a departmental perspective drive value through compliance with the green book – stop checking the...
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A DEPARTMENTAL PERSPECTIVE
Drive Value through Compliance with the Green Book – Stop Checking the Box
Drive Value through Compliance
with the Green Book – Stop Checking
the Box
United States Department of AgricultureOrganization Chart
Drive Value through Compliance
with the Green Book – Stop Checking
the Box
What We Found
• Internal control activities are very compartmentalized and siloed
• Component agencies and staff offices are at varying levels of maturity with their risk management and internal control programs
• Internal control is still viewed by some as a financial activity/responsibility
• Component agencies and staff offices want some structure and more training to implement their risk management and internal control programs
Drive Value through Compliance
with the Green Book – Stop Checking
the Box
What We’ve Accomplished• Inter-agency workshops identified
potential areas for integration• Identified specific training needs• Broad-based communication efforts
(focusing on outside of the financial community)
• In Progress - Revising our Departmental Regulation and manual with stakeholder involvement
Drive Value through Compliance
with the Green Book – Stop Checking
the Box
Future State
• New Risk Management Framework will:– Provide senior management with actionable
information that supports executive-level risk management decision-making
– Establish a Tone-at-the-Top that reflects maintaining an effective Internal Control System is a shared responsibility across many organizational levels (e.g., executives, managers, agency staff)
– Facilitate and support an integrated approach to maintaining internal controls over operations, reporting & compliance
FEMA Risk Management and Compliance (RM&C) Division
A-123 Activities: Conduct tests of
design (TOD) and tests operational effectiveness (TOE) of internal control, remediation and verification and validation (V&V),and continuous monitoring.
Conference Spending Activities: Coordinates with requesting
personnel to process travel and conference requests with the goal of reducing costs, gather supporting documentation for expenses, and periodically report metrics to DHS.
USA Spending Activities: Report Assistance Prime
Awardee data to USASpending.gov twice per month.
A-133 Activities: Coordinate between auditor and
auditee, provide audit advise, communicate issues and results with the necessary Federal agencies and regulation authorities, and obtain or conduct audit quality control reviews.
IPERIA Activities: Assess and report on
improper payment findings in accordance with OMB Circular A-123 Appendix C, the Improper Payments Elimination and Recovery Act of 2010 (IPERA), Improper Payments Elimination and Recovery Improvement Act of 2012 (IPERA), and DHS guidance.
Financial Statement Audit Support Activities: Performs risk assessments of
audit activities to target processes for pre-audit review. RM&C also fosters ongoing dialogue with auditors to coordinate and discuss draft NFRs prior to issuance.
A-123 IPERIA
Financial Statement
Audit Support
USA Spending
Conference Spending
A-133
Evolving Requirements
and Duties
Resources Available
Enhanced ELC
Requirements
Fraud Risk
Program
Continuous
Monitoring
Technology
Staff
Resources
Evolving Requirements and Duties from
The New Green Book
• Landscape is changing with a focus on continuous monitoring rather than annual assessments.
– Department is revising guidance and the DHS playbook for internal control programs.
• DHS is seeking a clean audit opinion on internal controls for FY 2016.
• Additional requirements and duties are being added to existing processes.
– Continuous Monitoring.– Fraud Risk.– Enhanced ELC Requirements.
• Facing Pressure with resource constraints.– Need to streamline process.– Discover efficient ways of doing business to be
more effective.
Audit Remediation
Document Inputs
Work inputs being performed by different teams and processes
Automated
Consolidation
Dashboard Analytic Outputs
Assessments
NFR and Audit Process
Risk Areas
Real-time visual display of data for decision making and risk
management
RM&C Process Improvement Efforts
SharePoint Tool
Benefits:
• Efficiencies• Collaboration• Standardization• Business intelligence
• Version control• Automated DHS
submissions• Analytics
Data Analytics
• Bringing processes together in one centralized space.
• Providing real-time information to senior leaders in order to make actionable data driven decisions instead of ad-hoc reports and briefings that take weeks to produce.
• Facilitates reporting objective in the COSO framework.
How These Processes and Tools Relate to
The New Green Book Principles
Control Environment
Risk Assessment
Control Activities
Information and Communication
Monitoring
• Improves oversight and accountability with performance metrics.• Establishes a structure to allow program offices to conduct internal
control assessments and share the responsibility of maintaining an effective internal control program throughout the agency.
• Document both qualitative and quantitative risk analysis for current year and multi year planning purposes.
• Provides more time for analysis and responding to change.
• Improves control activities with collaborative remediation plans.
• Improves data integrity with the standardization of business processes.
• Communicates internal control status, results, and documentation both internally and externally.
• Performs ongoing monitoring of the control environment using real-time dashboards and briefing decks.
• Provides a platform to remediate deficiencies and monitor progress.
Next Steps
• Promoting the tools and templates developed for risk management processes to other agency stakeholders as a way of increasing organizational efficiencies and strengthening internal controls.
• Collaborating with other DHS Components on sharing the tools an templates developed as well as best business practices to strengthen DHS for the FY 2016 audit.
• Training FEMA program offices on maintaining an effective internal control environment and performing their own assessments.– Increasing accountability by sharing performance metrics across
the agency.