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Internal Controls Policies and Procedures


Praise for Internal Controls Policies and Procedures

"With many years as a consultant to numerous companies big and small, Rose brings a wealth of experience and knowledge to bear on the topic of internal controls in Internal Controls Policies and Procedures. Instead of 'reinventing the wheel,' companies can use this useful how-to manual to quickly put an effective program of?internal controls in place. It will prove to be an invaluable guide to internal auditors at companies of all sizes."
—Mark Greenquist, President and CEO, Telcordia Technologies, Inc.

"I have implemented, used, corrected, reviewed, and enhanced internal controls systems for most of my career. Getting started and following a path, founded in the COSO framework, is oftentimes the most difficult step in the process. What do you have to do? Why do you have to do it? How do you do it, and most important, how do you document what you have done? The author has answered these questions in an easy-to-read format and provided many useful tools and checklists to facilitate the completion of the internal controls process review. An extremely useful tool."
—William H. Hogan, Executive Vice President and Chief Financial Officer, Multi Packaging Solutions, Inc.

"The methodology presented within this publication is complete with flowcharts and checklists, which serve as a desktop reference for all organizations. Internal controls are dynamic and must be periodically reviewed and updated. Internal auditors play an important role in the process, but internal controls are the responsibility of all employees within an organization. I highly recommend this book both to auditors and management as a best practices model for establishing and enhancing their organization's control framework."
—Jim Kaplan, President and CEO,, the global resource for auditors, and the recipient of the IIA's 2007 prestigious Bradford Cadmus Memorial Award

Rose Hightower, Accountant, MSc, has been the owner of IDEAL Consulting Solutions International, LLC, for ten years, consulting in implementing internal controls and policy and procedure programs for large companies. Bringing over twenty years of experience from IBM and serving as finance manager, her program contains practical lessons and simple solutions for any size company. She is known as "The Policy Guru" and offers advice and counsel to clients from her Web site,
How to Use this Manual.


Governance Journey.

A01 Big G to little g governance journey.

Appendix: Background for COSO, SOX, PCAOB.

A02 Risk Assessment.

A03 Oversight.

A04 Documentation.

Internal Control Program.

B01 Internal Control Program.

B02 Internal Control Process.

B02a Internal Control Policy and Procedure.

B02b Internal Control Program Charter.

B02c Internal Control Plan.

B03 Authorization and Approval Program.

B03a Delegation of Authority.

B03b Authorization – Delegation, SubDelegation of Authority.

B03c Responsibility, Authority, Support, Counsel, and Inform (RASCI).

B04 Information Technology Program.

B04a End–User Computing—Control of Spreadsheets Policy and Procedure.

B05 Account Reconciliation Program.

B05a Account Reconciliation.

B06 Quarterly Subcertifi cation Program.

B06a Quarterly Subcertifi cation.

B06b Quarterly Subcertifi cation – Matrix.

B06c Quarterly Financial Subcertifi cation Training For First-Time Subcertifiers.

Control Activity Program Testing Guides.

C01 Control Activity Program.

C01a Control Activities Template.

C01b Result of Control Activity Testing.

C01c Internal Control – Planning, Testing, and Remediation Worksheet.

C01d Reporting Scorecard.

C02 AP – Disbursements.

C02a AR – Allowance for Doubtful Accounts.

C02b AR – Cash Applications.

C02c AR – Collections.

C02d AR – Credit Administration.

C02e Cash and Marketable Securities.

C02f Financial Planning and Analysis.

C02g Fixed Assets, Long Lived Assets.

C02h Intercompany Transactions – Cross Charges.

C02i Raw Materials and Inventory.

C02j Journal Entries.

C02k Payroll.

C02l Procurement.

C02m Revenue Recognition.

C02n Retail Sales Orders to Business Partners.

C02o Income Tax.


Internal Control Planning, Testing and Remediation Worksheets.