DOL Internal Control Program

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Roles and Responsibilities in Agency
Internal Control Programs Presented by
Steve Kozlowski
NYS DOL Internal Control Officer
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Presentation Objectives

• Outline internal control roles and
  responsibilities for each employee in an
  organization
• Highlight the key role played by the Internal
  Control Officer and Practitioner
• Provide information and ideas to take back to
  your jobs for improving effectiveness of your
  organizations internal control program

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Presenters Perspectives

• 31 year career employee with the NYS DOL
• 15 years experience implementing NYS Internal
  Control Act in DOL
• DOL organizational structure, size and culture
• Resources and support provided for internal
  control program

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References

• NYS Internal Control Act
• Budget Policy and Reporting Manual B-350
• NYS Internal Control Task Force Report and
  Compliance Roadmap
• OSC Standards

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All Employees Have Internal Control
Responsibilities

• ICO and IC Practitioner
• Internal Audit and other Internal Control Players
• Agency head and executive management
• Program Directors/Deputy Directors
• Unit managers
• Line employees

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Critical Role of Internal Control Officer
Practitioner

• ICO and IC Practitioner key to program
  effectiveness
• Main Responsibility coordinate implementation of
  Internal Control Act
• Facilitate and participate in implementation of
  varies aspects of the Law
• ICO/Practitioner may also play a positive role in
  otherwise improving agency internal control
  systems

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Role of ICO/IC PractitionerProviding Value

• Service Provider over Compliance Officer
• Cheerleader sales person for programand
  internal controls. Getting everyone on-board.
• Facilitator organize and coordinate effective
  internal control program. Assign responsibility.
• Educator facilitate and implement educational
  and training efforts.
• Consultant provide supportive services to
  managers on a formal as well as ad hoc basis.
• Collaborator partner with other IC agency
  players.

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Tips for being an Effective ICO or ICO
Practitioner

• Know the organization its mission, structure,
  key personnel
• Be familiar with basic internal control concepts
  and relevant background material
• Be customer friendly
• Tenacity helps
• Know and use agency resources

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Role of ICO/ IC PractitionerInternal Control Act
Implementation

• Internal Control Act assigns responsibility to
  ICO for ensuring implementation of the Acts six
  requirements
• Designating an ICO
• Guidelines for internal controls
• Statement of management policies and standards
• Internal control review program
• Internal control training and education
• Considering establishment of audit function
• Annual DOB certification and summary report
• Subject to DOB/OSC oversight

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Role of ICO/ IC PractitionerInternal Control
Review

• Establish and implement an infrastructure and
  process for the review program in consultation
  with management
• Organizational structure
• Assignment of responsibilities
• Scheduling of activities
• Review forms and process for use by managers
• Training components
• Reporting and tracking systems
• Quality control

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Role of ICO/ IC PractitionerTraining and
Education

• Foster internal control understanding and support
  in all employees
• Provide supervisors with tools and assistance in
  understanding, reviewing, and improving internal
  controls in their units activities and
  operations
• Various delivery methods
• Web site, newsletters, brochures, presentations,
  posters, instructional materials
• Make it understandable and relevant
• Use technology and available resources

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Role of ICO/ IC PractitionerConsultant

• Establish your niche and value as internal
  control expert
• Provide consultative services to managers on a
  formal as well as ad hoc basis
• Brief and keep management up to date
• Special projects and assignments

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Role of ICO/ IC PractitionerCollaborator

• Be aware of agency internal control systems
• Partner with other IC agency personnel
• Coordinate and reinforce efforts

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Agency IC Systems

• Internal Auditor Independent review of agency
  operations
• Information Security Officer Protecting IT
  information and systems
• IG/Investigations reviewing reports of employee
  misconduct
• Ethics Officer advising management and employees
  on Ethics Law requirements
• Records Officer
• Employee Relations
• Outside oversight groups OSC, Federal government

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Internal Audit

• Independent appraisal of agency operations to
  assure conformance with management policies and
  effectiveness of internal controls
• Must meet generally applicable auditing standards
  and DOB Guidelines
• Relationship with Internal Control Officer

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Role of Agency Head and Deputies

• Agency head is ultimately responsible for the
  organizations internal controls
• Sets the tone for the organization
• Agency head demonstrated support of internal
  controls is critical. Support of deputy
  commissioners also important
• Getting Executive Support
• Giving briefing sessions, preparing reports
  including annual DOB Certification Summary Report
• Drafting memos and messages for agency head to
  managers and employees on importance of program

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Role of Program Management

• Program directors and deputy directors set the
  tone for their organizations
• Their encouragement is important for open and
  diligent participation by assessable unit
  managers
• Value of integrating internal control program
  activities with their other management processes
• Getting Program Management Support and
  involvement
• Invoking executive support
• Briefing sessions
• Requiring program manager sign-off of review
  forms
• Having a well organized program and communication
  mechanism

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Role of Unit ManagersShowing IC Commitment to
Employees

• Serve as a role model for employees in
  demonstrating commitment to internal controls
• Should make sure employees understand internal
  controls and why they are important
• Should reinforce importance of internal controls
  and established procedures with their employees
• Require employees to be accountable

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Role of Unit ManagersInternal Control Review

• Directly responsible for internal controls in
  their operational areas
• Responsible for reviewing internal controls and
  identifying improvement opportunities
• Should openly and diligently complete
  self-reviews to identify unit internal control
  strengths and weaknesses and to plan for
  follow-up on improvement opportunities
• Should encourage employee involvement in
  reviewing and improving their units internal
  controls

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Role of Employees

• Carry out their job responsibilities properly
• Understand the importance of internal controls
  and take them seriously
• Follow internal controls and procedures in place
• Report internal control problems to their
  supervisor
• Participate in reviewing their units internal
  controls as requested by supervisor
• Know their responsibilities under the Ethics Law
  and be ethical in use and safeguarding of agency
  resources

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• Dept. of Labor Internal Control UnitBuilding
  12, Room 208
• Steven Kozlowski, ICO 518-457-2938

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