According to the U.S. Government Accountability Office (GAO) Standards for Internal Control in the Federal Government, a good management control environment requires that organizational structures clearly define key areas of authority and responsibility and establish appropriate lines of reporting.
Controls are also affected by delegations of authority and responsibility for operating activities, reporting relationships, and authorization protocols. Good human capital policies and practices are also critical factors, including a proper amount of supervision. However, GAO notes that factors outside the control or influence of management can affect the achievement of goals. For example, errors of judgment and acts of collusion to circumvent controls can affect objectives. Although management controls cannot provide absolute assurance that all objectives will be met, established controls provide a reasonable assurance of meeting objectives.
Furthermore, management controls should provide reasonable assurance of compliance with applicable laws and regulations. For example, USAID’s Automated Directives System (ADS) prescribes that USAID and U.S. Government policy prohibits U.S. officials from acting without proper authority in a way that leads a recipient or potential recipient acting in good faith to believe that USAID has changed the amount of an existing award or revised an existing award budget, program description, or any of the terms and conditions of the award (ADS 303.3.18). Such actions could rise to the level of an unauthorized commitment.
Develop and implement a periodic training program for staff that clearly defines the authority, responsibility, and accountability of agreement officers, technical representatives, and program staff, including their communications with implementers, to support an effective management control environment.
Source: AUDIT REPORT NO. G-391-11-002-P DECEMBER 10, 2010
The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations. Please see the disclaimer of this site before using recommendations.
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- Program Oversight - ADS 303 - ADS 202.3 - ADS 203.3
- File Documentation - Procurement Executive Bulletin (PEB 2005-06)
- Monitoring and Oversight Needs Improvement - ADS 596.3
- Review and Test Conflict-of-Interest Mitigating Processes - ADS 596 - Standards for Internal Controls in the Federal Government - USAID Contract and Information Bulletin 99-17
- Suspension and Debarment - FAR 9.4 - 22 CFR 208
- Potential Corruption Went Unreported - USAID’s Handbook on Fighting Corruption
- Contractor Lacked a Code of Business Ethics and Conduct - Federal Acquisition Regulation Clause 52.203–13
- Subcontractor Had a Conflict of Interest - FAR Subpart 9.5 Organizational and Consultant Conflicts of Interest - Contract Information Bulletin 99-17