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Meeting DOE’s OMB Circular A-123 Requirements at Fermilab & Financial Management Assurance. Circular A-123: Management's Responsibility for Internal Control Appendix A (Internal Control over Financial Reporting). BACKGROUND. A-123:
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Meeting DOE’s OMB Circular A-123 Requirements at Fermilab&Financial Management Assurance Circular A-123: Management's Responsibility for Internal Control Appendix A (Internal Control over Financial Reporting)
BACKGROUND A-123: • Defines management’s responsibility for internal control in federal agencies. • Provides guidance to help management improve accountability and effectiveness of operations by maintaining effective internal controls, and assessing, correcting, and reporting on internal controls. • Applies to Fermilab through DOE. The Lab’s financial information and internal controls affect DOE. • First implemented in FY06.
BACKGROUND (cont.) Appendix A: • Ensures the Federal Government is committed to safeguarding its assets and providing reliable financial information. • Strengthens the requirements for methods management must use to assess, document, and report on internal control over financial reporting. • Emphasizes the need for agencies to integrate and coordinate internal control assessments with other internal control related activities. • Supports DOE’s requirement of quarterly reporting through DOE’s AART (A-123 Assessment & Reporting Tool).
A-123 Requirements • Document risks & controls over financial reporting for processes affecting “material accounts”. • Assess the design effectiveness of the controls, and document the assessment process. • Test the controls as DOE A-123 schedule dictates (A-123 year is July 1 – June 30). • Submit quarterly reports via the AART (A-123 Assessment & Reporting Tool). • Submit a Corrective Action Plan when deficiencies are identified by assessments and testing, and take corrective action.
2009 A-123 Activities • Document, assess, and test the Travel Process and Pro-Card Sub-Process. • Cyclical testing of other Sub-Processes (approximately 35 controls) • Testing cycle is 3 years (maximum) • Internal Audit conducts test work • Migrate to new Financial Management Assurance (FMA) Tool – when???
2009 Milestones • January 2009 – 1st Qtr AART due DOE-CH -done • April 2009 – 2nd Qtr AART due DOE-CH - done • June 2009 – Complete 2009 testing • July 2009 – 3rd Qtr AART due DOE-CH • New FMA tool due?? When?? What is FMA – “Financial Management Assurance?
Build on A-123,Evolve to a Common Approach Local …. SCIC FFMIA A-123 Leverage Capture Once
Certifications • Key Corporate Certifications • A-123, Appendix A (Controls over Financial Reporting) • FMFIA, Section II (Financial Management Controls) • FMFIA Section IV (Financial Management System Controls) • FISMA (Information System Controls) • FMS 2108, Year-end Closing Statement (Ending Balances) • Statement of Costs Incurred and Claimed Certification (Contractor Cost) • Other Certifications / Activities that can be supported • Mgmt. Representation Letter Assurances (Financial Statements) • Subsequent Events Calls (Financial statements) • Support Cost Data Certification • Financial Management System Certifications • Biennnial Pricing Reviews • Letter of Credit Certifications • Erroneous Payment/Recovery Audit Activities • Trial Balance Reconciliations • …….
Evolution from A-123 to FMA A-123 only Material Accounts focus Standard Process Cycle / Process Local Sub-processes Local Risks Inherent Risk (Impact / Likelihood) Control Sets …… PERCV Remediation / CAP Detail data capture (Test info, Rationales, Documentation location....) All Key Certifications incl A-123 Compliance and Risk based focus Standard Process Cycle / Process Standard Sub-processes StandardRisks / Local Risks Exposure Risk / Control Effectiveness / Risk Occurrence Controls / Standard Compliance Controls Name of System for Automated Controls No PERCV CAP References / No CAP Tracking in Release 1 Higher level data capture (delegated responsibility to Field / Detail data capture optional) A-123 FMA Targeted to year round use and certifications support
FMA Tool as Evolution from AART Controls Process Hierarchy Risks Risk Factors Evaluation Dates (Last, Next) Risk Assessment
Implementation Strategy & Timelines What we were told in December • Strategy • Migration timeline from AART to FMA is at the Site’s discretion during FY 2009 • Until a Site has migrated to FMA they continue with the AART and current certification approaches • Sites need to populate the FMA Tool with required data to support certifications • Everyone will be operational on FMA by October 1, 2009
FMA – What we know now • Latest Info: • Full rollout of FMA tool in May (previously October 1st) • Office of Internal Review will send out tool, guidance, and timeline “soon” (next week), to be followed by training webinars. • Will have to fill out both tools this year; no due date yet • No automated way to migrate risks & controls from AART to new tool • 192 standard risks identified with ability to add local risks • Risk definitions have changed in FMA; more robust risk analysis in new tool and testing cycles not as rigid • To be continued . . .