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Internal Control Tip of Week – Risk Assessments to Identify Priorities for More In-Depth Reviews

By Thomas Canby posted 11-16-2017 09:00

  

It only takes one employee to compromise the overall performance of increasingly complex technology-supported processes and to create the potential for nearly innumerable internal control risks.  Accordingly, it’s critical for executive management to have a healthy respect for how increased levels of complexity are correlated with risk and far-ranging internal control issues. This is especially the case following various employee assignments and reassignments after the start of the new school year.

Accordingly, this is a good time for an employee survey to take the pulse of the organization and assess potential control risks. The survey should target all employees in each organizational unit and use of an independent third-party may be a consideration to help encourage open and actionable feedback. The results will reveal useful insights that will be helpful in prioritizing areas that indicate opportunities in select organizational units for more in-depth reviews of internal controls. The survey questions may include:

  • Are job descriptions current?
  • Are employees’ position assignments and stipend records updated and accurate?
  • Do employees have access to manuals containing standards for procedures, policies and process workflows?
  • Do appropriate employees in the unit have access to documentation of and do they adequately understand key controls?
  • Do appropriate employees in the unit have access to documentation of and adequately understand compliance-related rules, regulations and guidelines?
  • Are the unit’s organizational structure and lines of authority understood by all employees?
  • Are appropriate front-line employees, local supervisors and managers required to sign a certification form that they have received or have access to the school district’s documentation of standards for the organizational unit for procedures, policies and process workflows?
  • Did annual personnel evaluations for the prior evaluation period or year include an assessment of local managers’ and supervisors’ adherence to the school district’s documentation of standards for procedures, policies and process workflows?
  • Are unannounced visits in campuses and departments made periodically to review key record-keeping processes and supporting documentation, especially records that support the payroll for hourly employees?
  • Are all records in each organization unit maintained in accordance with procedures and process manuals?
  • Are employees following processes designed to ensure adequate segregation of duties, and no process shortcuts are being followed that effectively circumvent supervisor standards for reviews and approvals by supervisors?
  • Do all employees in each organizational unit understand annual operational plans and are performance level targets documented and reviewed periodically?
  • Has each organizational unit developed benchmarks to other units in the organization and to external organizations?
  • Do the unit’s employees have the tools and resources to adequately perform their duties and excel?
  • Are there operational process delays indicating employees in any organizational unit need additional training, knowledge, and skills to perform assigned roles and responsibilities?
  • Is the unit’s employee turnover rate reasonable?
  • Is employee morale acceptable?
  • Are communications, collaboration and team effort encouraged?
  • Does the unit’s management demonstrate the importance of following the district’s code of ethics- and conflict of interest-related policies and procedures?
  • Does the unit’s management encourage suggestions and feedback to improve performance, service and quality?
  • Does the unit have a sufficient business continuation plan that addresses absences of key employees, catastrophic events, and backup procedures for key school finance, operational and technology systems that help ensure minimal disruption?
  • Are the unit’s employees aware of how to communicate suspected fraud, theft, misuse of assets, conflict of interest and ethical issues?
  • Do employees perceive that issues involving key processes and controls would be detected in a timely manner?

Management should step back and ask what is the worst-case scenario that could occur in relation to select ”not sure” or “no” answers. It is to be expected that there may be one or more ”not sure” or “no” answers to survey questions. However, management should also evaluate answers in the context of potential low, medium or high internal control impacts. It’s important to also follow trends to help ensure timely identification of emerging issues while they are more readily resolvable with minimal disruption to the delivery of services, programs and activities. School districts need to be proactive, as it only takes one employee associated with any number of scenarios for a school district to be the next newspaper article.

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