The AOC Inspector General’s Statement of Management Opportunities and Performance Challenges (continued)

Enhancing Internal Controls

After 12 years of struggling to implement an Internal Control Program, the AOC has made significant inroads into establishing a viable program over the past year. The Internal Control Material Weakness identified in the Fiscal Year (FY) 2012 Financial Statements Audit was not reaffirmed in the FY 2013 Financial Statements Audit. In addition, the Senior Management Council (SMC) has not only prioritized completing the steps necessary to implement the program but is establishing firm milestone dates and formalizing Internal Control Policy. The draft policy provides sufficient detail to ensure personnel are aware of their roles in the process. Personnel at all levels of the process are to be held accountable for completion of assigned tasks.

AOC’s senior leaders along with the Senior Assessment Team (SAT), are responsible for setting the proper tone and provide all the resources needed for success. Vulnerability assessments have been updated and completed to identify areas for testing. Testing in limited areas is being completed and reviewed. The SMC recognizes that AOC’s Internal Control Program is in its relative infancy and plans on continuing the contractual arrangement that has aided their efforts to date.

From our past perspective, a stumbling block in this management challenge was an agency-wide culture that viewed internal controls as an extra burden, rather than as a necessary part of how each employee approaches day-to-day work. AOC still does not have a robust program; however, senior management at this point has committed to establishing internal controls as a cornerstone of its accountability structure.

We will continue our roles on the SMC and the SAT, as an advisor, and monitor actual implementation through OIG Audits and Investigations.

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