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SAS112 Implementation UCSD Status Update. SAS112 Refresher . Communication to the Governing Board of Internal Control Related Matters Noted in an Audit. Significantly “lowers the bar” as to what is required to be reported.
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SAS112 Implementation UCSD Status Update UCSD Office of the Controller
SAS112 Refresher • Communication to the Governing Board of Internal Control Related Matters Noted in an Audit. • Significantly “lowers the bar” as to what is required to be reported. • Is effective for universities for the current fiscal year that began June 30, 2006. UCSD Office of the Controller
SAS112 Levels of Reporting • A control deficiency exists when the design or operation of a control does not allow for the prevention or detection of misstatements in a timely manner. • A significant deficiency is a control deficiency that adversely affects our ability to initiate, authorize, record, process, or report external financial data reliably in accordance with GAAP such that there is more than a remote likelihood that a misstatement of our financial statements that is more than inconsequential will not be prevented or detected. • A material weakness is a significant deficiency that results in more than a remote likelihood that a material misstatement of our financial statements will not be prevented or detected. UCSD Office of the Controller
SAS112 Reporting Triggers for UCSD • A significant deficiency is triggered for the campus if the misstatement “could be” $2.9 million.(0.2% of Oper. Exp.) • A material weakness is triggered for the campus if the misstatement “could be” $14.7 million.(1% of Oper. Exp.) • Certain conditions defined are “presumptive” of the above. UCSD Office of the Controller
SAS112 Presumed Significant Deficiencies or Material Weaknesses • Ineffective governance or ineffective oversight of internal control. • Material misstatement of the financial statement discovered by the auditor during the annual audit. • Ineffective internal audit or risk assessment function. • Ineffective regulatory compliance function. • Identification of any fraud on the part of senior management. • Failure by management to assess a significant deficiency that has been communicated to them, and failure to correct such deficiency. UCSD Office of the Controller
Requirements for Key Controls Under SAS 112 • A key control must exist. • A key control must be functioning effectively. • A key control must be documented. UCSD Office of the Controller
Why is a Reportable Condition Under SAS112 Likely at UCSD? • Similar requirements in the corporate world resulted in an initial high percentage of reportable matters. • UCSD’s control environment is highly decentralized. • SAS112 has already been in effect for UCSD for 8 months. • All requirements of a key control will be difficult to meet initially. • We are trying to do this with existing resources. Corporations spent millions. UCSD Office of the Controller
Strategies in Response to SAS112 • Identify Key Controls • Non-IT controls have been identified and confirmed. • IT controls in process. • Assess Key Controls • Beginning with core business functions. • Working on improving systems for overall mitigating controls. UCSD Office of the Controller
Strategies in Response to SAS112 • Assess Presumptive Conditions • Evaluation in progress. • Make Necessary Changes in Response to Assessments • Will proceed as assessments are completed. • Communicate Widely Regarding Control Responsibilities • Working with VC offices to establish contact with leaders in various areas. • Presenting to all business officer forums. UCSD Office of the Controller
Principles of Good Internal Control • Internal Control is the responsibility of EVERYONE. • Control is a person at the source, knowing the right thing to do, and DOING IT. • If you are relying on someone else to be the “bad guy”, we have lost control. • Accountability is essential if we are all going to do the right thing every time. UCSD Office of the Controller