All Posts by Charles Hall

Governmental Internal Controls

By Charles Hall | Fraud , Local Governments

Below I provide useful summary of governmental internal controls.

Why am I providing this list of useful controls? Most small governments struggle with establishing sound internal controls. So, the list provides a beginning point for preventing theft in your government. While not a comprehensive list, it will help. 

Many of the internal controls listed below are also pertinent to nonprofits and small businesses as well. You will find this same checklist in The Little Book of Local Government Fraud Prevention (available on Amazon) which provides many more fraud prevention ideas.

I am providing general fraud prevention controls and then transaction-level controls for:

• Cash receipts and billing
• Cash payments and purchasing
• Payroll

General Governmental Internal Controls

Here are some general governmental internal controls.

1. Have bank statements mailed directly to someone outside of accounting; recipient should peruse bank statement activity before providing it to accounting
2. Perform surprise audits (use outside CPA if possible)
3. Elected officials and management should review the monthly budget to actual reports (and other pertinent financial reports)
4. Map internal control processes by transaction cycle (preferably done by a seasoned CPA); once complete, provide the map to all employees involved in the cycle; when control weaknesses exist, institute additional controls (see 11. below)
5. Use a whistleblower program (preferably use an outside whistleblower company)
6. Reconcile bank statements monthly (have a second person review and initial the reconciliation)
7. Purchase fidelity bond coverage (based on risk exposure)
8. Periodically request from the government’s bank a list of all bank accounts in the name of the government or with the government’s federal tax I.D. number; compare the list to bank accounts set up in the general ledger
9. Secure computer access physically (e.g., locked doors) and electronically (e.g., passwords)
10. Do not allow the electronic transmission (e.g., email) of sensitive data (e.g., social security numbers) without the use of protected transmission technology (e.g. Sharefile); create policy and train staff
11. Where possible, segregate who (1) authorizes transactions, (2) records transactions, (3) reconciles records, and (4) has custody of assets; when segregation of duties is not possible, require documented second-person review and/or surprise audits

Transaction Governmental Internal Controls

Here are transaction level governmental internal controls.

Cash Receipts and Billing Controls

1. Use a centralized receipting location (when possible)
2. Assign each cash drawer to a separate person; require daily reconciliation to receipts; require second person review
3. Deposit cash timely (preferably daily); require the composition of cash and checks to be listed on each deposit ticket (to help prevent check-for-cash substitution)
4. Immediately issue a receipt for each payment received; a duplicate of the receipt or electronic record of the receipt is to be retained by the government
5. A supervisor should review receipting-personnel adjustments made to accounts receivable
6. Do not allow the cashing of personal checks (e.g., from cash drawers)

Cash Payments and Purchasing Controls

1. Guard all check stock (as though it were cash)
2. Do not allow hand-drawn checks; only issue checks through the computerized system; if hand-drawn checks are issued, have a second person create and post the related journal entry
3. Do not allow the signing of blank checks
4. Limit check signing authorization to as few people as possible
5. Require two employees to effectuate each wire transfer
6. Persons who authorize wire transfers should not make related accounting entries
7. Require a documented bidding process for larger purchases (and sealed bids for significant purchases or contracts); specify procedures for evaluating and awarding contracts.
8. Limit the number of credit cards and the chargeable maximum amount on each card
9. Allow only one person to use an individual credit card; require receipts for all purchases
10. Require a street address and social security or tax I.D. numbers for each vendor added to accounts payable vendor list (P.O. box numbers without a street address should not be accepted)
11. Signed vendor checks should not be returned to those who authorized the payment; mail checks directly to vendors
12. Compare payroll addresses with vendor addresses for potential fictitious vendors (usually done with electronic audit tools such as IDEA or ACL)

Payroll Controls

1. Provide a departmental overtime budget/expense report to governing body or relevant committee
2. Use direct deposit for payroll checks
3. Payroll rates keyed into the payroll system must be supported by proper authorization in the employee personnel file
4. Immediately remove terminated employees from the payroll system
5. Use biometric time clocks to eliminate buddy-punching
6. Check for duplicate direct-deposit bank account numbers
7. A department head should provide written authorization for overtime prior to payment

Your Recommendations

What additional controls do you recommend? Share your thoughts below.

Preparing Financial Statements: Which Standards Apply?

By Charles Hall | Preparation, Compilation & Review

Which standards apply when you prepare financial statements?

The AICPA Accounting and Review Services Committee added a section to the compilation and review standards called Preparation of Financial Statements. Since then, I’ve received several questions about which standards apply when financial statements are prepared–especially if you concurrently provide another service such as a compilation, review, or audit.

Those questions include:

• Can an accountant perform a compilation and not prepare the financial statements?
• Are the preparation of financial statements and the performance of a compilation engagement two separate services?
• If an auditor prepares financial statements and audits a company, what is the relevant standard for preparing the financial statements?
• Is the preparation of financial statements a nonattest service, though the audit is an attest service?

Below I provide: (1) a summary of how compilations changed with the issuance of SSARS 21 and (2) a summary of how the preparation of financial statements service interplays with compilations, reviews, and audits.

The Old Compilation Standard 

Using SSARS 19, the performance of a compilation involved one service which encompassed:

• Preparing financial statements,
• Performing compilation procedures (e.g., reading the financials), and
• Issuing a report

How Compilation Engagements Changed 

So, how did SSARS 21 change compilations?

If an accountant prepares the financial statements and performs a compilation engagement using SSARS 21, she is performing two services (not one). In this case, the performance of the preparation of financial statements is not subject to any formal standard (including SSARS 21).

When an accountant performs both the preparation of financial statements and a related compilation engagement, is AR-C 70, Preparation of Financial Statements, applicable?

No.

“Wait…you’re saying that a new standard called Preparation of Financial Statements was added with SSARS 21, but when the accountant prepares financial statements and performs a compilation engagement, the (SSARS 21) preparation standard is not applicable?”

Yes.

AR-C 70, Preparation of Financial Statements, states that the standard is not applicable “when an accountant prepares financial statements and is engaged to perform an audit, review, or compilation of those financial statements.” So if an accountant prepares financial statements as a part of a compilation engagement, AR-C 70 does not apply.

Why?

If AR-C 70, Preparation of Financial Statements, and AR-C 80, Compilation Engagements, were both in play, they would conflict. AR-C 70 requires the accountant to state on each financial statement page that “no assurance is provided” or to issue a disclaimer. AR-C 80 requires the issuance of a compilation report and does not allow the accountant to state that “no assurance is provided” on each financial statement page or for the accountant to issue a disclaimer.

Meaning?

When the accountant prepares financial statements and performs a related compilation, the creation of the financial statements is a nonattest service with no particular guidance–not even from SSARS 21. (Of course, the AICPA Code of Professional Conduct applies to all services.)

When a compilation engagement (an attest service) is performed and financial statements are prepared (a nonattest service), two separate services are being performed by the same accounting firm.

Financial Statement Preparation and Other Services

The table summarizes which standard is applicable when:
1. A preparation engagement is performed (alone)
2. Preparation and compilation engagements are performed for the same time period
3. Preparation and review engagements are performed for the same time period
4. Preparation and audit engagements are performed for the same time period

Preparation of Financial Statements	Compilation Engagement	Review Engagement	Audit Engagement	Standard to Follow
Yes				AR-C 70 Preparation
Yes	Yes			AR-C 80 Compilation
Yes		Yes		AR-C 90 Review
Yes			Yes	AU-C Audit Sections

AR-C 70, Preparation of Financial Statements, applies only in the first example above. When the accountant performs a preparation service and a compilation, review, or audit service for the same time period, AR-C 70 is not applicable–that is, no formal standard applies to the preparation service.

In all the examples listed above, the preparation of financial statements is a nonattest service.

In examples 2, 3 and 4 (where a preparation service and an attest service are provided), your engagement letter should include language about performing nonattest services and how the client will assign someone with suitable skill, knowledge, and experience to oversee the preparation of financial statements service. Such language is only required when a nonattest and an attest service is provided.

SSARS 22 and 23

Since the above information deals with SSARS 21, you may be wondering what additional SSARS have been issued–and how those newer standards affect compilations. 

SSARS 22, Compilation of Pro Forma Financial Information was effective for compilation reports dated on or after May 1, 2017. So, what is pro forma information? It is a presentation that shows what the significant effects on historical financial information might have been had a consummated or proposed transaction (or event) occurred at an earlier date.

SSARS 23, Omnibus Statement on Standards for Accounting and Review Services, was issued in late October 2016. That standard changed supplementary information wording in compilation and review reports. 

The primary impact of SSARS 23 is to provide standards for the preparation and compilation of prospective financial information.

While portions of SSARS 23 were effective upon issuance (the supplementary language change), the remainder of the standard was effective for prospective financial information prepared on or after May 1, 2017, and for compilation reports dated on or after May 1, 2017, respectively.

Simplifying the Measurement of Inventory

By Charles Hall | Accounting

Are you up to speed on ASU 2015-11 Simplifying the Measurement of Inventory? This post assists in understanding the new accounting measurement for inventory.

Inventory Measurement Accounting

ASU 2015-11 requires that entities measure inventory at the lower of cost or net realizable value (LCNRV), provided they don’t use the last-in-first-out method (LIFO) or the retail inventory method. Entities using LIFO or the retail inventory method will continue to use the lower of cost or market (where market is replacement cost). Entities using the first-in-first-out (FIFO), average cost, or any other cost flow methods (other than LIFO and the retail inventory methods) should use the lower of cost or net realizable value approach.

So, where applicable, market is being replaced by net realizable value.

The Financial Accounting Standards Board’s glossary defines net realizable value as follows:

Estimated selling prices in the ordinary course of business, less reasonably predictable costs of completion, disposal, and transportation.

Why the change? FASB is working to simplify some accounting standards. FASB had received comments from stakeholders that the requirement to subsequently measure inventory was “unnecessarily complex because there are several potential outcomes.”

Why did FASB not require the LCNRV method for all entities? The summary section of ASU 2015-11 says,  “The Board received feedback from stakeholders that the proposed amendments would reduce costs and increase comparability for inventory measured using FIFO or average cost but potentially could result in significant transition costs that would not be justified by the benefits for inventory measured using LIFO or the retail inventory method…Therefore, the Board decided to limit the scope of the simplification to exclude inventory measured using LIFO or the retail inventory method.”

What Disclosure is Required for the Change in Accounting Principle?

BC16 of ASU 2015-11 states the following:

The Board decided that the only disclosures required at transition should be the nature of and reason for the change in accounting principle. The Board concluded that the costs of a quantitative disclosure about the change from the lower of cost or market to the lower of cost and net realizable value would not justify the benefits because a reporting entity would be required in the year of adoption to measure inventory using both existing requirements and the amendments in this Update, and because the change would not be significant for some entities.

An entity is required only to disclose the nature and reason for the change in accounting principle in the first interim and annual period of adoption.

Sample ASU 2015-11 Disclosures

Here is a sample disclosure from Mercer International Inc.’s 10-K:

Accounting Pronouncements Implemented

In July 2015, the FASB issued Accounting Standards Update 2015-11, Simplifying the Measurement of Inventory (“ASU 2015–11”) which requires that inventory within the scope of this update, including inventory stated at average cost, be measured at the lower of cost and net realizable value. This update is effective for financial statements issued for fiscal years beginning after December 15, 2016. The adoption of ASU 2015–11 did not impact the Company’s financial position.

Here is a sample disclosure from Delta Apparel, Inc.’s 10-K:

Recently Issued Accounting Pronouncements Not Yet Adopted

In July 2015, the FASB issued ASU No. 2015-11, Simplifying the Measurement of Inventory, (“ASU 2015–11“).  This new guidance requires an entity to measure inventory at the lower of cost and net realizable value. Currently, entities measure inventory at the lower of cost or market. ASU 2015–11 replaces market with net realizable value. Net realizable value is the estimated selling price in the ordinary course of business, less reasonably predictable costs of completion, disposal, and transportation. Subsequent measurement is unchanged for inventory measured under last-in, first-out or the retail inventory method.  ASU 2015–11 requires prospective adoption for inventory measurements for fiscal years beginning after December 15, 2016, and interim periods within those years for public business entities.  Early application is permitted.  ASU 2015–11 will, therefore, be effective in our fiscal year beginning October 1, 2017. We are evaluating the effect that ASU 2015–11 will have on our Consolidated Financial Statements and related disclosures, but do not believe it will have a material impact.

Here is a sample disclosure from Dr. Pepper Snapple Group, Inc.’s 10-K:

Effective Dates for ASU 2015-11

For public business entities, the amendments are effective for fiscal years beginning after December 15, 2016, including interim periods within those fiscal years. For all other entities, the amendments are effective for fiscal years beginning after December 15, 2016, and interim periods within fiscal years beginning after December 15, 2017. The amendments should be applied prospectively with earlier application permitted as of the beginning of an interim or annual reporting period.

Twenty Mistakes that CPAs Make

By Charles Hall | Accounting and Auditing

Here are twenty mistakes that CPAs make:

1. We hire people without sufficient knowledge and temperament
2. We accept more work than we can possibly perform
3. We don’t cull our bad clients (which contributes to #2.)
4. We work without taking breaks
5. We don’t exercise
6. We try to be experts in too many industries
7. We use outdated computers and software (e.g., we are not paperless)
8. We don’t plan our continuing education (and take anything we can find at the end of the year)
9. We have no strategy, moving from one engagement to another because it’s pressing
10. We work sitting down all day (when standup desks are available)
11. We bill our clients months after the service is provided (rather than a couple of weeks)
12. We allow email to drive our day (we are reactive)
13. We don’t express sincere appreciation to our peers and employees (those fully deserving of “thank you!”)
14. We don’t use engagement letters to define our work
15. We have no exit strategy, hoping someone will knock on our door and offer to buy the practice
16. We ignore those we love (because we are overworked and irritable)
17. We don’t stay current on evolving standards
18. We don’t fire unproductive or difficult employees
19. We don’t deal with problems (bad clients or employees) because doing so is awkward
20. We never pause to evaluate our lives

Since  1984, I have worked in public accounting, a profession I dearly love. One thing I’ve noticed about CPAs is we are too immersed in our work–to a point of blindness. We don’t step back and evaluate what or how we do things. Would we be better off if we intentionally removed certain responsibilities? Might we not be even more profitable and happier? 

Two things–more than anything else–will sap your energy and productivity: (1) difficult clients and (2) unproductive or difficult employees.

The 80/20 rule is applicable in our profession. We make 80% of our money from 20% of our work. And 80% of our headaches come from 20% of our clients and employees. (Were you awake last night thinking about one of these?) While the exact percentages may not be true for you, the concept is highly relevant. 

I’ve given you twenty mistakes that CPAs make. Are there others you would add?

If you found this article of interest, see my post What Keeps CPAs Awake at Night. Also, here are Forty Mistakes Auditors Make.

How to Quickly Convert Word and Excel Files to PDFs

By Charles Hall | Technology

Do you ever need to convert Word or Excel files on your desktop into a PDF? Below I show you how to convert your Excel or Word documents to a PDF in just a few steps. I do so using Adobe Acrobat DC.

Now, see how to convert and combine multiple Word and Excel files into one PDF.