us/agencies/accmanual/index.htm

OSC Financial and Audit Solutions Newsletters
http://www.osc.state.ny.us/audits/newslett.htm

Internal Control Task Force from the State Comptroller
http://www.osc.state.ny.us/agencies/ictf/tr.htm

State University Internal Control Policy

http://www.suny.edu/sunypp/documents.cfm?doc_id=290

Stae University Internal Control Program Guidelines

http://www.suny.edu/sunypp/documents.cfm?doc_id=289

Links to Professional Organizations:
New York State Internal Control Association
http://www.nysica.com/

The Institute of Internal Auditors
http://www.theiia.org/

American Institute of Certified Public Accountants
http://www.aicpa.org/index.htm

Association of College and University Auditors
http://www.acua.org/

National Association of College and University Business Officers
http://www.nacubo.org/

General Accounting Office
http://www.gao.gov/