Second Quarter 2006 • Vol. 10 • No. 2
CSA SentinelCSA Sentinel – CSA Center membership required for access. Welcome to CSA Sentinel, The IIA's quarterly publication for control-self assessment (CSA) professionals. A benefit of membership in The IIA’s CSA Center, this newsletter features articles on the latest thinking in CSA and risk, interviews, a question-and-answer profile section, practical "how-to" advice, research, and news with the latest development updates. If you would like to learn more about becoming a CSA member, click here. In This IssueThis issue's articles include: Control Self-assessment: Defeating the "Killer Bees to Group Dynamics" CSA 101: Basics for the Newcomer Q&A with Dave Harmon According to Mike Center News Quick Tips: Evaluating Soft Controls Calendar All contents of this Web site, except where expressly stated, are the copyrighted property of the Institute of Internal Auditors Inc. Control Self-assessment: Defeating the "Killer Bees to Group Dynamics"Learn how to conduct a productive and successful control self-assessment by avoiding and defeating five common issues — the "Killer Bees to Group Dynamics" — that can ruin even the most well planned CSA workshop.PETER HUGHES, Ph.D., CIA, CPA, CITP
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Fundamentals of Facilitated WorkshopsUsed approximately in 30 percent of self-assessment efforts, facilitated workshops are a popular method for conducting CSA activities. Based on self-assessments, facilitated workshops include suggestions from management, the work team, and sometimes internal auditors. There are four basic CSA facilitated workshop formats:
While each workshop format helps identify control gaps and opportunities in the organization's control structure, organizations should perform an analysis of external threats — as well as internal strengths and weaknesses — to determine which format is most appropriate within the organization. Many CSA users combine one or more formats to meet their needs. |
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Any component of an organization can facilitate CSA activities, including the internal audit staff.
Three primary CSA approaches are facilitated workshops, questionnaires, and management-produced analysis. Organizations often combine more than one approach to accommodate their self-assessments.
Facilitated workshops are the most popular and effective — yet often the most time consuming — approach to CSA. Workshops allow gathering risk and control information from work teams that represent multiple levels of an organization. Optimally, a trained facilitator who can assist with conflict management and group dynamics, keeping the team focused on its objective, leads sessions. (See Fundamentals of Facilitated Workshops for more information.)
The questionnaire approach uses a survey instrument that offers opportunities to gather insightful responses. Questionnaires help determine the strength of the control environment, reinforce business and financial policies, and minimize internal audit resources, but typically do not produce the most reliable results due to misinterpretation of questions and no collaborative discussion amongst a group. Process owners use the survey results to assess their control structure.
A management-produced analysis does not use a facilitated workshop or questionnaire and produces an internal analysis of the business process. The CSA specialist — who may be an internal auditor — combines the results of the analysis with information gathered from other sources, such as key management personnel. By synthesizing this material, the CSA specialist develops an analysis that process owners can use in their self-assessment efforts.
For more information on CSA tools and techniques, newcomers may wish to check out Larry Hubbard's book Control Self-assessment: A Practical Guide, which is available from The IIA Bookstore. The IIA’s Professional Practices Pamphlet 98-2 provides additional CSA guidance. (PDF, 143 KB)
An organization should consider six major issues to implement CSA effectively:
Once these issues have been considered and addressed, an organization can move forward with the CSA process.
Because CSA is en effective method for gathering internal control information in today's environment, it can help internal auditors improve their work. As a result, auditors can help organizations protect stakeholder interests. Furthermore, CSA generates internal control information that may be useful for management and internal auditors when evaluating the adequacy of internal controls. This helps to improve the organization's control environment by raising employee awareness of internal controls, which ultimately results in a proven asset within the corporate structure.
Although your questions are somewhat insightful regarding organizational culture and window dressing, I must emphatically answer "no" and "no." The Committee of Sponsoring Organizations of the Treadway Commission's Enterprise Risk Management — Integrated Framework and the U.S. Sarbanes-Oxley Act of 2002 can, and should, play a major, successful role in both for-profit and nonprofit organizations.
Enterprise Risk Management (ERM) and Sarbanes-Oxley are different animals, neither of which I accept as the exclusive domain of for-profit organizations. ERM is a control model with universal application, regardless of an organization's type. I'm more than a little surprised when organizations still refer to adopting ERM — ERM isn't an orphan that requires adoption; it's the law of the land. ERM, in its basic form, has had its mandate for more than 10 years and, although ERM finally is getting some respect, it still isn't being implemented fully.
Sarbanes-Oxley, on the other hand, is legislation pertaining to publicly traded companies. Although the use of Sarbanes-Oxley in nonprofits is a legitimate question, the essence of Sarbanes-Oxley does have universal appeal: management accountability and sound financial management. Since when do these principles not apply to nonprofits? The United Nations and its oil-for-food fraud is a perfect example. Nonprofits may have the right to ignore Sarbanes-Oxley, but that doesn't mean they should. Potter Stewart, former U.S. Supreme Court justice, said it best: "There's a big difference between what you have a right to do and what is right to do."
In fact, many nonprofits have embraced relevant portions of Sarbanes-Oxley as best practices. The requirements for auditor independence (i.e., the structure of audit committees and relationships with external auditors) make good sense and are inexpensive to satisfy. Similarly, selected parts of corporate responsibility requirements are relevant, such as establishing a code of conduct and using management certifications. Personally, I would not want to put myself in a position where I had to justify why these steps weren't implemented. Full compliance with the documentation and assessment of internal controls may not be applicable, but neither is the situation where there is no formal documentation of internal controls.
Possibly not. However, ERM and Sarbanes-Oxley don't fit the cultures of for-profit organizations either. All practitioners acknowledge that adapting ERM to an organization's existing culture is a key to success. I believe the ultimate goal of ERM is to change an organization's culture. Everything else logically flows from that. If organizations had the right culture, it wouldn't be necessary to spend all this time on internal control models. The very fact that ERM does not fit the culture of nonprofits makes the case for its implementation.
Regarding Sarbanes-Oxley, I agree that it doesn't fit the nonprofits' culture. It is a mandate for public companies and was never intended to fit with any culture; it was intended for compliance. Achieving Sarbanes-Oxley compliance will change an organization's culture for the better.
To this question, I counter by asking whether it is unrealistic for nonprofits not to adopt these practices. By now, you should have a pretty clear sense of my position that nonprofits need good internal controls the same way for-profits do. In fact, the argument could be made that the need is greater. For-profits have the built-in discipline of the marketplace competition to answer to, which helps to "weed out" the worst of the worst for-profit companies, while nonprofits rely on the good stewardship of management. Without a discipline like ERM and relevant portions of Sarbanes-Oxley, stewardship — when it does exist — may tend to lose its effectiveness over time. Organizations like the United Nations, which are created with the noblest of intentions, but have a unique monopoly, are a perfect example. Over time, the concept of good stewardship takes a back seat to bureaucracy and employee entitlements.
Although implementations of ERM and Sarbanes-Oxley can be window dressing, they shouldn't be. I think with any new change process, there are elements of both form (i.e., window dressing) and substance (i.e., effective change). Early on, substance frequently takes a back seat to form. But, ultimately, if the process has integrity (i.e., the proper sponsorship), substance overcomes form as the prevailing effect.
One easy way to avoid the frustration of a transforming change is to believe the process doesn't apply to you or that the proposed change lacks substance. What tends to get overlooked is the cost of not changing. The assumption that continuing to proceed in an aimless manner, alleging that what has worked in the past will continue to work in the future, only delays — but does not avoid — the consequences.
It's been more than a decade since I was first introduced to CSA at Westcoast Energy. At that time, CSA was a process-based program where the audit group would lead departments through a self-evaluation of their risks and controls, economy, efficiency, effectiveness, and the ability to meet stated goals and objectives. One of the key components of the program — the use of storyboards to document the process — actually was pioneered by Westcoast Energy.
CSA was such a great success with the departments that volunteered to be our test subjects that when we officially offered it as an audit approach, we found many willing participants. I have conducted many types of self-assessment reviews over the years — objective, controls, and risk — and although I may be biased by saying all were successful, it was the continous, positive testaments from unbiased clients that proved self-assessment was an important tool for any audit group. I remember one company where The Committee of Sponsoring Organizations of the Treadway Commission/Criteria of Control CSA approach was fully supported by the chief executive officer. This approach was used to help the company and its personnel examine the organization and determine what was needed to transform it from a money-losing operation into an industry leader. CSA was credited as one of the key success factors responsible for transforming this organization into one of the most profitable companies in its industry.
In the beginning, many of us faced distractions and hurdles while trying to implement self-assessment. Some management and even internal audit leaders believed that internal audit should only do financial and compliance auditing; therefore, self-assessment was refused. Others gave permission to implement self-assessment for the opposite reason — they saw CSA as a way of doing more audits in less time and with fewer resources. But we discovered that CSA was only one of many audit approaches. Some of us had senior management's support, but soon discovered that other departments were working against us because they were afraid of what we would undercover. I can even remember external auditors laughing at the idea of self-assessments being conduct by internal auditors, let alone company management.
CSA professionals always will face challenges in trying to implement some sort of self-assessment program. But will the premise of self-assessment ever die? Absolutely not! It has been around for close to a century in the form of your annual tax return. And every time you travel between countries and complete a customs declaration, you self-access. Even today, we have legislation that requires management to self-assess the internal controls over financial reporting. And the latest and greatest sound business practice — enterprise risk management (ERM) — is rooted in the need to have the entire organization self-assess the potential risk it faces each year to maximize business objectives and opportunities.
Whether you are a practitioner of internal or external audit, financial reporting, risk management, regulatory compliance, or human resources, you're administering at least one self-assessment review or audit in one form or another. CSA is a fact of life and a fact of business that always will be present. So let's strive to work with one another to share experiences and processes so that we can realize the full potential of self-assessment programs.
This will be my last column for CSA Sentinel. During the last 10 years, I've seen and done a lot with CSA, or as I like to call it, just plain old self-assessment. I know many of you do not agree with all of my opinions, but I can say that I've learned a lot by listening with an open mind. To all of you out there who have read my column, thank you for at least giving me an ear — whether you agreed or disagreed. My last opinion for you is this: no matter what others say, no matter what others are doing, and no matter how much you paid the consultant — in the end, you choose the self-assessment approach that best meets the needs of your organization. Remember, in self-assessment, there is no wrong or right way — only the best way.
Finally, I would like to thank all of my editors, past and present, for all their help and encouragement. It is through their dedication and support that this rough piece of rock could be polished up and turned into diamond.
Mark your calendar for The IIA's 2006 Risk and Control Conference, Aug. 21–23, in Palm Beach, Fla. Risk and control is big business — improving your ability to add value and help improve your organization's risk management and control processes is what this conference is all about.
Participants can take advantage of numerous networking opportunities to share ideas, best practices, and discuss the current challenges facing your organizations. Don't miss this excellent opportunity to focus on the issues that are important to your organization, while making sense of different frameworks, regulations, and best practices of interest to internal auditors and other business professionals.
To obtain additional information and to register, visit The IIA Web site,
www.theiia.org/training/conf/index.cfm?e_code=RISK0806, or contact customer service at +1-407-937-1111.
The Certified Internal Auditor® (CIA) designation is the only globally accepted certification for internal auditors and remains the standard by which individuals demonstrate their competency and professionalism in the internal audit field. Candidates leave the program enriched with educational experience, information, and business tools that can be applied immediately in any organization or business environment.
Upcoming exam dates are:
For additional information and to register, visit The IIA Web site, www.theiia.org/?doc_id=43, or contact customer service at +1-407-937-1111.
The Certification in Control Self-Assessment® (CCSA) is a specialty certification program designed for control self-assessment (CSA) practitioners. Business professionals of all CSA experience levels can benefit from this comprehensive program. Gaining the required knowledge in areas such as risk and control models — often considered the realm of auditors only — exposes CSA practitioners to vital CSA concepts that can help clients achieve their objectives.
Upcoming exam dates will be held on:
If you wish to learn more or to register, visit The IIA Web site, www.theiia.org/?doc_id=36, or contact customer service at +1-407-937-1111.
Most soft controls can only be self-assessed because they impact attitudes, and attitudes — unlike policies, procedures, and reconciliations — are unique to each person. In The Committee of Sponsoring Organizations of the Treadway Commission's frameworks, soft controls fall under the "internal environment" component and must be evaluated before all the other control components. That way, the impact of soft controls — or the environment — on people can be considered in designing or evaluating other controls.
In evaluating soft controls, managers can tell you the "design" of soft controls, but it is the actual workers who can tell you the "operation" of soft controls. Answering the following questions can help you evaluate your organization's soft controls:
Enterprise Risk Management: What's New? What's Next?
May 22–24; Lake Buena Vista (Orlando), Fla.
Evaluating Internal Controls: A COSO-based Approach
May 22–24; Lake Buena Vista (Orlando), Fla.
Adding Value Using Risk-based Auditing
June 12–14; New York, N.Y.
Corporate Governance: Strategies for Internal Audit
June 14–16; New York, N.Y.
Enterprise Risk Management: Process Improvement Workshop
June 15–16; New York, N.Y.
Enterprise Risk Management: What's New? What's Next?
June 12–14; New York, N.Y.
Evaluating Internal Controls: A COSO-based Approach
June 12–14; New York, N.Y.
Value-added Business Controls: The Right Way to Manage Risk
June 14–16; New York, N.Y.
Enterprise Risk Management: What's New? What's Next?
July 10–12; Vancouver, British Columbia
July 24–26; Boston, Mass.
Evaluating Internal Controls: A COSO-based Approach
July 10–12; Vancouver, British Columbia
Facilitating Results Using CSA
July 26–28; Boston, Mass.
Introduction to Control Self-assessment
July 24–26; Boston, Mass.
Adding Value Using Risk-based Auditing
August 28–30; Palm Beach, Fla.
Corporate Governance: Strategies for Internal Audit
August 7–9; Las Vegas, Nev.
August 28–30; Palm Beach, Fla.
Enterprise Risk Management: What's New? What's Next?
August 28–30; Palm Beach, Fla.
Evaluating Internal Controls: A COSO-based Approach
August 7–9; Las Vegas, Nev.
The IIA's Risk and Control Conference
August 21–23; Palm Beach, Fla.
Value-added Business Controls: The Right Way to Manage Risk
August 9–11; Las Vegas, Nev.
August 28–30; Palm Beach, Fla.
To add your CSA course, seminar, conference, or event to the calendar, please forward all pertinent information to Editor Allison Cain via e-mail allison.cain@theiia.org, or by fax, +1-407-830-4832.