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DCAMM’s Internal Control Plan Was Not Updated With a 2019 Coronavirus Pandemic Component.

Without this update, DCAMM’s ability to achieve its mission and objectives effectively and efficiently may be hindered.
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Overview

DCAMM’s internal control plan (ICP) was not updated with a 2019 coronavirus (COVID-19) pandemic component as required by CTR’s “COVID-19 Pandemic Response Internal Controls Guidance,” issued September 30, 2020.

The absence of an up-to-date, comprehensive ICP may hinder DCAMM’s ability to achieve its mission and objectives effectively and efficiently.

Authoritative Guidance

CTR’s “COVID-19 Pandemic Response Internal Controls Guidance,” dated September 30, 2020, states,

Department internal control plans must be based on risk assessments and updated annually, or when significant changes occur. Because the COVID-19 Pandemic has affected all departments, the Comptroller, in consultation with the State Auditor’s Office, is providing two options for updating internal controls.

  1. If the impact to your department is such that it can be reflected in your Internal Control Plan (ICP), then update the ICP as you would for any other mid-year changes.
  2. Departments experiencing a significant impact, and requiring the accumulation of substantial documentation (e.g. changes to business processes, requirements of federal and state specific laws or guidance, new funds or new programs), can draft a separate COVID-19 Pandemic Response Plan Appendix to the ICP as an organized set (hard or soft copies) of emails, documents, risk assessments, policies and procedures.

Reasons for Noncompliance

DCAMM did not have policies and procedures in place, including a monitoring component, to ensure that its ICP is updated when significant changes occur.

Recommendation

DCAMM should establish policies and procedures, including a monitoring component, for updating its ICP when significant changes occur.

Auditee’s Response

After notification by, and in consultation with, the [Office of the State Auditor]; DCAMM updated its Internal Control Plan in March, 2021 to reflect CTR’s “COVID-19 Pandemic Response Internal Controls Guidance,” issued September 30, 2020. Prior to the March, 2021 update, the DCAMM Internal Control Plan had previously been updated in June of 2020.

DCAMM is implementing the recommendation of the [Office of the State Auditor] by creating a policy and procedure for updates in response to significant unforeseen changes (such as the coronavirus pandemic), in addition to periodic reviews and updates. The procedure will be led by the DCAMM Deputy Commissioner of Finance, supported by the DCAMM Chief Financial Officer. The Deputy Commissioner and Chief Financial Officer shall each collect guidance, notifications, comments or any other change in conditions/situation which either mandate or may justify an immediate update to the Internal Control Plan. In such event, the Deputy Commissioner and Chief Financial Officer shall immediately confer and prepare a recommended update for submission to the DCAMM Commissioner.

The foregoing policy and procedure will be incorporated into the DCAMM Internal Control Plan.

Auditor’s Reply

Based on its response, DCAMM is taking measures to address our concerns on this matter.

Date published: February 23, 2022

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