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The Internal Control Staff serves FSIS by providing independent and objective analysis of FSIS management
controls and processes in order to help prevent waste, fraud, abuse and mismanagement.
About Internal Control Staff
Key Program Activities
Related Web Sites
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Introduction
The Internal Control Staff serves the Agency by conducting independent, objective and critical reviews and
analyses of the Food Safety and Inspection Service (FSIS) programs in order to help prevent waste, fraud,
abuse and mismanagement. ICS's tasks include conducting assessments, performance measurements, audits,
investigations, program and data analysis, interagency coordination, audit liaison duties and special studies
to assure the presence, integrity and effectiveness of management and internal controls.
The ICS is part of the Office of Program Evaluation, Enforcement and Review (OPEER). The ICS was established
after the Fiscal Year 1996 reorganization within FSIS. The ICS's primary functions are:
- Assuring the integrity and effectiveness of management controls within the Agency, including policy
formulation and the development of management control procedures.
- Conducting assessments or audits of specific program entities or activities in response to actual
or perceived breakdowns in program and employee effectiveness.
- Conducting personnel misconduct investigations.
- Serving as the liaison for the U.S. General Accounting Office (GAO) and USDA Office of Inspector
General (OIG) audit activities by audit organizations.
- Maintaining a comprehensive database for OIG hotline/whistleblower complaints, GAO/OIG audits and
other "indicators" of potential problems.
- Serving as the Agency's liaison for handling OIG hotline and whistleblower complaints. Monitoring
and tracking approximately 175 complaints each year.
- Verifying and validating the Agency's Government Performance and Results Act (GPRA) measurements
and results.
- Coordinating Agency's self-assessments, as needed.
- Performing special analyses and reviews, including developing issue papers to support Agency
management's decisions.
- Researching and organizing information requested under the Freedom of Information Act (FOIA).
- Evaluating and assessing the management control implications of proposed Agency directives and notices.
Background
The ICS serves as the agency quality and program assurance agent by conducting independent, objective and
critical reviews and analyses to meet FSIS public health objectives and help prevent waste, fraud, abuse and
mismanagement. ICS works to ensure management is accountable and responsible for the quality and timeliness of
program performance - increasing productivity, controlling cost, mitigating adverse aspects of agency operations,
and assuring that programs are managed with integrity and in compliance with law. ICS conducts performance
measurements, public health program assessments, investigations, program and data analyses, interagency
coordination, and audit liaison activities to assure the presence, quality, integrity and effectiveness of
agency management and internal controls.
The ICS functions involve oversight, determinations affecting public policy, public health and welfare, and
assurances of the adequacy of systems and processes to prevent waste, fraud, abuse, and mismanagement. ICS is
comprised of a multidisciplinary group of technical, investigative and scientific specialists with a wide-range
of expertise to effectively evaluate FSIS programs and operations.
Mission and Function Statements
The responsibility of the Internal Control Staff (ICS) is to assist FSIS management in carrying out their
management control responsibilities; to independently and objectively assess the effectiveness of the agency's
programs; and to maintain an effective liaison with General Accounting Office (GAO), Office of Inspector General
(OIG) and other oversight organizations. The ICS works to alert Agency officials of potential or harmful
compromise or failure of FSIS programs.
Internal controls are an integral part of any organization's basic management processes and are mandated by
the United States Department of Agriculture. They ensure that organizational missions are being met through
effective and efficient means. They protect the organization's resources and assets from fraud, waste, abuse
and mismanagement.
Vision Statement
The Internal Control Staff (ICS) vision is to serve in a technically, scientifically, programmatically competent
and proactive manner in keeping the Food Safety and Inspection Service (FSIS) Administrator, Under Secretary for
Food Safety, and the Secretary of USDA informed on sensitive management control issues, especially those related
to food safety and public health. To achieve this vision, the ICS focus is on improving program performance
through compliance and program assessments. The ICS combines this vision statement and its goals of being
customer-oriented, performance-driven, and results oriented in accomplishing its mission to assure improved
program performance leading to improvement in public health through food safety.
A thorough understanding of FSIS programs and how they are implemented is vital to ICS effectiveness. To be
credible, ICS must have a working knowledge of each program and be able to incorporate that knowledge into
customer and stakeholder discussions and work products. Further, ICS believes that the value-added assistance
improves the understanding and quality of management controls, leading to improved food safety and food security
programs within FSIS. This allows more effectual liaison with internal and external customers and helps identify
opportunities for effecting program improvements through program analysis and corresponding follow-up.
Key Internal Control Staff Skills
The ICS has two functional teams with specialized skills and expertise in many areas - the Audits and
Investigations Team and the Performance Measurement and Analysis Team. The expertise within these two teams
is shown in the figure below. Provided are some of the skills within the ICS teams. Recently, ICS added expertise
in public health and public policy to strengthen the role of ICS public health program assurance functions.
Collaborative teamwork enables the ICS to serve the agency by providing a wide range of assurance functions.
Key Program Activities
External Audit Management
The Internal Control Staff (ICS) serves as the FSIS liaison and coordinator for external audit activities with
the General Accounting Office (GAO), the Office of Inspector General (OIG), and other outside groups. The
Assistant Administrator of the Office of Program Evaluation, Enforcement and Review (OPEER), serves as the
Agency's Audit Liaison Officer. GAO has the overall responsibility for reviewing the federal government's
accounting systems and assessing the actions taken in implementing the Federal Manager's Financial Integrity
Act of 1982 (FMFIA). The ICS ensures FSIS compliance with applicable laws, regulations, policies and procedures
relative to OIG, GAO, FMFIA, and Office of Management and Budget Circular A-123 activities. The ICS provides
direction and guidance to Agency offices on the development of responses to OIG and GAO reports. In addition,
the Staff assists in negotiations and resolution of disputed findings and recommendations, ensuring that
responses reflect the FSIS perspective.
The USDA's OIG is responsible for auditing and investigating the Department's operations and programs to
evaluate and assess their efficiency and effectiveness. GAO and OIG audits and surveys provide external
independent oversight to ensure that effective management controls are in place in all program, financial,
and administrative activities. In addition, the audits ensure that appropriate corrective action is taken to
resolve program weaknesses or deficient areas.
The ICS works with program officials in coordinating the audits and providing logistical support, ensures FSIS
corporate responses to the audit reports, and tracks audit findings and recommendations to ensure and facilitate
closure. In addition, the Staff prepares periodic status reports (sources of recommendations, number of
recommendations made, number concluded, etc.); and analyzes the programs intended and corrective actions in
relation to previously agreed-upon management commitments, feasibility and appropriateness.
The ICS works closely with the Office of the Chief Financial Officer (OCFO) to provide assurance of FSIS program
activities and performance measures. The ICS works with the OCFO to verify reported program performance and
evaluate that stated performance measures are measurable and reflective of food safety and public health goals.
In addition, the ICS, working with the OCFO, ensures that final action on audits is recorded and the audit is
closed out, thereby minimizing the possibility of an audit appearing in the Secretary's Report to Congress as
unresolved.
Management Controls
The Internal Control Staff (ICS) promotes managerial accountability, evaluates management controls, and helps
to protect program resources from waste, fraud, abuse, and mismanagement. Management controls are a system of
checks and balances designed to enhance accountability and promote good management practices. Department
Regulation 1110-2, "Management Accountability and Control", and FSIS Directive 1090.1, Revision 2, "Management
Control", define the responsibilities associated with management controls. The ICS has oversight responsibility
to ensure that checks and balances are in place. The Assistant Administrator, Office of Program Evaluation,
Enforcement and Review (OPEER) is the designated Management Control Officer for FSIS to coordinate the efforts
of each agency or mission area and to act as a liaison with the Office of the Chief Financial Officer (OCFO).
This responsibility has been delegated to the ICS.
The Agency is responsible for:
- Taking systematic and proactive actions to implement appropriate, cost-effective internal and management
controls for all processes which support the delivery of agency programs and operations,
- Ensuring that internal and management controls for processes supporting agency programs and operations
are commensurate with program risks, results-oriented management, and support the objectives outlined
in the above section,
- Ensuring that internal and management controls are an integral part of each organization's entire cycle
of planning, budgeting, program delivery or operations, accounting, and auditing processes,
- Ensuring that clear documentation for transactions, internal and management controls and other significant
events are readily available for examination,
- Assessing the risks and external factors which may impair program delivery and operations on an annual
basis or more frequently, if needed,
- Periodically assessing the adequacy of internal and management controls for programs and operations and
document results,
- Identify significant weaknesses in internal and management controls and develop corrective action plans
for material deficiencies,
- Disclosing material internal and management control weaknesses to the next level of management,
- Ensuring that the agency's strategic or annual performance plans address the correction of material
deficiencies identified or disclosed,
- Ensuring that FSIS policies and operations are based on a sound scientific foundation,
- Ensuring that all material deficiencies and significant deficiencies, which are not deemed material to
the Department, are corrected in a timely manner, and
- Ensuring that all managers and employees are aware of the importance of internal and management controls
as well as specific program risks, control objectives, and control measures.
To carry out these responsibilities, FSIS established an Executive Steering Committee for Management Controls
to provide policy direction and guidance for management controls, emphasizing management accountability and
pursuing a corporate approach to management control issues. ICS is responsible for coordinating the efforts and
activities of the Executive Steering Committee. The membership of the committee includes the ICS is responsible
for coordinating analyses and reports on FSIS management control activities. This includes providing operation
coordination of management controls and technical assistance throughout the agency, conducting management control
reviews to assess the effectiveness of the agency's management controls, monitoring corrective action for
weaknesses and reporting on the progress of completed corrective actions.
Management Control Liaisons
Each program area, and the Office of the Administrator, has identified a liaison for management controls. The
management control liaisons work with Internal Control Staff (ICS):
- In the development of FSIS' management control policy and procedures,
- To assist program managers in identifying and implementing management control processes,
- To assist in scheduling and planning management control reviews for the assessable units within their
sphere of influence,
- In communicating management control-related guidance and directions to the programs,
- To coordinate, compile and submit program reporting requirements,
- In educating and instructing employees on management control principles, and
- To provide information for the FMFIA year-end reporting to the Department.
Single Audit Act
All non-federal entities that expen $300,000 or more of federal awards in a year are required to obtain an
annual audit. The single audit is intended to meet the basic audit needs of both the non-federal entity and
federal awarding agencies.
For additional information on the Single Audit Act go to the OMB Circulars Web page at
https://webarchive.library.unt.edu/eot2008/20080917000041/http://www.whitehouse.gov/omb/circulars/index.html.
Federal Managers' Financial Integrity Act (FMFIA)
The FMFIA requires Departments to assess the adequacy of their management controls annually and to report
annually to the President and to the Congress on whether there is reasonable assurance that management controls
are achieving their intended objectives. Departments must also report on any material weaknesses. For USDA to
perform this duty, Agency Administrators must obtain information on agency operation, identify weaknesses, and
identify corrective actions to correct the weaknesses. The FMFIA establishes a review process of internal
accounting, administrative controls, and accounting systems. In addition, the FMFIA requires that all government
resources be protected from fraud, waste, and abuse.
For additional information on the Federal Manager's Financial Integrity Act, refer to the following:
Laws, Regulations, and Directives
There are several laws and guidance documents governing management responsibilities for management controls.
Listed below are several applicable laws, USDA Regulations, and Agency Directives that most directly relate to
management accountability and safeguarding against fraud, waste, mismanagement and unauthorized use of assets.
Frequently Asked Questions
Q. Why was this office selected to be audited?
A. If you are like many staff or division directors, you may not have requested an internal audit. The
ICS regularly performs an ongoing examination of the Agency's internal controls; and as part of this process,
will encourage certain assessable units to have an audit performed based on various indications and findings.
Regular management control reviews for many units are scheduled on a 3-year cycle. Units that choose conduct
their own internal self-assessments are subject to having their management control reviews verified by the ICS.
Q. Can directors request an audit?
A.Yes, an audit can produce many benefits, and timing can be an important factor. If you have recently
assumed new or additional supervisory responsibilities, an audit can be useful in providing a review of
administrative procedures to aid in determining whether internal controls in that unit are adequate. It is
also beneficial in providing an assessment of system controls, which could identify where office procedures
relying on computer applications should be modified.
A periodic "checkup" to review your unit's administrative activity can help ensure that your procedures continue
to comply with USDA regulations and FSIS directives. An audit is an opportunity to receive an independent
appraisal of the effectiveness and efficiency of your unit's administrative activities.
Any supervisor or manager within the FSIS can request an audit. Requests should be submitted to the ICS through
the appropriate Assistant Administrator or program area senior official.
What should I expect when an audit is scheduled for my unit?
A. The ICS will contact you to schedule a meeting to discuss the scope of the review and the logistics
of conducting the audit. At this initial meeting, you should take the opportunity to discuss any concerns or
questions you may have about the audit, and to determine how you can facilitate the review process. A typical
audit has several stages, including preliminary research, data collection and analysis, review, preparation and
distribution of a report, and follow-up.
Q. How long will the audit take?
A. Audits can last from several days to several months. The auditor will give you a reasonable estimate
of the time needed to complete the audit.
Q. How will the audit findings be reported?
A.You and your staff will be kept appraised of the auditor's findings throughout the course of the
audit. At the conclusion of the audit, you will be able to review a draft of the report before the final
version is issued. Except for special reports requested by the Administrator or an Assistant Administrator
all audit information is treated as confidential and reported only to those who need to know.
Final audit reports distribution vary depending on the requestor.
Special Projects
The Internal Control Staff (ICS), when requested, conducts special studies and analyses that provide FSIS
management and decision-makers information and answers in addressing key management issues. With skills in
the areas of statistics, risk assessment, financial management, public health, operations research, project
management, and information technology, the ICS is capable of conducting complex analysis that offer answers
to assist management in address cross-cutting Agency issues and improving the performance of its public health
programs.
In FY 2000, the ICS conducted an assessment of the Field Automation Information Management (FAIM) initiative.
This assessment utilized the Performance Excellence Criteria in the President's Quality Award program. The
assessment provided an objective evaluation of FAIM in the areas of Leadership, Strategic Planning, Customer
Focus, Information and Analysis, Human Resource Focus, Process Management, and Business Results.
In FY 2001, the ICS initiated a collaborative effort with the then Planning Staff, Office of Management, in
verifying and validating the Agency's performance results reported under the Government Performance Results
Act (GPRA). The ICS objectively verifies and validates the GPRA results through the research and acquisition
of independent facts and information that either corroborates or disproves the Agency's performance results.
Audits & Investigations
Audits
The Internal Control Staff (ICS) Audit Program is a proactive and comprehensive service that provides managers
with information to maintain and enhance their programs. The audits include a methodical examination, review and
verification of a specific program element, activity or event. The process is initiated by an ICS team conducting
preparatory actions aimed at collecting background and supporting documentation in the area to be reviewed. On
the day the audit begins, the ICS team meets with the program manager and appropriate personnel to reconfirm
the objectives of the audit. The team then does a thorough check and analysis of the program's activities. Upon
completing the audit, a written audit report is developed that addresses the findings and recommendations are
made for enhancing the program.
The President's Management Agenda includes an initiative to reduce Federal government erroneous payments for
agencies that enter into contracts in excess of $500 million (M) per fiscal year. Departments, such as USDA,
that meet this requirement must implement a recovery audit program for amounts potentially paid erroneously to
contractors. USDA will implement this requirement at the mission area/agency level. This requires FSIS, as a
part of USDA, to conduct audits for contracts that are deemed to have potential recovery cost savings benefits.
ICS has the function of conducting such audits for the Agency.
Investigations
ICS' mission is to conduct timely and objective administrative investigations concerning sensitive and complex
issues that may threaten the overall performance of the FSIS function. Requests for such investigations may come
from high-level Agency officials, other FSIS employees or the general public having information concerning
violations of the rules of conduct, abuse of authority, mismanagement or specific dangers to public health and
safety. In keeping with FSIS policy to protect employees from assaults, threats of assault, and other forms of
intimidation or interference relating to the performance of their official duties, ICS also investigates these
type complaints upon request. All information, complaints or allegations received within the Agency that reflects
adversely upon its integrity or the conduct of employees will receive a thorough, timely and impartial inquiry.
The USDA Office of Inspector General (OIG) has delegated to Agencies the authority to conduct personnel misconduct
investigations to determine if there is evidence of employee misconduct, waste, mismanagement or abuse. FSIS has
numerous employees who are credentialed investigators as a collateral duty to their official position. The
Department must certify agency employees before they are issued investigative credentials. Investigators assemble
sworn witness statements, documents, and other evidence into a formal investigative report. They do not make
decisions or offer recommendations on corrective or disciplinary actions.
OIG routinely receives complaints through telephone calls, mail, or in person. Each complaint is assigned an
OIG case number and is reviewed for possible OIG investigative or audit interest. If there is none, it is
forwarded to the appropriate Agency for action. These complaints are either provided for the Agency's information
with no requirement to report back to the OIG, or, as is more likely, they are forwarded for inquiry or
investigation. A report is returned to OIG with the findings and action may or may not be taken at that time.
ICS serves as the Agency's control point for all OIG hotline/whistleblower complaints received by FSIS. As the
FSIS liaison, ICS has the responsibility for ensuring that all complaints are assigned to the appropriate program
area for resolution, that all allegations are addressed, and that responses are forwarded to the OIG as required.
The Department will officially close the hotline complaint upon approval of the completed investigation or inquiry
by OIG.
ICS maintains a database tracking system to facilitate effective inquiry and reporting, prepares critical
analyses when high-risk areas are identified, and prepares periodic status reports to keep management abreast
of key issues.
Program Assessments & Reviews
ICS conducts program assessments on an entire program or a segment of a program and focuses on compliance,
efficiency, and effectiveness. Program assessments are intended to verify or increase the impact of products
or services on customers or clients, improve delivery mechanisms to be more efficient and less costly, and verify
if the program is really running as originally planned. The assessments facilitate management's thinking about
what their program is about, including its goals, how it meets its goals and how it will know if it has met its
goals or not. Program assessments can also produce valid comparisons between programs to decide which should be
retained and fully examine and describe effective programs for duplication elsewhere. A final report will
identify findings and a follow-up will be conducted on corrective actions.
The ICS has an oversight responsibility to help ensure that the Agency's programs and activities are conducted
in conformity with the goals and objectives for which they were established. This oversight responsibility extends
to verifying that these programs stay within the authority granted and for administering them in the most
effective, efficient, and economical manner possible. The ICS fulfills its responsibility by performing program
assessments and reviews which include an evaluation of the manner in which Agency management conducts its
responsibilities, how programs are conducted, the controls in place to prevent waste, fraud, abuse and
mismanagement, and to identify if more efficient and effective approaches should be recommended. To properly
administer a program, management must provide the organization, policy guidance, planning, supervision, and
controls necessary to properly plan the course and goals of the activity, and provide the controls to assure
that it stays on track and makes acceptable progress. Assessments and reviews are either self-initiated or
requested by program officials. Assessments or reviews requested by program officials are generally considered
"no fault" reviews.
The ICS has two functional teams with the capability to conduct various types of assessments. The types of
assessments include:
- Full Scope Assessments: An assessment of an entire operation to (1) ensure compliance, (2) evaluate
efficiency/effectiveness, or (3) measure results. Performed where time is not of the essence, and full
documentation is required of the results.
- Quick Response Assessments: Performed where the customer knows what the problem is and needs a quick
turnaround for suggestions for a fix. Our goal is to have an answer within 10 days.
- Advisory Services: To assist managers in the decision making process. Provide advice on new systems,
processes, internal controls, or interpretations of policies/regulations.
- Audit Compliance: Performance of follow-up reviews of external and internal audits to ensure that
agreed to recommendations have been implemented.
The Performance Measurement and Analysis Team is capable of conducting multifaceted reviews requiring financial,
statistical, information technology or analytical expertise. The Audits and Investigations Team is configured to
perform conventional reviews of Agency program areas and their operations. No matter what type of assessment is
required, the ICS generally follows a standard process in conducting it.
Requests for a program assessment may be initiated by any management official, and should begin with a
discussion with the ICS. Assessments usually involve on-site visits, which are often preceded by the gathering
of available and pertinent information in the Agency's possession. The expertise of the ICS may be augmented by
technical experts from other parts of the Agency to assist in the assessment. At the site, interviews are
conducted with Agency employees and supervisors, and non-FSIS employees when necessary. Records and interviews
may also be obtained at other sites, such as District Offices, to support the assessment. The results are
provided to management, and discussions are initiated with key Agency entities to develop actions to resolve
the immediate problems, and to preclude similar problems in the future
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Last Modified:
May 23, 2008 |
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