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Volume 1, Issue 1October 2007

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NBC Efforts to Build and Sustain
an Internal Control and Compliance Program

OMB’s Circular A-123 OMB Circular A-123, issued on December, 21 2004 defines the management responsibilities for internal financial controls in Federal agencies. - Click on the image to access the A-123 Circular on the OMB Website.
OMB’s Circular A-123, issued on December, 21 2004 defines the management responsibilities for internal financial controls in Federal agencies.

The National Business Center (NBC) has successfully built and is sustaining a robust Internal Control and Compliance Program (CCP) in response to OMB’s Circular A-123 and client requirements.

In FY 2005, the Office of Management and Budget (OMB) issued new guidance under a revision to OMB Circular A-123 for enhancing both “financial” and “program” controls and financial reporting effective for the FY 2006 financial statement. OMB’s enhancements included changes for financial reporting as well as additional requirements for assuring program internal controls.

To satisfy the requirements for enhanced financial reporting controls the NBC documented the business processes of 19 critical financial activities, documented work flows, identified key controls, created test plans and conducted financial transaction testing. The NBC created an organization within the Accounting Operations Division (AOD), to be responsible for performing the financial transaction level testing for all customers.

To satisfy the requirements for enhanced financial reporting controls the NBC documented the business processes of 19 critical financial activities, documented work flows, identified key controls, created test plans and conducted financial transaction testing.

These financial testing activities supplement the evaluation of system controls as performed by the NBC through the annual FISMA and SAS 70 Type II review processes. The major applications reviewed each year include: (1) Federal Financial System (FFS), (2) Federal Personnel Payroll System (FPPS), (3) Hyperion Consolidated Financial Statements (CFS), (4) Oracle Federal Financials, and (5) Momentum Financials. The NBC uses the results of its financial transactions testing and internal system and SAS 70 reviews to provide assertions to customers regarding the status of controls over financial reporting as of June 30th of each year.

To satisfy the requirements for enhanced “program” controls, the NBC created a component and assessable unit inventory of 134 units. Assessable units are NBC programs or major processes which can be reviewed in an efficient, reasonable, and logical manner. The NBC also developed a risk assessment tool, conducted risk assessment, developed a multi-year review plan and has begun to document the business processes and conduct management reviews. The results of these reviews will form the basis of the NBC’s assertions to customers over program controls.

The NBC has implemented an internal control program that is commensurate with program risks, provides value to customers and management in comparison to compliance program costs.

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Last Updated on 10/05/07