Transcript Power Point Template - NC Community Colleges

Accountability and Internal
Controls – Best Practices
Arnessa Richbourg Guilford Tech CC
Nate Humphrey
Wake Tech CC
Margaret Roberton NCCCS
NC Community College Performance Management
ACCOUNTABILITY & CREDIBILITY
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Re-focusing the
Conversation
– Planning
– Assessments
• Fiscal Accountability
– Compliance
– Documentation
– Mitigating Exposure
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Operations &
Internal Controls
• Program Accountability
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Vision of Accountability
Workshop Opportunities at NCCCAEA Conference
• Vision of Accountability – Draft Document
• Education Program Audit Procedures_Memo_CC14-030
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Vision for New System of
Accountability
Mission:
The mission of the Compliance Services Section is to promote the integrity of the System’s
budget allocation process by:
•
Providing an objective assessment of college compliance with State laws and State Board rules
governing the reporting of data used as the basis of college budget allocations as well as
charging and waiving tuition and fees.
•
Coaching colleges on areas of potential risk through sharing information on trends in
compliance review findings, good documentation practices, and use of mitigating controls.
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Findings Included in Education Program
Audit Reports
for Audits Conducted FY 2014-2015
Request: The State Board is asked to approve an amendment to the FY 2014-15 Program Audit
Procedures that clarifies that audit findings will only include direct violations of the General
Statutes or the State Board of Community Colleges Code (SBCCC). Issues identified by auditors
that pose potential risk, but for which the SBCCC is ambiguous or rules have not yet been
adopted, will be documented in a management letter to the college president. Such issues will
also be forwarded to the Executive Vice President, who will in turn request the appropriate
System Office division to recommend clarifying SBCCC language.
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Current Statute, Code &
Guidance
G.S. 115-5(m)
“The State Board of Community Colleges shall maintain an education program auditing function
that conducts an annual audit of each community college operating under the provisions of this
Chapter. The purpose of the annual audit shall be to ensure college programs and related fiscal
operations comply with State law, State regulations, State Board policies, and System Office
guidance. The State Board of Community Colleges shall require auditors of community college
programs to use a statistically valid sample size in performing program audits of community
colleges. All education program audit findings shall be forwarded to the college president, local
college board of trustees, the State Board of community Colleges, and the State Auditor.”
1D SBCCC 300.96(c)
“Each college’s local board of trustees must adopt a policy which requires the development and
implementation of an internal audit plan. Each college is required to publish, maintain and utilize
an internal audit plan. The college presidents shall periodically report to the board of trustees on
the findings of the internal audit. The internal audit plan must be submitted to the department for
compliance review.”
CC00-147 “Revisions to the Accountability and Credibility Plan for Continuing Education”
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Proposed Language:
G.S. 115D-5(m)
“The State Board of Community Colleges shall maintain a
compliance function that conducts periodic reviews of each
community college operating under the provisions of this Chapter.
The purpose of the compliance review shall be to ensure that data
used to allocate State funds among colleges is reported accurately
to the System Office and that colleges are charging and waiving
tuition and fees consistent with law. The State Board of Community
Colleges shall require the use of statistically valid sample size in
performing compliance reviews of community colleges. All
compliance review findings that are material shall be forwarded to
the college president, local college board of trustees, the State
Board of Community Colleges, and the State Auditor. The State
Board shall adopt rules governing the frequency and scope of
compliance reviews.”
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Proposed SBCCC
Language
1D SBCCC 300.4
PROGRAM MANAGEMENT
a)
Program Planning. Each college shall review the quality and viability
of all its programs and services at least once every three years to
determine program strengths and weaknesses and to identify areas
for program improvement.
b)
Program Accountability. Below are the general provisions:
1)
2)
3)
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Each college's local board of trustees shall adopt a policy which requires the
development and implementation of a Continuing Education internal program
accountability plan. At a minimum, the Program Accountability Plan will 1) define
a system of checks and balances to prevent and detect errors or irregularities
when reporting hours for FTE purposes and 2) establish a framework for defining
program quality and improvement procedures.
The program accountability plan shall be reviewed by the local board of trustees
at least once every three years.
A copy of this policy including amendments shall be submitted to the System
office upon
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Guidance Documents
•
•
•
•
•
•
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COSO Internal Framework
Performance Management Pillars
Program Analysis Worksheet
Aligning Outcomes
Control Self-Assessments
Process Flow Charts
Outlier Identifiers
Committee to identify additional
tools and guidance
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Organizational Performance
Ability to achieve goals through intentional actions
Leadership function
to set context and
expectations
Management
function to ‘deliver’
outcomes
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• Strategic Performance Management
– Monitoring activities and results over
extended periods of time to identify
adjustments more substantive in nature
(relevancy, focus, alignment)
• Tactical Performance Management
– Monitoring activities and results in ‘real
time’ to achieve accountable results
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Performance Management
Performance Leadership
Management System
Information & Knowledge
Production
Operational
Leader
Operational
Manager
Accountability
Systems
Results
Focused
Budgeting
Measuring &
Monitoring
Systems
External
Evaluation
Inspire
Commitment to
goals &
objectives
Organize work
with focus on
quality and
targeted
results
Assessment on
achievement of
targeted results
Ability to build
and sustain
capacity to
achieve
targeted results
Support real
time
adjustments to
adapt to
emergent
conditions
Support
strategic
decision
making
Hunter and Bohni Nielsen 2013
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Performance Management
Performance Leadership
Management System
Information & Knowledge
Production
Operational
Leader
Operational
Manager
Accountability
Systems
Results
Focused
Budgeting
Measuring &
Monitoring
Systems
External
Evaluation
Inspire
Commitment to
goals &
objectives
Organize work
with focus on
quality and
targeted
results
Assessment on
achievement of
targeted results
Ability to build
and sustain
capacity to
achieve
targeted results
Support real
time
adjustments to
adapt to
emergent
conditions
Support
strategic
decision
making
Hunter and Bohni Nielsen 2013
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Mechanisms of
Performance
Accountability
Effective and efficient systems of internal
control that adapt to changing business
and operating environments, mitigate
risks to acceptable levels, and support
sound decision making and governance of
the organization.
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Internal Control Objectives
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Operations
•effectiveness and efficiency of the entity’s operations,
including operational and financial performance goals,
and safeguarding assets against loss
Reporting
•internal and external reporting and may encompass
reliability, timeliness, transparency, or other terms as
set forth by regulators, recognized standard setters, or
the entity’s policies
Compliance
•adherence to laws and regulations to which the entity
is subject
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COSO: Internal Control –
Integrated Framework
Control
Environm ent
Risk Assessm ent
Control Activities
Inform a tion &
Com m unica tion
M onitoring
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1.Demonstrates commitment to integrity & ethical values
2.Exercises oversight responsibility
3.Establishes structure, authority and responsibility
4.Demonstrates commitment to competence
5.Enforces accountability
6.Specifies suitable objectives
7.Identifies and analyzes risk
8.Assesses fraud risk
9.Identifies and analyzes significant change
10.Selects and develops control activities
11.Selects and develops general controls over technology
12.Deploys through policies and procedures
13.Uses relevant information
14.Communicates internally
15.Communicates Externally
16.Conducts ongoing and or separate evaluations
17.Evaluates and communicates deficiencies
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Framework Aligned to
Performance Management
Control
Environm ent
Risk Assessm ent
Control Activities
Inform a tion &
Com m unica tion
M onitoring
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1.Demonstrates commitment to integrity & ethical values
2.Exercises oversight responsibility
3.Establishes structure, authority and responsibility
4.Demonstrates commitment to competence
5.Enforces accountability
6.Specifies suitable objectives
7.Identifies and analyzes risk
8.Assesses fraud risk
9.Identifies and analyzes significant change
10.Selects and develops control activities
11.Selects and develops general controls over technology
12.Deploys through policies and procedures
13.Uses relevant information
14.Communicates internally
15.Communicates Externally
16.Conducts ongoing and or separate evaluations
17.Evaluates and communicates deficiencies
Organizational Culture of
Accountability
Clarity/Transparency of Objectives
Accountability Plans & Systems
Information/Knowledge Sharing
Evaluations
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Internal Controls – Tips
and Tools
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