Standards for Internal Control in the Federal Government (Guidance,
11/01/1999, GAO/AIMD-00-21.3.1).

GAO published a guide on internal control standards for executive agency
managers as required by the Federal Managers' Financial Integrity Act.
The standards apply equally to program implementation and administration
as well as financial operations, and they are intended to help both
program and financial managers.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  AIMD-00-21.3.1
     TITLE:  Standards for Internal Control in the Federal Government
      DATE:  11/01/1999
   SUBJECT:  Internal controls
	     Standards evaluation
	     Auditing standards
	     Auditing procedures
	     Financial management
	     Federal agency accounting systems
	     Information resources management
	     Accountability

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Cover
================================================================ COVER

Internal Control

November 1999

STANDARDS FOR INTERNAL CONTROL IN
THE FEDERAL GOVERNMENT

GAO/AIMD-00-21.3.1

GAO/AIMD-00-021P

(11/99)

Abbreviations
=============================================================== ABBREV

  COSO - Committee of Sponsoring Organizations of the Treadway
     Commission
  FMFIA - Federal Managers' Financial Integrity Act of 1982
  GPRA - Government Performance and Results Act of 1993
  OMB - Office of Management and Budget

FOREWORD
============================================================ Chapter 0

Federal policymakers and program managers are continually seeking
ways to better achieve agencies' missions and program results, in
other words, they are seeking ways to improve accountability.  A key
factor in helping achieve such outcomes and minimize operational
problems is to implement appropriate internal control.  Effective
internal control also helps in managing change to cope with shifting
environments and evolving demands and priorities.  As programs change
and as agencies strive to improve operational processes and implement
new technological developments, management must continually assess
and evaluate its internal control to assure that the control
activities being used are effective and updated when necessary. 

The Federal Managers' Financial Integrity Act of 1982 (FMFIA)
requires the General Accounting Office (GAO) to issue standards for
internal control in government.  The standards provide the overall
framework for establishing and maintaining internal control and for
identifying and addressing major performance and management
challenges and areas at greatest risk of fraud, waste, abuse, and
mismanagement.  Office of Management and Budget (OMB) Circular A-123,
Management Accountability and Control, revised June 21, 1995,
provides the specific requirements for assessing and reporting on
controls.  The term internal control in this document is synonymous
with the term management control (as used in OMB Circular A-123) that
covers all aspects of an agency's operations (programmatic,
financial, and compliance). 

Recently, other laws have prompted renewed focus on internal control. 
The Government Performance and Results Act of 1993 requires agencies
to clarify their missions, set strategic and annual performance
goals, and measure and report on performance toward those goals. 
Internal control plays a significant role in helping managers achieve
those goals.  Also, the Chief Financial Officers Act of 1990 calls
for financial management systems to comply with internal control
standards, and the Federal Financial Management Improvement Act of
1996 identifies internal control as an integral part of improving
financial management systems. 

Rapid advances in information technology have highlighted the need
for updated internal control guidance related to modern computer
systems.  The management of human capital has gained recognition as a
significant part of internal control.  Furthermore, the private
sector has updated its internal control guidance with the issuance of
Internal Control -- Integrated Framework, published by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO). 
Consequently, we have developed this standards update which
supersedes our previously issued "Standards for Internal Controls in
the Federal Government."

This update gives greater recognition to the increasing use of
information technology to carry out critical government operations,
recognizes the importance of human capital, and incorporates, as
appropriate, the relevant updated internal control guidance developed
in the private sector.  The standards are effective beginning October
1, 1999. 

We appreciate the efforts of government officials, public accounting
professionals, and other members of the financial community and
academia who provided valuable assistance in developing these
standards.

David M.  Walker
Comptroller General
of the United States

INTRODUCTION
============================================================ Chapter 1

The following definition, objectives, and fundamental concepts
provide the foundation for the internal control standards. 

   DEFINITION AND OBJECTIVES
---------------------------------------------------------- Chapter 1:1

   (See figure in printed
   edition.)

Internal control is a major part of managing an organization.  It
comprises the plans, methods, and procedures used to meet missions,
goals, and objectives and, in doing so, supports performance-based
management.  Internal control also serves as the first line of
defense in safeguarding assets and preventing and detecting errors
and fraud.  In short, internal control, which is synonymous with
management control, helps government program managers achieve desired
results through effective stewardship of public resources. 

Internal control should provide reasonable assurance that the
objectives of the agency are being achieved in the following
categories: 

  -- Effectiveness and efficiency of operations including the use of
     the entity's resources. 

  -- Reliability of financial reporting, including reports on budget
     execution, financial statements, and other reports for internal
     and external use. 

  -- Compliance with applicable laws and regulations. 

A subset of these objectives is the safeguarding of assets.  Internal
control should be designed to provide reasonable assurance regarding
prevention of or prompt detection of unauthorized acquisition, use,
or disposition of an agency's assets. 

   FUNDAMENTAL CONCEPTS
---------------------------------------------------------- Chapter 1:2

   (See figure in printed
   edition.)

The fundamental concepts provide the underlying framework for
designing and applying the standards. 

      INTERNAL CONTROL IS A
      CONTINUOUS BUILT-IN
      COMPONENT OF OPERATIONS
-------------------------------------------------------- Chapter 1:2.1

Internal control is not one event, but a series of actions and
activities that occur throughout an entity's operations and on an
ongoing basis.  Internal control should be recognized as an integral
part of each system that management uses to regulate and guide its
operations rather than as a separate system within an agency.  In
this sense, internal control is management control that is built into
the entity as a part of its infrastructure to help managers run the
entity and achieve their aims on an ongoing basis. 

      INTERNAL CONTROL IS EFFECTED
      BY PEOPLE
-------------------------------------------------------- Chapter 1:2.2

People are what make internal control work.  The responsibility for
good internal control rests with all managers.  Management sets the
objectives, puts the control mechanisms and activities in place, and
monitors and evaluates the control.  However, all personnel in the
organization play important roles in making it happen. 

      INTERNAL CONTROL PROVIDES
      REASONABLE ASSURANCE, NOT
      ABSOLUTE ASSURANCE
-------------------------------------------------------- Chapter 1:2.3

Management should design and implement internal control based on the
related cost and benefits.  No matter how well designed and operated,
internal control cannot provide absolute assurance that all agency
objectives will be met.  Factors outside the control or influence of
management can affect the entity's ability to achieve all of its
goals.  For example, human mistakes, judgment errors, and acts of
collusion to circumvent control can affect meeting agency objectives. 
Therefore, once in place, internal control provides reasonable, not
absolute, assurance of meeting agency objectives. 

INTERNAL CONTROL STANDARDS
============================================================ Chapter 2

   PRESENTATION OF THE STANDARDS
---------------------------------------------------------- Chapter 2:1

   (See figure in printed
   edition.)

These standards define the minimum level of quality acceptable for
internal control in government and provide the basis against which
internal control is to be evaluated.  These standards apply to all
aspects of an agency's operations:  programmatic, financial, and
compliance.  However, they are not intended to limit or interfere
with duly granted authority related to developing legislation,
rule-making, or other discretionary policy-making in an agency. 
These standards provide a general framework.  In implementing these
standards, management is responsible for developing the detailed
policies, procedures, and practices to fit their agency's operations
and to ensure that they are built into and an integral part of
operations. 

In the following material, each of these standards is presented in a
short, concise statement.  Additional information is provided to help
managers incorporate the standards into their daily operations. 

   CONTROL ENVIRONMENT
---------------------------------------------------------- Chapter 2:2

   (See figure in printed
   edition.)

A positive control environment is the foundation for all other
standards.  It provides discipline and structure as well as the
climate which influences the quality of internal control.  Several
key factors affect the control environment. 

One factor is the integrity and ethical values maintained and
demonstrated by management and staff.  Agency management plays a key
role in providing leadership in this area, especially in setting and
maintaining the organization's ethical tone, providing guidance for
proper behavior, removing temptations for unethical behavior, and
providing discipline when appropriate. 

Another factor is management's commitment to competence.  All
personnel need to possess 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 control.  Management needs to identify appropriate knowledge
and skills needed for various jobs and provide needed training, as
well as candid and constructive counseling, and performance
appraisals. 

Management's philosophy and operating style also affect the
environment.  This factor determines the degree of risk the agency is
willing to take and management's philosophy towards performance-based
management.  Further, the attitude and philosophy of management
toward information systems, accounting, personnel functions,
monitoring, and audits and evaluations can have a profound effect on
internal control. 

Another factor affecting the environment is the agency's
organizational structure.  It provides management's framework for
planning, directing, and controlling operations to achieve agency
objectives.  A good internal control environment requires that the
agency's organizational structure clearly define key areas of
authority and responsibility and establish appropriate lines of
reporting. 

The environment is also affected by the manner in which the agency
delegates authority and responsibility throughout the organization. 
This delegation covers authority and responsibility for operating
activities, reporting relationships, and authorization protocols. 

Good human capital policies and practices are another critical
environmental factor.  This includes establishing appropriate
practices for hiring, orienting, training, evaluating, counseling,
promoting, compensating, and disciplining personnel.  It also
includes providing a proper amount of supervision. 

A final factor affecting the environment is the agency's relationship
with the Congress and central oversight agencies such as OMB. 
Congress mandates the programs that agencies undertake and monitors
their progress and central agencies provide policy and guidance on
many different matters.  In addition, Inspectors General and internal
senior management councils can contribute to a good overall control
environment. 

   RISK ASSESSMENT
---------------------------------------------------------- Chapter 2:3

   (See figure in printed
   edition.)

A precondition to risk assessment is the establishment of clear,
consistent agency objectives.  Risk assessment is the identification
and analysis of relevant risks associated with achieving the
objectives, such as those defined in strategic and annual performance
plans developed under the Government Performance and Results Act, and
forming a basis for determining how risks should be managed. 

Management needs to comprehensively identify risks and should
consider all significant interactions between the entity and other
parties as well as internal factors at both the entitywide and
activity level.  Risk identification methods may include qualitative
and quantitative ranking activities, management conferences,
forecasting and strategic planning, and consideration of findings
from audits and other assessments. 

Once risks have been identified, they should be analyzed for their
possible effect.  Risk analysis generally includes estimating the
risk's significance, assessing the likelihood of its occurrence, and
deciding how to manage the risk and what actions should be taken. 
The specific risk analysis methodology used can vary by agency
because of differences in agencies' missions and the difficulty in
qualitatively and quantitatively assigning risk levels. 

Because governmental, economic, industry, regulatory, and operating
conditions continually change, mechanisms should be provided to
identify and deal with any special risks prompted by such changes. 

   CONTROL ACTIVITIES
---------------------------------------------------------- Chapter 2:4

   (See figure in printed
   edition.)

Control activities are the policies, procedures, techniques, and
mechanisms that enforce management's directives, such as the process
of adhering to requirements for budget development and execution. 
They help ensure that actions are taken to address risks.  Control
activities are an integral part of an entity's planning,
implementing, reviewing, and accountability for stewardship of
government resources and achieving effective results. 

Control activities occur at all levels and functions of the entity. 
They include a wide range of diverse activities such as approvals,
authorizations, verifications, reconciliations, performance reviews,
maintenance of security, and the creation and maintenance of related
records which provide evidence of execution of these activities as
well as appropriate documentation.  Control activities may be applied
in a computerized information system environment or through manual
processes. 

Activities may be classified by specific control objectives, such as
ensuring completeness and accuracy of information processing. 

      EXAMPLES OF CONTROL
      ACTIVITIES
-------------------------------------------------------- Chapter 2:4.1

   (See figure in printed
   edition.)

There are certain categories of control activities that are common to
all agencies.  Examples include the following: 

         TOP LEVEL REVIEWS OF
         ACTUAL PERFORMANCE
------------------------------------------------------ Chapter 2:4.1.1

Management should track major agency achievements and compare these
to the plans, goals, and objectives established under the Government
Performance and Results Act. 

         REVIEWS BY MANAGEMENT AT
         THE FUNCTIONAL OR
         ACTIVITY LEVEL
------------------------------------------------------ Chapter 2:4.1.2

Managers also need to compare actual performance to planned or
expected results throughout the organization and analyze significant
differences. 

         MANAGEMENT OF HUMAN
         CAPITAL
------------------------------------------------------ Chapter 2:4.1.3

Effective management of an organization's workforce--its human
capital--is essential to achieving results and an important part of
internal control.  Management should view human capital as an asset
rather than a cost.  Only when the right personnel for the job are on
board and are provided the right training, tools, structure,
incentives, and responsibilities is operational success possible. 
Management should ensure that skill needs are continually assessed
and that the organization is able to obtain a workforce that has the
required skills that match those necessary to achieve organizational
goals.  Training should be aimed at developing and retaining employee
skill levels to meet changing organizational needs.  Qualified and
continuous supervision should be provided to ensure that internal
control objectives are achieved.  Performance evaluation and
feedback, supplemented by an effective reward system, should be
designed to help employees understand the connection between their
performance and the organization's success.  As a part of its human
capital planning, management should also consider how best to retain
valuable employees, plan for their eventual succession, and ensure
continuity of needed skills and abilities. 

         CONTROLS OVER INFORMATION
         PROCESSING
------------------------------------------------------ Chapter 2:4.1.4

A variety of control activities are used in information processing. 
Examples include edit checks of data entered, accounting for
transactions in numerical sequences, comparing file totals with
control accounts, and controlling access to data, files, and
programs.  Further guidance on control activities for information
processing is provided below under "Control Activities Specific for
Information Systems."

         PHYSICAL CONTROL OVER
         VULNERABLE ASSETS
------------------------------------------------------ Chapter 2:4.1.5

An agency must establish physical control to secure and safeguard
vulnerable assets.  Examples include security for and limited access
to assets such as cash, securities, inventories, and equipment which
might be vulnerable to risk of loss or unauthorized use.  Such assets
should be periodically counted and compared to control records. 

         ESTABLISHMENT AND REVIEW
         OF PERFORMANCE MEASURES
         AND INDICATORS
------------------------------------------------------ Chapter 2:4.1.6

Activities need to be established to monitor performance measures and
indicators.  These controls could call for comparisons and
assessments relating different sets of data to one another so that
analyses of the relationships can be made and appropriate actions
taken.  Controls should also be aimed at validating the propriety and
integrity of both organizational and individual performance measures
and indicators. 

         SEGREGATION OF DUTIES
------------------------------------------------------ Chapter 2:4.1.7

Key duties and responsibilities need to be divided or segregated
among different people to reduce the risk of error or fraud.  This
should include separating the responsibilities for authorizing
transactions, processing and recording them, reviewing the
transactions, and handling any related assets.  No one individual
should control all key aspects of a transaction or event. 

         PROPER EXECUTION OF
         TRANSACTIONS AND EVENTS
------------------------------------------------------ Chapter 2:4.1.8

Transactions and other significant events should be authorized and
executed only by persons acting within the scope of their authority. 
This is the principal means of assuring that only valid transactions
to exchange, transfer, use, or commit resources and other events are
initiated or entered into.  Authorizations should be clearly
communicated to managers and employees. 

         ACCURATE AND TIMELY
         RECORDING OF TRANSACTIONS
         AND EVENTS
------------------------------------------------------ Chapter 2:4.1.9

Transactions should be promptly recorded to maintain their relevance
and value to management in controlling operations and making
decisions.  This applies to the entire process or life cycle of a
transaction or event from the initiation and authorization through
its final classification in summary records.  In addition, control
activities help to ensure that all transactions are completely and
accurately recorded. 

         ACCESS RESTRICTIONS TO
         AND ACCOUNTABILITY FOR
         RESOURCES AND RECORDS
----------------------------------------------------- Chapter 2:4.1.10

Access to resources and records should be limited to authorized
individuals, and accountability for their custody and use should be
assigned and maintained.  Periodic comparison of resources with the
recorded accountability should be made to help reduce the risk of
errors, fraud, misuse, or unauthorized alteration. 

         APPROPRIATE DOCUMENTATION
         OF TRANSACTIONS AND
         INTERNAL CONTROL
----------------------------------------------------- Chapter 2:4.1.11

Internal control and all transactions and other significant events
need to be clearly documented, and the documentation should be
readily available for examination.  The documentation should appear
in management directives, administrative policies, or operating
manuals and may be in paper or electronic form.  All documentation
and records should be properly managed and maintained. 

These examples are meant only to illustrate the range and variety of
control activities that may be useful to agency managers.  They are
not all-inclusive and may not include particular control activities
that an agency may need. 

Furthermore, an agency's internal control should be flexible to allow
agencies to tailor control activities to fit their special needs. 
The specific control activities used by a given agency may be
different from those used by others due to a number of factors. 
These could include specific threats they face and risks they incur;
differences in objectives; managerial judgment; size and complexity
of the organization; operational environment; sensitivity and value
of data; and requirements for system reliability, availability, and
performance. 

      CONTROL ACTIVITIES SPECIFIC
      FOR INFORMATION SYSTEMS
-------------------------------------------------------- Chapter 2:4.2

   (See figure in printed
   edition.)

There are two broad groupings of information systems control -
general control and application control.  General control applies to
all information systems--mainframe, minicomputer, network, and
end-user environments.  Application control is designed to cover the
processing of data within the application software. 

         GENERAL CONTROL
------------------------------------------------------ Chapter 2:4.2.1

This category includes entitywide security program planning,
management, control over data center operations, system software
acquisition and maintenance, access security, and application system
development and maintenance.  More specifically: 

  -- Data center and client-server operations controls include backup
     and recovery procedures, and contingency and disaster planning. 
     In addition, data center operations controls also include job
     set-up and scheduling procedures and controls over operator
     activities. 

  -- System software control includes control over the acquisition,
     implementation, and maintenance of all system software including
     the operating system, data-based management systems,
     telecommunications, security software, and utility programs. 

  -- Access security control protects the systems and network from
     inappropriate access and unauthorized use by hackers and other
     trespassers or inappropriate use by agency personnel.  Specific
     control activities include frequent changes of dial-up numbers;
     use of dial-back access; restrictions on users to allow access
     only to system functions that they need; software and hardware
     "firewalls" to restrict access to assets, computers, and
     networks by external persons; and frequent changes of passwords
     and deactivation of former employees' passwords. 

  -- Application system development and maintenance control provides
     the structure for safely developing new systems and modifying
     existing systems.  Included are documentation requirements;
     authorizations for undertaking projects; and reviews, testing,
     and approvals of development and modification activities before
     placing systems into operation.  An alternative to in-house
     development is the procurement of commercial software, but
     control is necessary to ensure that selected software meets the
     user's needs, and that it is properly placed into operation. 

         APPLICATION CONTROL
------------------------------------------------------ Chapter 2:4.2.2

This category of control is designed to help ensure completeness,
accuracy, authorization, and validity of all transactions during
application processing.  Control should be installed at an
application's interfaces with other systems to ensure that all inputs
are received and are valid and outputs are correct and properly
distributed.  An example is computerized edit checks built into the
system to review the format, existence, and reasonableness of data. 

General and application control over computer systems are
interrelated.  General control supports the functioning of
application control, and both are needed to ensure complete and
accurate information processing.  If the general control is
inadequate, the application control is unlikely to function properly
and could be overridden. 

Because information technology changes rapidly, controls must evolve
to remain effective.  Changes in technology and its application to
electronic commerce and expanding Internet applications will change
the specific control activities that may be employed and how they are
implemented, but the basic requirements of control will not have
changed.  As more powerful computers place more responsibility for
data processing in the hands of the end users, the needed controls
should be identified and implemented. 

   INFORMATION AND COMMUNICATIONS
---------------------------------------------------------- Chapter 2:5

   (See figure in printed
   edition.)

For an entity to run and control its operations, it must have
relevant, reliable, and timely communications relating to internal as
well as external events.  Information is needed throughout the agency
to achieve all of its objectives. 

Program managers need both operational and financial data to
determine whether they are meeting their agencies' strategic and
annual performance plans and meeting their goals for accountability
for effective and efficient use of resources.  For example, operating
information is required for development of financial reports.  This
covers a broad range of data from purchases, subsidies, and other
transactions to data on fixed assets, inventories, and receivables. 
Operating information is also needed to determine whether the agency
is achieving its compliance requirements under various laws and
regulations.  Financial information is needed for both external and
internal uses.  It is required to develop financial statements for
periodic external reporting, and, on a day-to-day basis, to make
operating decisions, montinor performance, and allocate resources. 
Pertinent information should be identified, captured, and distributed
in a form and time frame that permits people to perform their duties
efficiently. 

Effective communications should occur in a broad sense with
information flowing down, across, and up the organization.  In
additional to internal communications, management should ensure there
are adequate means of communicating with, and obtaining information
from, external stakeholders that may have a significant impact on the
agency achieving its goals.  Moreover, effective information
technology management is critical to achieving useful, reliable, and
continuous recording and communication of information. 

   MONITORING
---------------------------------------------------------- Chapter 2:6

   (See figure in printed
   edition.)

Internal control should generally be designed to assure that ongoing
monitoring occurs in the course of normal operations.  It is
performed continually and is ingrained in the agency's operations. 
It includes regular management and supervisory activities,
comparisons, reconciliations, and other actions people take in
performing their duties. 

Separate evaluations of control can also be useful by focusing
directly on the controls' effectiveness at a specific time.  The
scope and frequency of separate evaluations should depend primarily
on the assessment of risks and the effectiveness of ongoing
monitoring procedures.  Separate evaluations may take the form of
self-assessments as well as review of control design and direct
testing of internal control.  Separate evaluations also may be
performed by the agency Inspector General or an external auditor. 
Deficiencies found during ongoing monitoring or through separate
evaluations should be communicated to the individual responsible for
the function and also to at least one level of management above that
individual.  Serious matters should be reported to top management. 

Monitoring of internal control should include policies and procedures
for ensuring that the findings of audits and other reviews are
promptly resolved.  Managers are to (1) promptly evaluate findings
from audits and other reviews, including those showing deficiencies
and recommendations reported by auditors and others who evaluate
agencies' operations, (2) determine proper actions in response to
findings and recommendations from audits and reviews, and (3)
complete, within established time frames, all actions that correct or
otherwise resolve the matters brought to management's attention.  The
resolution process begins when audit or other review results are
reported to management, and is completed only after action has been
taken that (1) corrects identified deficiencies, (2) produces
improvements, or (3) demonstrates the findings and recommendations do
not warrant management action. 

*** End of document. ***