White Internal Control Systems
White Internal Control Systems
1 
Internal Control Systems 
County Auditors Spring Conference 
May 2014 
How many of you can say that you 
are reasonably certain that the 
office: operates in a way that goals 
are reached; reports materially 
correct information; and materially 
complies with laws and 
regulations? 
5/7/2014 
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Did the voters that elected you do 
so because they thought you 
would make sure things were done 
right? 
 
How are you making sure?  
Internal controls  
combat fraud and mistakes 
 Prevent 
Opportunity 
 
 Detect Fraud, 
Errors and 
Omissions 
 
Fraud Triangle 
Pressure 
Opportunity  Rationalization 
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Why do we talk about internal controls 
then find it difficult to take action? 
 
 Control systems are not uniform. 
 They are not tangible. 
 
They are not rocket science but in order to be 
effective they have to be more than just 
thoughts in the mind of management. 
 
Summary of the Discussion 
 Understanding Internal Control  
 3 Categories of Objectives 
 5 Components on Internal Control Systems 
 New COSO 2013 
 Expanded guidance on the role of those in charge of 
governance in Internal Control Systems 
 Adjusted for increased dependence on IT 
 17 principles under the 5 components 
 Implementation 
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COSO Definition of Effective Internal 
Control 
An effective system of internal control requires 
that: 
 Each of the 5 components and 17 principles 
are present and functioning and, 
 The 5 components operate together in an 
integrated manner. 
 
A major deficiency exists if the county cannot 
conclude that these are met. 
Internal Control Framework 
(COSO Cube 2013) 
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Managements Objectives 
 Operations 
 Reporting 
 Compliance 
Internal Control Components 
 Control Environment 
 Risk Assessment 
 Control Activities 
 Information & 
Communication 
 Monitoring Activities 
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Control Environment 
 Set of standards, 
processes, and 
structures  
 Tone at the top 
 Integrity and ethical 
values of the county 
 Includes performance 
measures, incentives, 
and rewards 
 
 
Acts as the foundation for 
a sound system of internal 
control 
Risk Assessment 
Risk assessment requires 
management to consider 
the impact of possible 
changes in the external 
environment and within 
the county that may 
render internal control 
ineffective. 
 Many organizations,  
take a risk-based 
approach to internal 
control 
 Includes: 
 Risk Identification 
 Risk Analysis 
 Risk Response 
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Control Activities 
 Preventive or detective in nature 
 Manual and automated activities 
 Includes segregation of duties 
Control activities are the actions established through 
policies and procedures to mitigate risks to the 
achievement of objectives. 
Information and Communication 
 Emphasizes importance of quality information 
 Volume and sources 
 Complexity of processes 
 Technology advances 
 Greater interaction with 3
rd
 party vendors 
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Monitoring Activities 
Ongoing Evaluations 
 
 Built into the business 
process at various levels 
 
 Timely information 
Separate Evaluations 
 
 Conducted periodically 
 
 Frequency will depend on 
assessment of risks and 
effectiveness of ongoing 
evaluations 
New Principles 
 
 
COSO 2013 Update 
clarifies requirements for 
effective internal control 
with the 17 new principles 
 
 
 Principles relate to a 
component of the 
internal control system 
 Not required  
 Common sense 
 
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Control Environment 
1. The county demonstrates a commitment to integrity 
and ethical values. 
2. Governing boards demonstrate independence from 
management and exercises oversight of internal 
control system. 
3. Management establishes, with board oversight, 
structures, reporting lines, and appropriate 
authorities & responsibilities. 
4. The county demonstrates a commitment to attract, 
develop and retain competent individuals. 
5. The county holds individuals accountable for their 
internal control responsibilities.  
Risk Assessment 
6. The county specifies objectives with sufficient clarity 
to enable the identification and assessment of risks 
relating to objectives. 
7. The county identifies risks to the achievement of its 
objective across the entity and analyzes risks as a 
basis for determining how the risks should be 
managed. 
8. The county considers the potential for fraud in 
assessing risks to the achievement of objectives. 
9. The county identifies and assesses changes that could 
significantly impact the system of internal control. 
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Control Activities 
10.  The county selects and develops control 
activities that contribute to the mitigation of 
risks to the achievement of objectives to 
acceptable levels. 
11. The county selects and develops general control 
activities over technology to support the 
achievement of objectives. 
12. The county deploys control activities through 
policies that establish what is expected and 
procedures that put policies into place. 
Information and Communication 
13.  The county obtains or generates and uses 
relevant, quality information to support the 
functioning of internal control. 
14.  The county internally communicates 
information, including objectives and 
responsibilities for internal control, necessary to 
support the functioning of the internal control. 
15. The county communicates with external parties 
regarding matters affecting the functioning of 
internal control.  
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Monitoring Activities 
16.  The county selects, develops, and performs 
ongoing and/or separate evaluations to 
ascertain whether the components of internal 
control are present and functioning. 
17. The county evaluates and communicates 
internal control deficiencies in a timely manner 
to those parties responsible for taking corrective 
action, including senior management and the 
governing boards, as appropriate.  
Implementation 
  
 
Action! 
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Take it Step by Step! 
1. Control Environment 
2. Risk Assessment 
3. Control Activities 
4. Information and Communication 
5. Monitoring 
Documentation 
 Start with documenting the 5 components in 
significant areas first. 
 Cash handling 
 Managements Goals 
 Customer Service 
 Compliance with Laws and Regulations 
 
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Find where there is risk that is not 
mitigated by internal control 
 This is Risk 
identification 
 Perform your risk 
analysis 
 Respond to the risk 
 Implementing controls 
 Insurance 
 Acceptance of the Risk 
LaGrange Clerk of the Circuit Court 
 Charged $23,253.31 
 Cash receipts not deposited 
 Transfers to cover the amount of missing cash 
receipts 
 Cash shortages 
 Additional Audit Costs 
 President of the Clerks Association and named 
Clerk of the Year just prior to this report being 
made public 
5/7/2014 
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Switzerland County School 
Corporation 
 Charged Treasurer over $1.1 million (over 4 years) 
 Manually wrote checks to pay personal credit 
cards 
 Used a different check series 
 Altered bank statements 
 Adjusted disbursement records 
 U.S. Attorney charged criminally and civil charges 
brought by the school 
Ashland Township 
 Charged Trustee $7,860.23 
 Consecutive audits reported unsupported disbursements for 
utilities, travel expenses, office supplies and repairs. 
 Other Examination Results and Comments 
 Unapproved salary payments 
 Failure to remit payroll withholdings 
 Failure to provide board minutes for audit 
 Disbursements made in excess of appropriations 
 Late filing of the annual financial report 
 Failure to File 100R 
 Certified to Prosecuting Attorney and AG  
 Removed from office 
 
5/7/2014 
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Town of Brownstown 
 Charged Clerk Treasurer $ 393,916.98 
 Over paid her salary by $369,054.70 over 4 years 
 Made unauthorized payroll payments to her son 
for 3 years in the amount of $22,606.50 
 Charged $2,255.78 for penalties and interest 
incurred with IRS and IDOR 
 Left town during the audit October 2009 
 April 2010 sheriff sold her residence under 
foreclosure order 
Town of North Judson 
 Charged Clerk-Treasurer $ 84,892.67 
 Cemetery lot receipts not deposited (required cash) 
 Utility receipts not deposited 
 Utility customer deposits not receipted 
 Ordinance Violations Collections not deposited 
 Police Dept receipts not deposited 
 Equipment purchased was not at the Town 
 Personal expenses paid by Town check 
 Paid herself without supporting documentation 
 Certified to the AG and Prosecuting Attorney 
 
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Are you going to trust or make 
sure things are done right in your 
office?