Standards for Internal Control in the Federal Government (Supersedes AIMD-98-21.3.1)

Published by the Government Accountability Office on 1999-11-01.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                     United States General Accounting Office

GAO                  Internal Control

November 1999
                     Standards for Internal
                     Control in the Federal


           Federal policymakers and program managers are
           continually seeking ways to better achieve agencies’
           missions and program results, in other words, they
           are seeking ways to improve accountability. A key
           factor in helping achieve such outcomes and minimize
           operational problems is to implement appropriate
           internal control. Effective internal control also helps
           in managing change to cope with shifting
           environments and evolving demands and priorities. As
           programs change and as agencies strive to improve
           operational processes and implement new
           technological developments, management must
           continually assess and evaluate its internal control to
           assure that the control activities being used are
           effective and updated when necessary.

           The Federal Managers’ Financial Integrity Act of 1982
           (FMFIA) requires the General Accounting Office (GAO)
           to issue standards for internal control in government.
           The standards provide the overall framework for
           establishing and maintaining internal control and for
           identifying and addressing major performance and
           management challenges and areas at greatest risk of
           fraud, waste, abuse, and mismanagement. Office of
           Management and Budget (OMB) Circular A-123,
           Management Accountability and Control, revised
           June 21, 1995, provides the specific requirements for
           assessing and reporting on controls. The term internal
           control in this document is synonymous with the term
           management control (as used in OMB Circular
           A-123) that covers all aspects of an agency’s
           operations (programmatic, financial, and

           Recently, other laws have prompted renewed focus
           on internal control. The Government Performance
           and Results Act of 1993 requires agencies to clarify
           their missions, set strategic and annual performance
           goals, and measure and report on performance

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toward those goals. Internal control plays a
significant role in helping managers achieve those
goals. Also, the Chief Financial Officers Act of 1990
calls for financial management systems to comply
with internal control standards, and the Federal
Financial Management Improvement Act of 1996
identifies internal control as an integral part of
improving financial management systems.

Rapid advances in information technology have
highlighted the need for updated internal control
guidance related to modern computer systems. The
management of human capital has gained recognition
as a significant part of internal control. Furthermore,
the private sector has updated its internal control
guidance with the issuance of Internal Control —
Integrated Framework, published by the Committee
of Sponsoring Organizations of the Treadway
Commission (COSO). Consequently, we have
developed this standards update which supersedes
our previously issued “Standards for Internal Controls
in the Federal Government.”

This update gives greater recognition to the
increasing use of information technology to carry out
critical government operations, recognizes the
importance of human capital, and incorporates, as
appropriate, the relevant updated internal control
guidance developed in the private sector. The
standards are effective beginning with fiscal year 2000
and the Federal Managers Financial Integrity Act
reports covering that year.

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We appreciate the efforts of government officials,
public accounting professionals, and other members
of the financial community and academia who
provided valuable assistance in developing these

David M. Walker
Comptroller General
of the United States

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                 The following definition, objectives, and fundamental
                 concepts provide the foundation for the internal
                 control standards.

Definition and
                    Internal Control

                    An integral component of an organization’s
                    management that provides reasonable assurance
                    that the following objectives are being achieved:

                    • effectiveness and efficiency of operations,
                    • reliability of financial reporting, and
                    • compliance with applicable laws and regulations.

                 Internal control is a major part of managing an
                 organization. It comprises the plans, methods, and
                 procedures used to meet missions, goals, and
                 objectives and, in doing so, supports
                 performance-based management. Internal control also
                 serves as the first line of defense in safeguarding
                 assets and preventing and detecting errors and fraud.
                 In short, internal control, which is synonymous with
                 management control, helps government program
                 managers achieve desired results through effective
                 stewardship of public resources.

                 Internal control should provide reasonable assurance
                 that the objectives of the agency are being achieved in
                 the following categories:

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                        •   Effectiveness and efficiency of operations including
                            the use of the entity’s resources.
                        •   Reliability of financial reporting, including reports on
                            budget execution, financial statements, and other
                            reports for internal and external use.
                        •   Compliance with applicable laws and regulations.

                            A subset of these objectives is the safeguarding of
                            assets. Internal control should be designed to provide
                            reasonable assurance regarding prevention of or
                            prompt detection of unauthorized acquisition, use, or
                            disposition of an agency’s assets.

Concepts                        Internal Control

                                • A continuous built-in component of operations.
                                • Effected by people.
                                • Provides reasonable assurance, not absolute

                            The fundamental concepts provide the underlying
                            framework for designing and applying the standards.

Internal Control Is a       Internal control is not one event, but a series of
Continuous Built-in         actions and activities that occur throughout an
Component of                entity’s operations and on an ongoing basis. Internal
                            control should be recognized as an integral part of
Operations                  each system that management uses to regulate and
                            guide its operations rather than as a separate system
                            within an agency. In this sense, internal control is
                            management control that is built into the entity as a

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                      part of its infrastructure to help managers run the
                      entity and achieve their aims on an ongoing basis.

Internal Control Is   People are what make internal control work. The
Effected by People    responsibility for good internal control rests with all
                      managers. Management sets the objectives, puts the
                      control mechanisms and activities in place, and
                      monitors and evaluates the control. However, all
                      personnel in the organization play important roles in
                      making it happen.

Internal Control      Management should design and implement internal
Provides Reasonable   control based on the related cost and benefits. No
Assurance, Not        matter how well designed and operated, internal
                      control cannot provide absolute assurance that all
Absolute Assurance    agency objectives will be met. Factors outside the
                      control or influence of management can affect the
                      entity’s ability to achieve all of its goals. For example,
                      human mistakes, judgment errors, and acts of
                      collusion to circumvent control can affect meeting
                      agency objectives. Therefore, once in place, internal
                      control provides reasonable, not absolute, assurance
                      of meeting agency objectives.

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Internal Control Standards

Presentation of
the Standards
                      The Five Standards for Internal Control

                      •   Control Environment
                      •   Risk Assessment
                      •   Control Activities
                      •   Information and Communications
                      •   Monitoring

                  These standards define the minimum level of quality
                  acceptable for internal control in government and
                  provide the basis against which internal control is to
                  be evaluated. These standards apply to all aspects of
                  an agency’s operations: programmatic, financial, and
                  compliance. However, they are not intended to limit
                  or interfere with duly granted authority related to
                  developing legislation, rule-making, or other
                  discretionary policy-making in an agency. These
                  standards provide a general framework. In
                  implementing these standards, management is
                  responsible for developing the detailed policies,
                  procedures, and practices to fit their agency’s
                  operations and to ensure that they are built into and
                  an integral part of operations.

                  In the following material, each of these standards is
                  presented in a short, concise statement. Additional
                  information is provided to help managers incorporate
                  the standards into their daily operations.

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              Internal Control Standards

                  Management and employees should establish
                  and maintain an environment throughout the
                  organization that sets a positive and supportive
                  attitude toward internal control and conscientious

              A positive control environment is the foundation for
              all other standards. It provides discipline and
              structure as well as the climate which influences the
              quality of internal control. Several key factors affect
              the control environment.

              One factor is the integrity and ethical values
              maintained and demonstrated by management and
              staff. Agency management plays a key role in
              providing leadership in this area, especially in setting
              and maintaining the organization’s ethical tone,
              providing guidance for proper behavior, removing
              temptations for unethical behavior, and providing
              discipline when appropriate.

              Another factor is management’s commitment to
              competence. All personnel need to possess and
              maintain a level of competence that allows them to
              accomplish their assigned duties, as well as
              understand the importance of developing and
              implementing good internal control. Management
              needs to identify appropriate knowledge and skills
              needed for various jobs and provide needed training,
              as well as candid and constructive counseling, and
              performance appraisals.

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Internal Control Standards

Management’s philosophy and operating style also
affect the environment. This factor determines the
degree of risk the agency is willing to take and
management’s philosophy towards
performance-based management. Further, the attitude
and philosophy of management toward information
systems, accounting, personnel functions, monitoring,
and audits and evaluations can have a profound effect
on internal control.

Another factor affecting the environment is the
agency’s organizational structure. It provides
management’s framework for planning, directing, and
controlling operations to achieve agency objectives. A
good internal control environment requires that the
agency’s organizational structure clearly define key
areas of authority and responsibility and establish
appropriate lines of reporting.

The environment is also affected by the manner in
which the agency delegates authority and
responsibility throughout the organization. This
delegation covers authority and responsibility for
operating activities, reporting relationships, and
authorization protocols.

Good human capital policies and practices are
another critical environmental factor. This includes
establishing appropriate practices for hiring,
orienting, training, evaluating, counseling, promoting,
compensating, and disciplining personnel. It also
includes providing a proper amount of supervision.

A final factor affecting the environment is the
agency’s relationship with the Congress and central
oversight agencies such as OMB. Congress mandates
the programs that agencies undertake and monitors
their progress and central agencies provide policy and
guidance on many different matters. In addition,

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                  Internal Control Standards

                  Inspectors General and internal senior management
                  councils can contribute to a good overall control

Risk Assessment
                      Internal control should provide for an assessment
                      of the risks the agency faces from both external
                      and internal sources.

                  A precondition to risk assessment is the
                  establishment of clear, consistent agency objectives.
                  Risk assessment is the identification and analysis of
                  relevant risks associated with achieving the
                  objectives, such as those defined in strategic and
                  annual performance plans developed under the
                  Government Performance and Results Act, and
                  forming a basis for determining how risks should be

                  Management needs to comprehensively identify risks
                  and should consider all significant interactions
                  between the entity and other parties as well as
                  internal factors at both the entitywide and activity
                  level. Risk identification methods may include
                  qualitative and quantitative ranking activities,
                  management conferences, forecasting and strategic
                  planning, and consideration of findings from audits
                  and other assessments.

                  Once risks have been identified, they should be
                  analyzed for their possible effect. Risk analysis
                  generally includes estimating the risk’s significance,
                  assessing the likelihood of its occurrence, and

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                     Internal Control Standards

                     deciding how to manage the risk and what actions
                     should be taken. The specific risk analysis
                     methodology used can vary by agency because of
                     differences in agencies’ missions and the difficulty in
                     qualitatively and quantitatively assigning risk levels.

                     Because governmental, economic, industry,
                     regulatory, and operating conditions continually
                     change, mechanisms should be provided to identify
                     and deal with any special risks prompted by such

Control Activities
                          Internal control activities help ensure that
                          management's directives are carried out. The
                          control activities should be effective and efficient
                          in accomplishing the agency's control objectives.

                     Control activities are the policies, procedures,
                     techniques, and mechanisms that enforce
                     management’s directives, such as the process of
                     adhering to requirements for budget development and
                     execution. They help ensure that actions are taken to
                     address risks. Control activities are an integral part of
                     an entity’s planning, implementing, reviewing, and
                     accountability for stewardship of government
                     resources and achieving effective results.

                     Control activities occur at all levels and functions of
                     the entity. They include a wide range of diverse
                     activities such as approvals, authorizations,
                     verifications, reconciliations, performance reviews,

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                      Internal Control Standards

                      maintenance of security, and the creation and
                      maintenance of related records which provide
                      evidence of execution of these activities as well as
                      appropriate documentation. Control activities may be
                      applied in a computerized information system
                      environment or through manual processes.

                      Activities may be classified by specific control
                      objectives, such as ensuring completeness and
                      accuracy of information processing.

Examples of Control
                           • Top level reviews of actual performance,
                           • Reviews by management at the functional or
                              activity level,
                           • Management of human capital,
                           • Controls over information processing,
                           • Physical control over vulnerable assets,
                           • Establishment and review of performance
                             measures and indicators,
                           • Segregation of duties,
                           • Proper execution of transactions and events,
                           • Accurate and timely recording of transactions
                             and events,
                           • Access restrictions to and accountability for
                             resources and records, and
                           • Appropriate documentation of transactions and
                             internal control.

                      There are certain categories of control activities that
                      are common to all agencies. Examples include the

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                         Internal Control Standards

Top Level Reviews of     Management should track major agency achievements
Actual Performance       and compare these to the plans, goals, and objectives
                         established under the Government Performance and
                         Results Act.

Reviews by Management    Managers also need to compare actual performance
at the Functional or     to planned or expected results throughout the
Activity Level           organization and analyze significant differences.

Management of Human      Effective management of an organization’s
Capital                  workforce—its human capital—is essential to
                         achieving results and an important part of internal
                         control. Management should view human capital as
                         an asset rather than a cost. Only when the right
                         personnel for the job are on board and are provided
                         the right training, tools, structure, incentives, and
                         responsibilities is operational success possible.
                         Management should ensure that skill needs are
                         continually assessed and that the organization is able
                         to obtain a workforce that has the required skills that
                         match those necessary to achieve organizational
                         goals. Training should be aimed at developing and
                         retaining employee skill levels to meet changing
                         organizational needs. Qualified and continuous
                         supervision should be provided to ensure that internal
                         control objectives are achieved. Performance
                         evaluation and feedback, supplemented by an
                         effective reward system, should be designed to help
                         employees understand the connection between their
                         performance and the organization’s success. As a part
                         of its human capital planning, management should
                         also consider how best to retain valuable employees,
                         plan for their eventual succession, and ensure
                         continuity of needed skills and abilities.

Controls Over            A variety of control activities are used in information
Information Processing   processing. Examples include edit checks of data
                         entered, accounting for transactions in numerical
                         sequences, comparing file totals with control

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                          Internal Control Standards

                          accounts, and controlling access to data, files, and
                          programs. Further guidance on control activities for
                          information processing is provided below under
                          “Control Activities Specific for Information Systems.”

Physical Control Over     An agency must establish physical control to secure
Vulnerable Assets         and safeguard vulnerable assets. Examples include
                          security for and limited access to assets such as cash,
                          securities, inventories, and equipment which might be
                          vulnerable to risk of loss or unauthorized use. Such
                          assets should be periodically counted and compared
                          to control records.

Establishment and         Activities need to be established to monitor
Review of Performance     performance measures and indicators. These controls
Measures and Indicators   could call for comparisons and assessments relating
                          different sets of data to one another so that analyses
                          of the relationships can be made and appropriate
                          actions taken. Controls should also be aimed at
                          validating the propriety and integrity of both
                          organizational and individual performance measures
                          and indicators.

Segregation of Duties     Key duties and responsibilities need to be divided or
                          segregated among different people to reduce the risk
                          of error or fraud. This should include separating the
                          responsibilities for authorizing transactions,
                          processing and recording them, reviewing the
                          transactions, and handling any related assets. No one
                          individual should control all key aspects of a
                          transaction or event.

Proper Execution of       Transactions and other significant events should be
Transactions and Events   authorized and executed only by persons acting
                          within the scope of their authority. This is the
                          principal means of assuring that only valid
                          transactions to exchange, transfer, use, or commit
                          resources and other events are initiated or entered

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                          Internal Control Standards

                          into. Authorizations should be clearly communicated
                          to managers and employees.

Accurate and Timely       Transactions should be promptly recorded to
Recording of              maintain their relevance and value to management in
Transactions and Events   controlling operations and making decisions. This
                          applies to the entire process or life cycle of a
                          transaction or event from the initiation and
                          authorization through its final classification in
                          summary records. In addition, control activities help
                          to ensure that all transactions are completely and
                          accurately recorded.

Access Restrictions to    Access to resources and records should be limited to
and Accountability for    authorized individuals, and accountability for their
Resources and Records     custody and use should be assigned and maintained.
                          Periodic comparison of resources with the recorded
                          accountability should be made to help reduce the risk
                          of errors, fraud, misuse, or unauthorized alteration.

Appropriate               Internal control and all transactions and other
Documentation of          significant events need to be clearly documented, and
Transactions and          the documentation should be readily available for
Internal Control          examination. The documentation should appear in
                          management directives, administrative policies, or
                          operating manuals and may be in paper or electronic
                          form. All documentation and records should be
                          properly managed and maintained.

                          These examples are meant only to illustrate the range
                          and variety of control activities that may be useful to
                          agency managers. They are not all-inclusive and may
                          not include particular control activities that an agency
                          may need.

                          Furthermore, an agency’s internal control should be
                          flexible to allow agencies to tailor control activities to
                          fit their special needs. The specific control activities
                          used by a given agency may be different from those

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                          Internal Control Standards

                          used by others due to a number of factors. These
                          could include specific threats they face and risks they
                          incur; differences in objectives; managerial judgment;
                          size and complexity of the organization; operational
                          environment; sensitivity and value of data; and
                          requirements for system reliability, availability, and

Control Activities
Specific for
Information Systems              • General Control
                                 • Application Control

                          There are two broad groupings of information
                          systems control - general control and application
                          control. General control applies to all information
                          systems—mainframe, minicomputer, network, and
                          end-user environments. Application control is
                          designed to cover the processing of data within the
                          application software.

General Control           This category includes entitywide security program
                          planning, management, control over data center
                          operations, system software acquisition and
                          maintenance, access security, and application system
                          development and maintenance. More specifically:

                      •   Data center and client-server operations controls
                          include backup and recovery procedures, and
                          contingency and disaster planning. In addition, data
                          center operations controls also include job set-up and
                          scheduling procedures and controls over operator

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                          Internal Control Standards

                      •   System software control includes control over the
                          acquisition, implementation, and maintenance of all
                          system software including the operating system,
                          data-based management systems,
                          telecommunications, security software, and utility
                      •   Access security control protects the systems and
                          network from inappropriate access and unauthorized
                          use by hackers and other trespassers or inappropriate
                          use by agency personnel. Specific control activities
                          include frequent changes of dial-up numbers; use of
                          dial-back access; restrictions on users to allow access
                          only to system functions that they need; software and
                          hardware “firewalls” to restrict access to assets,
                          computers, and networks by external persons; and
                          frequent changes of passwords and deactivation of
                          former employees’ passwords.
                      •   Application system development and maintenance
                          control provides the structure for safely developing
                          new systems and modifying existing systems.
                          Included are documentation requirements;
                          authorizations for undertaking projects; and reviews,
                          testing, and approvals of development and
                          modification activities before placing systems into
                          operation. An alternative to in-house development is
                          the procurement of commercial software, but control
                          is necessary to ensure that selected software meets
                          the user’s needs, and that it is properly placed into

Application Control       This category of control is designed to help ensure
                          completeness, accuracy, authorization, and validity of
                          all transactions during application processing.
                          Control should be installed at an application’s
                          interfaces with other systems to ensure that all inputs
                          are received and are valid and outputs are correct and
                          properly distributed. An example is computerized edit
                          checks built into the system to review the format,
                          existence, and reasonableness of data.

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                  Internal Control Standards

                  General and application control over computer
                  systems are interrelated. General control supports the
                  functioning of application control, and both are
                  needed to ensure complete and accurate information
                  processing. If the general control is inadequate, the
                  application control is unlikely to function properly
                  and could be overridden.

                  Because information technology changes rapidly,
                  controls must evolve to remain effective. Changes in
                  technology and its application to electronic
                  commerce and expanding Internet applications will
                  change the specific control activities that may be
                  employed and how they are implemented, but the
                  basic requirements of control will not have changed.
                  As more powerful computers place more
                  responsibility for data processing in the hands of the
                  end users, the needed controls should be identified
                  and implemented.

Information and
                      Information should be recorded and communicated
                      to management and others within the entity who
                      need it and in a form and within a time frame that
                      enables them to carry out their internal control and
                      other responsibilities.

                  For an entity to run and control its operations, it must
                  have relevant, reliable, and timely communications
                  relating to internal as well as external events.
                  Information is needed throughout the agency to
                  achieve all of its objectives.

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Internal Control Standards

Program managers need both operational and
financial data to determine whether they are meeting
their agencies’ strategic and annual performance
plans and meeting their goals for accountability for
effective and efficient use of resources. For example,
operating information is required for development of
financial reports. This covers a broad range of data
from purchases, subsidies, and other transactions to
data on fixed assets, inventories, and receivables.
Operating information is also needed to determine
whether the agency is achieving its compliance
requirements under various laws and regulations.
Financial information is needed for both external and
internal uses. It is required to develop financial
statements for periodic external reporting, and, on a
day-to-day basis, to make operating decisions,
montinor performance, and allocate resources.
Pertinent information should be identified, captured,
and distributed in a form and time frame that permits
people to perform their duties efficiently.

Effective communications should occur in a broad
sense with information flowing down, across, and up
the organization. In additional to internal
communications, management should ensure there
are adequate means of communicating with, and
obtaining information from, external stakeholders
that may have a significant impact on the agency
achieving its goals. Moreover, effective information
technology management is critical to achieving useful,
reliable, and continuous recording and
communication of information.

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             Internal Control Standards

               Internal control monitoring should assess the quality
               of performance over time and ensure that the findings
               of audits and other reviews are promptly resolved.

             Internal control should generally be designed to
             assure that ongoing monitoring occurs in the course
             of normal operations. It is performed continually and
             is ingrained in the agency’s operations. It includes
             regular management and supervisory activities,
             comparisons, reconciliations, and other actions
             people take in performing their duties.

             Separate evaluations of control can also be useful by
             focusing directly on the controls’ effectiveness at a
             specific time. The scope and frequency of separate
             evaluations should depend primarily on the
             assessment of risks and the effectiveness of ongoing
             monitoring procedures. Separate evaluations may
             take the form of self-assessments as well as review of
             control design and direct testing of internal control.
             Separate evaluations also may be performed by the
             agency Inspector General or an external auditor.
             Deficiencies found during ongoing monitoring or
             through separate evaluations should be
             communicated to the individual responsible for the
             function and also to at least one level of management
             above that individual. Serious matters should be
             reported to top management.

             Monitoring of internal control should include policies
             and procedures for ensuring that the findings of
             audits and other reviews are promptly resolved.
             Managers are to (1) promptly evaluate findings from

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Internal Control Standards

audits and other reviews, including those showing
deficiencies and recommendations reported by
auditors and others who evaluate agencies’
operations, (2) determine proper actions in response
to findings and recommendations from audits and
reviews, and (3) complete, within established time
frames, all actions that correct or otherwise resolve
the matters brought to management’s attention. The
resolution process begins when audit or other review
results are reported to management, and is completed
only after action has been taken that (1) corrects
identified deficiencies, (2) produces improvements, or
(3) demonstrates the findings and recommendations
do not warrant management action.

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