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Other Matters: The Internal Control Plan of the Massachusetts Sheriffs’ Association Did Not Include All Required Components and Did Not Address the 2019 Coronavirus Pandemic.

The lack of a compliant and updated ICP impedes MSA from identifying vulnerabilities that could prevent it from achieving organizational goals and objectives and exposes it to heightened risks in its operations.
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Overview

The internal control plan (ICP) of the Massachusetts Sheriffs’ Association (MSA) did not include all the components required by the Office of the Comptroller of the Commonwealth’s (CTR’s) Internal Control Guide and had not been updated to address the 2019 coronavirus (COVID-19) pandemic. In our review of MSA’s ICP, we identified the following issues:

  • MSA’s ICP does not consider or adequately identify all eight components of the enterprise risk management (ERM) framework described in CTR’s Internal Control Guide. The Office of the State Auditor (OSA) compared MSA’s ICP to CTR’s Internal Control Guide and determined that seven of the eight ERM components—objective setting, event identification, risk assessment, risk response, control activities, information and communication, and monitoring—were not included in MSA’s ICP.
  • MSA has not reviewed or updated its ICP since 2016. CTR’s Internal Control Guide states, “The ICP must be reviewed and updated annually.”
  • MSA’s ICP does not describe the method that its personnel should use to report internal control issues and/or policy violations.
  • MSA’s ICP does not include control activities and does not document procedures for collecting required reports from sheriffs’ offices based on MSA’s budgetary language.
  • MSA’s ICP does not address the COVID-19 pandemic as required by CTR’s September 30, 2020 document “COVID-19 Pandemic Response Internal Controls Guidance.”

The lack of a compliant and updated ICP impedes MSA from identifying vulnerabilities that could prevent it from achieving organizational goals and objectives and exposes it to heightened risks in its operations.

In OSA’s opinion, MSA should review and update its ICP annually and whenever significant changes occur in objectives, risks, management structure, or program scope.

Auditee’s Response

Under the new MSA Executive Director’s leadership, the MSA has a brand new and updated Internal Control Plan which incorporates the Auditor’s and Comptroller’s recommendations.

Date published: June 28, 2022

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