Companies set up an ICFR (internal control over financial reporting) strategy, establish policies and procedures for internal control, assess the control environment and risks of material misstatement of financial statements, monitor and approve transactions, test a sample of transactions, and issue ICFR report certifications by the CEO and CFO filed as part of their 10-K. Show Companies establish internal control systems with policies and procedures that include segregation of duties, invoice document matching, and authorizations and approvals. For proper separation of duties, the same employee isn’t handling assets like cash and recording accounting transactions for revenue, costs, assets, expenses, and other expenditures. Businesses establish a control environment that includes the corporate culture, an ethical executive management tone that encourages proper financial reporting, and the Audit Committee’s review of the financial statements as a source of high-level oversight. ICFR relates to the preparation of financial statements and includes data security requirements. The financial statements should be internally reviewed, including authorizing journal entries, reconciling accounts to the general ledger, comparing financial statements to the underlying accounting records, and evaluating reasonableness through an analytic review. FP&A procedures like trend analysis, ratios computation, and variance analysis comparing actual with budgeted amounts should be scrutinized as another check on financial statement accuracy. On an annual basis, management’s assessment of internal control over financial statements is performed. Management of public companies reports the results regarding reasonable assurance of the operating effectiveness of ICFR at the business in the 10-K. Quarterly, management assesses if any material changes in its ICFR have occurred. In Form 10-Q reports filed with the SEC, management has reporting requirements to disclose that it has responsibility for establishing and maintaining ICFR. It must include any changes to ICFR that have or are likely to affect its ICFR materially. All public companies (registrants) must include management’s report on internal control over financial reporting in their Form 10-K annual report filed with the SEC, per SOX 404(a). The SEC requires publicly traded companies with at least $100 million in revenue to have their auditors complete a separate attestation of ICFR (internal control over financial reporting)and also include the auditor attestation report in their Form 10-K. The company must disclose material weaknesses in internal control in its SEC filing. The company should have procedures to remedy internal control, particularly those deemed significant deficiencies or the most severe classification of ICFR deficiency, material weaknesses.
Internal control is all of the policies and procedures management uses to achieve the following goals. Management Responsibility: Administrative management is responsible for maintaining an adequate system of internal control. Management is responsible for communicating the expectations and duties of staff as part of a control environment. They are also responsible for assuring that the other major areas of an internal control framework are addressed. Staff Responsibility: Staff and operating personnel are responsible for carrying out the internal control activities set forth by management. The framework of a good internal control system includes: Internal control activities are the policies and procedures as well as the daily activities that occur within an internal control system. A good internal control system should include the control activities listed below. These activities generally fit into two types of activities. Click on the links below for information regarding these activities including best practices.
Other Internal Control Best PracticesWith a good internal control system in place, other considerations to keep in mind include:
Additional InformationWashington State Office of Financial Management's guide to internal control and auditing |