NASC Presentation – March 2014 An Overview of Pennsylvania’s Internal Controls By: Anna Maria Kiehl, CPA State Comptroller/Chief Accounting Officer Governor’s Office of Budget / Office of Comptroller Operations

 Pennsylvania’s Internal Control Structure  Statewide Audit Committee - Functions of the Audit Committee - Goals and Objectives of the Committee - Frequency of Committee Meetings - Questions?  Single Audit Finding Prompts need to improve Access Controls with SAP’s Governance Risk Compliance - Background - Overview - Challenges - Actions - Useful Tools - Sample internal flowcharts & reporting - Questions? Agenda 2 NASC Presentation – March

Examples of Internal Controls in Pennsylvania 3 NASC Presentation – March 2014 Implement controls through effective policies & procedures: General System Controls/data security System access controls Month-end closing processes and reconciliations Methods for identifying and assessing risk: Recommendations of Audit Committee/Audit findings/MLCs System Development Life cycle Reviews /Post implementation reviews Examining new programs and areas most vulnerable (e.g., systems, financial reporting, operational) Control Environment Risk Assessment Control Activities Components Process Methods for maintaining integrity, ethics and competency: Governor’s Code of Conduct/Ethics Disclosure Forms Statewide Audit Committee/Bureau of Internal Audits Auditor General Audits & Inspector General Investigations Bureau of Quality Assurance Independent annual audits Continuous IC Training & Employee Development/Standards Increased accounting and auditing entry level requirements 3

PA’s Process to Ensure Effective Internal Controls 4 NASC Presentation – March 2014 Information & Communication Components Process Information must be disseminated timely: Monthly /Quarterly/Comprehensive Annual Financial Reporting Required Communications with Management on Audit findings & Required Resolutions Quarterly Audit Committee Meetings/Annual Audit Plan/Findings Policy communications, e.g., New OMB Grant Reform standards Entity-wide business process communications On-line and classroom training for fraud detection and prevention, ethics, accountability and transparency requirements 4

PA’s Process to Ensure Effective Internal Controls  Monitoring Activities Methods to continuously monitor internal controls include: Monitoring of role assignments & segregation of duties Continuous control payment monitoring Performance metrics and analysis/ management dashboards Quality assurance processes to ensure compliance with laws, regulations, and policies. Weekly system access Controls risk reporting Inventory and Fixed Asset monitoring Management reviews/System Development Life Cycle Reviews Components Process 5

6 NASC Presentation – March 2014 Questions or Comments? PA’s Process to Ensure Effective Internal Controls 6

 The audit committee reviews and discusses the following with the external auditors:  Annual financial statements (CAFR)  Single Audit report and findings  Significant written communications between the independent auditors and management (i.e. management letter, unadjusted audit differences)  Significant disputes or difficulties with management encountered during the audit  Matters required to be discussed in accordance with SAS 114, “The Auditors Communication with Those Charged with Governance” Functions of an Audit Committee 7 NASC Presentation – March

Internal Controls  Review the following with the internal auditors:  Significant risks or exposures facing the Commonwealth, as well as steps taken by management to mitigate these risks  The audit scope and plan for the internal auditors  Any significant findings and recommendations, from internal audits, along with management’s response  Any difficulties the internal audit team encountered in the course of their audits Functions of an Audit Committee 8 NASC Presentation – March

 Oversee the internal and external auditing and reporting process  Provide direction for the Commonwealth’s limited internal audit resources  Review and approve the Commonwealth annual audit plan to promote accountability and ensure management maintains appropriate internal controls  Review audit findings and recommendations and directs the necessary follow-up to ensure appropriate corrective action is initiated across state agencies. Goals and Objectives of the Committee 9 NASC Presentation – March

PA has been moving forward with five strategic goals. These strategic goals are as follows:  Established a Commonwealth-wide audit committee.  Facilitate Control Self Assessment sessions with agency heads and management  Complete a Commonwealth-wide audit risk assessment  Develop an annual audit plan based on risk  Established a Bureau of Quality Assurance to provide continuous monitoring for improper payments, compliance, and continuous process improvements. Enterprise Risk Management (ERM) 10 NASC Presentation – March

Notifications will be provided to the committee when the following occur:  Department of the Auditor General Opens a Special Performance Audit  US Office of the Inspector General Opens an Audit  Department of the Auditor General Releases a Special Performance Audit  US Office of the Inspector General Releases an Audit  BOA Releases a High Profile Audit Audit Committee Communications 10 NASC Presentation – March

 The Audit Committee meets 3-4 times annually  Usually meets at least twice with independent auditors to discuss CAFR and Single audits, auditor adjustments, audit findings, and management letter comments.  Usually meets to approve annual internal audit plan and requests management reviews and audits of risk areas  Agenda is typically set by the Director of the Bureau of Audits  Comptroller and Director of Reporting attend the meetings and provide content. Frequency of Audit Committee Meetings 12 NASC Presentation – March

Audit Committee 13 NASC Presentation – March 2014 Questions or Comments? 13

Background:  Segregation of Duties risks within the Commonwealth’s SAP system resulted in a recurring single audit finding for 8 consecutive years.  Previous attempts were made to address SAP Access Controls: Approva failed since it was not directly integrated with SAP.  Number of users – Large organization with thousands of core users – needed a tool that could analyze large numbers of users with extensive access to multiple modules of SAP. SAP’s Governance, Risk & Compliance Module (GRC) 14 NASC Presentation – March

 “Governance” is how we manage strategic initiatives  “Risk” is the effect of uncertainty on business objectives. Risk management is the process that helps minimize financial losses  “Compliance” goes beyond our conformity with laws and regulations to include all facets that affect integrity, reputation, and our “brand”  SAP’s GRC module provides the Commonwealth with an enterprise view across these activities throughout our organization. 15 NASC Presentation – March 2014 SAP’s Governance, Risk & Compliance Module (GRC) 15

GRC is the system access control tool that helps:  Protect key information  Prevent unauthorized access  Prevent unauthorized transactions  Prevent errors and fraudulent activity  Ensures proper Segregation of Duties (SoD)  Ensure the security & integrity of our financial systems & reporting 16 NASC Presentation – March 2014 SAP’s Governance, Risk & Compliance Module (GRC) 16

Challenges:  The complexity of the GRC module/ significant learning curve.  The complexity and extent of access issues that developed over ten years that SAP was in place.  Little understanding of GRC from a rule set /business perspective  Few resources to dedicate to such a large project  Budget constraints prevented hiring SAP consultants  Minimal guidance on how to best implement the system within our current business environment.  PA’s role assignment process is managed by another state agency and sits outside of SAP.  Multiple agency involvement – role development (OA-IT), role assignment (OA/HR) and risk monitoring (Comptroller) 17 NASC Presentation – March 2014 SAP’s Governance, Risk & Compliance Module (GRC) 17

Year 2010 – Year of Planning and gaining an understanding of the system tools  Small project team developed to coordinate the clean-up of SoD risks.  The group led workshops of technical and business representatives to determine how to identify and resolve risks.  Process is on-going 18 NASC Presentation – March 2014 SAP’s Governance, Risk & Compliance Module (GRC) 18

Tremendous Progress within the last 6 months  Resolving risks identified within our Office of Budget  Systematizing & automating processes  Documenting processes & procedures  Improving communication between agencies  Reporting  And training personnel 19 NASC Presentation – March 2014 SAP’s Governance, Risk & Compliance Module (GRC) 19

The Future:  To continue GRC rollout to agencies with greatest number of risks  Expect the cleanup to benefit the remaining agencies who share same roles/risks.  Expect roles to stay clean going forward using GRC simulation tool.  Most current pain: establishing a process to help agency HR reps interpret SoD risk results before requesting a role for their users. 20 NASC Presentation – March 2014 SAP’s Governance, Risk & Compliance Module (GRC) 20

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SAP’s Governance, Risk & Compliance 27 NASC Presentation – March 2014 Questions? 27