Data standard internal control federal government comptroller general united state september united state government accountability office content overview foreword green book section fundamental concept internal control definition internal control definition internal control system section establishing effective internal control system presentation standard attribute internal control entity role internal control system objective entity section evaluation effective internal control system factor effective internal control evaluation internal control section additional consideration service organization large versus small entity benefit cost internal control documentation requirement entity control environment principle demonstrate commitment integrity ethical value tone standard conduct adherence standard conduct principle exercise oversight responsibility oversight structure oversight internal control system input remediation deficiency principle establish authority organizational structure assignment responsibility delegation authority documentation internal control system principle demonstrate commitment competence expectation competence retention individual succession contingency plan preparation principle enforce accountability enforcement accountability consideration excessive pressure risk assessment principle define objective risk tolerance definition objective definition risk tolerance principle respond risk identification risk analysis risk response risk principle assess fraud risk type fraud fraud risk factor response fraud risk principle respond change identification change analysis response change control activity principle design control activity response objective risk design appropriate type control activity design control activity various level segregation duty principle design activity information system design information system design appropriate type control activity design information technology infrastructure design security management design information technology maintenance principle implement control activity documentation responsibility policy periodic review control activity information communication principle quality information identification information requirement relevant data reliable source data processed quality information principle communicate internally communication throughout entity appropriate method communication principle communicate externally communication external party appropriate method communication monitoring principle perform monitoring activity establishment baseline internal control system monitoring evaluation result principle evaluate issue remediate deficiency reporting issue evaluation issue corrective action appendix requirement appendix acknowledgment comptroller advisory council standard internal control federal government project team staff acknowledgment glossary figure figure green book sample page figure achieving objective internal control figure five component principle internal control figure organizational structure internal control figure principle supporting five component internal control figure example common category control activity work government number subject copyright protection united published product reproduced distributed entirety without permission work contain copyrighted image permission copyright holder necessary wish reproduce material overview foreword policymakers program manager continually seeking way improve accountability achieving factor improving accountability achieving mission implement effective internal control effective internal control system help entity adapt shifting evolving changing program change entity strive improve operational process implement management continually evaluates internal control system effective updated section title united state code commonly known federal financial integrity fmfia requires comptroller general issue standard internal control federal standard internal control federal government known green provide overall framework establishing maintaining effective internal control office management budget circular number provides specific requirement assessing reporting control federal term internal control document cover aspect objective green book also adopted quasigovernmental well number profit framework internal control management entity based applicable law appropriately adapt standard presented green book framework committee sponsoring organization treadway commission coso updated internal control guidance issuance revised internal control integrated coso introduced concept principle related five component internal green book adapts principle government committee sponsoring organization treadway internal control integrated framework american institute certified public standard effective beginning fiscal year fmfia report covering elect early adoption green revision standard gone extensive deliberative including public comment input comptroller advisory council standard internal control federal advisory council consists expert financial performance management drawn local private view party thoroughly considered finalizing appreciate effort government public accounting member audit academic community provided valuable assistance developing extend special thanks member advisory council standard internal control federal government extensive input feedback throughout entire process developing finalizing gene dodaro comptroller general united state september green book green book provides manager criterion operating effective internal control green book defines standard component principle explains integral internal control green book clarifies process management considers part internal mature highly effective internal control internal control indistinguishable activity personnel green book structured includes following section overview fundamental concept internal control section discussion internal control relate three category objective section discussion evaluation internal control operation section additional consideration apply component internal control system discussion requirement five component principle well discussion related including documentation green book clearly indicates component principle requirement discussion requirement included section documentation requirement summarized section figure depicts sample page green illustration identifies attribute green discussed section figure green book sample page section fundamental concept internal control definition internal control internal control process effected oversight personnel provides reasonable assurance objective entity achieved objective related risk broadly classified following three operation effectiveness efficiency operation reporting reliability reporting internal external compliance compliance applicable law regulation figure achieving objective internal control distinct overlapping particular objective fall address different direct responsibility different internal control comprises procedure used fulfill strategic objective internal control serf first line defense safeguarding internal control help manager achieve desired result effective stewardship public definition internal control system internal control system continuous built component effected provides reasonable number absolute objective internal control number series action occur throughout internal control recognized integral part operational process management us guide operation rather separate system within internal control built entity part organizational structure help manager achieve objective ongoing people make internal control management responsible effective internal control part management set implement evaluates internal control personnel throughout entity play important role implementing operating effective internal control effective internal control system increase likelihood entity achieve matter well internal control system provide absolute assurance objective factor outside control influence management affect ability achieve natural disaster affect ability achieve effective internal control provides number assurance organization achieve section establishing effective internal control system presentation standard green book defines standard internal control federal fmfia requires federal executive branch entity establish internal control accordance standard provide criterion assessing operating effectiveness internal control federal government entity determine internal control system nonfederal entity overview green book framework operate internal control green book applies standard number intended limit interfere duly granted authority related discretionary policy making implementing green management responsible designing policy procedure circumstance building integral part attribute entity determines set strategic establishes entity formulates plan achieve oversight oversight objective entity whole target activity within management us internal control help organization achieve different way present internal green book approach internal control hierarchical structure five component hierarchy includes requirement establishing effective internal control including specific documentation five component represent highest level hierarchy standard internal control federal five component internal control must effectively operating together integrated internal control system five component internal control control environment foundation internal control provides discipline structure help entity achieve risk assessment assesses risk facing entity seek achieve assessment provides basis developing appropriate risk discussion page federal internal control standard control activity action management establishes policy procedure achieve objective respond risk internal control includes information information communication quality information management personnel communicate support internal control monitoring activity management establishes operates assess quality performance time promptly resolve finding audit principle support effective operation associated component represent requirement necessary establish effective internal control component principle relevant establishing effective internal control rare operating regulatory situation management determined principle number relevant entity achieve objective address related management determines principle number management support determination documentation includes rationale absence associated component could operated addition principle green book contains documentation green book contains additional information form attribute intended help organize application material management consider operating associated attribute provide explanation principle documentation requirement explain precisely requirement mean intended include example procedure appropriate attribute also provide background information matter addressed green attribute relevant proper implementation green management responsibility understand attribute exercise judgment fulfilling requirement green doe number prescribe management operates internal control figure list five component internal control related figure five component principle internal control internal control entity direct relationship exists among five component internal organizational structure objective entity want five component internal control required entity achieve organizational structure encompasses operating operational structure management overview us achieve relationship depicted form cube developed coso figure organizational structure internal control three category objective classified represented column labeled five component internal control represented organizational structure represented third dimension component internal control applies three category objective organizational principle support component internal control discussion organizational page federal internal control standard figure principle supporting five component internal control internal control integrated process component impact operating effectiveness entity identical internal control system difference factor regulatory strategic entity risk information judgment needed responding differing role internal control system internal control part overall five component discussed context management everyone entity responsibility internal role internal control system categorized oversight body oversight body responsible overseeing strategic direction entity obligation related accountability includes overseeing operation internal control oversight body might member senior multiple party member oversight purpose green oversight oversight body implicit component management management directly responsible activity including operating effectiveness internal control responsibility vary depending function organizational personnel personnel help management operate internal control system responsible reporting issue noted compliance discussion identifying external auditor office inspector general number considered part internal control management evaluate incorporate recommendation external auditor responsibility internal control system resides objective entity oversight oversight set objective meet strategic goal requirement applicable law management set objective designing internal control management include setting objective part strategic planning part designing internal control defines objective specific measurable term enable management respond risk related achieving category objective management group objective three category operation effectiveness efficiency operation reporting reliability reporting internal external compliance compliance applicable law regulation operation objective operation objective relate program operation achieve mission defined strategic plan goal objective entity along effective efficient operation necessary fulfill effective operation produce intended result operational efficient operation manner minimizes waste management related subobjectives unit within organizational linking objective throughout entity management improves effectiveness efficiency program operation achieving reporting objective reporting objective relate preparation report external reporting objective grouped following external financial reporting objective objective related release financial performance accordance professional applicable law well expectation external nonfinancial reporting objective objective related release nonfinancial information accordance appropriate applicable law well expectation internal financial reporting objective nonfinancial reporting objective objective related gathering communicating information needed management support decision making evaluation compliance objective government objective related compliance applicable law regulation law regulation often prescribe government method achieve reporting performance relative achieving management considers objective category compliance comprehensively entity determines control necessary operate entity achieve objective management conduct activity accordance applicable law part specifying compliance entity determines law regulation apply management expected objective incorporate entity objective higher level performance established law setting management able exercise discretion relative performance safeguarding asset subset three category objective safeguarding management design internal control system provide reasonable assurance regarding prevention prompt detection correction unauthorized disposition setting subobjectives management develop objective specific subobjectives throughout organizational management defines subobjectives specific measurable term communicated personnel assigned responsibility achieve management personnel require understanding defined level performance accountability internal control section evaluation effective internal control system purpose section provide management factor consider evaluating effectiveness internal control federal circular number provides specific requirement perform evaluation report internal control federal nonfederal entity refer applicable law regulation well input external stakeholder determining appropriately evaluate report internal factor effective internal control effective internal control system provides reasonable assurance organization achieve stated section effective internal control system five component internal control effectively operating five component operating together integrated determine internal control system management assesses operating effectiveness five component principle component number component number operating together integrated internal control system evaluation internal control federal fmfia mandate head executive branch agency annually prepare statement whether system internal accounting administrative control comply requirement system number head agency prepare report material weakness system internal accounting administrative control identified plan schedule correcting weakness issue guidance evaluating requirement circular number nonfederal entity refer applicable law regulation guidance preparing statement regarding internal design implementation evaluating design internal management determines control individually combination control capable achieving objective addressing related evaluating management determines control exists entity placed control control effectively implemented number effectively deficiency design exists control necessary meet control objective missing existing control number properly designed even control operates control objective would number deficiency implementation exists properly designed control number implemented correctly internal control operating effectiveness evaluating operating management determines control applied relevant time period consistency mean substantially different control used different time period management evaluates operating effectiveness separately unique control control effectively operating number effectively designed deficiency operation exists properly designed control doe number operate person performing control doe number possess necessary authority competence perform control effect deficiency internal control system management evaluates control deficiency identified ongoing monitoring internal control system well separate evaluation performed internal external deficiency internal control exists operation control doe number allow management normal course performing assigned achieve control objective address related management evaluates significance identified significance refers relative importance deficiency achieving defined evaluate significance management assesses effect achieving defined objective entity transaction management evaluates significance deficiency considering magnitude likelihood nature magnitude impact refers likely effect deficiency could entity achieving objective affected factor duration deficiency significant objective likelihood occurrence refers possibility deficiency impacting ability achieve nature deficiency involves factor degree subjectivity involved deficiency whether deficiency arises fraud oversight body oversees evaluation significance deficiency deficiency properly deficiency evaluated individual basis management considers correlation among different deficiency group deficiency evaluating deficiency evaluation varies entity difference management make summary determination whether principle operating management considers impact deficiency identified achieving documentation requirement part summary management consider related attribute part summary principle number operating respective component discussion documentation based result summary determination management concludes operating effectiveness five component internal management also considers five component operate together five component number effectively operating effectively number operating together integrated internal control system judgment used making includes exercising reasonable section additional consideration service organization management engage external party perform certain operational process accounting payroll security health care claim purpose green external party referred service retains responsibility performance process assigned service management need understand control service organization operates assigned operational process service internal control system impact internal control control performed service organization necessary entity achieve objective address risk related assigned operational internal control include complementary user entity control identified service organization auditor necessary achieve service control management consider following determining extent oversight operational process assigned service nature service outsourced service standard conduct quality frequency service enforcement adherence standard conduct personnel magnitude level complexity operation organizational structure extent internal control sufficient entity achieves objective address risk related assigned operational process large versus small entity principle apply large small smaller entity different implementation approach larger smaller entity typically unique contribute effective internal control include higher level involvement management operational process direct interaction smaller entity find informal staff meeting effective communicating quality whereas larger entity need formal written intranet periodic formal communicate smaller face greater challenge segregating duty concentration responsibility overview authority organizational respond increased risk design internal control adding additional level review operational reviewing randomly selected transaction supporting taking periodic asset checking supervisor benefit cost internal control internal control provides many benefit provides management added confidence regarding achievement provides feedback effectively entity help reduce risk affecting achievement management considers variety cost factor relation expected benefit designing implementing internal complexity cost benefit determination compounded interrelationship control operational control integrated operational difficult isolate either cost management decide entity evaluates cost versus benefit various approach implementing effective internal control cost alone number acceptable reason avoid implementing internal management responsible meeting internal control cost versus benefit consideration support ability effectively operate internal control system balance allocation resource relation area greatest factor relevant achieving documentation requirement documentation necessary part effective internal control level nature documentation vary based size entity complexity operational process entity management us judgment determining extent documentation documentation required effective operating effectiveness internal control green book includes minimum documentation requirement discussion segregation page federal internal control standard management determines principle number management support determination documentation includes rationale absence associated component could operated paragraph management develops maintains documentation internal control paragraph management document policy internal control responsibility paragraph management evaluates document result ongoing monitoring separate evaluation identify internal control paragraph management evaluates document internal control issue determines appropriate corrective action internal control deficiency timely paragraph management completes document corrective action remediate internal control deficiency timely paragraph requirement represent minimum level documentation internal control management exercise judgment determining additional documentation necessary effective internal control management identifies deficiency achieving documentation effect identified deficiency considered part summary determination whether related principle operating entity green book applied framework internal control system quasi governmental well number profit management elect adopt green book management follows relevant requirement presented control environment overview control environment foundation internal control provides discipline affect overall quality internal influence objective defined control activity oversight body management establish maintain environment throughout entity set positive attitude toward internal principle oversight body management demonstrate commitment integrity ethical oversight body oversee internal control management establish organizational assign delegate authority achieve management demonstrate commitment retain competent management evaluate performance hold individual accountable internal control principle demonstrate commitment integrity ethical value oversight body management demonstrate commitment integrity ethical attribute following attribute contribute operating effectiveness tone standard conduct adherence standard conduct tone oversight body management demonstrate importance integrity ethical value oversight body management lead example demonstrates operating oversight body management tone throughout organization fundamental effective internal control larger various layer management organizational structure also oversight behavior reflect integrity ethical value expected throughout oversight body management reinforce commitment number maintaining minimum level performance necessary comply applicable law priority understood general tone either shown preceding barrier internal without strong tone support internal control risk identification risk response control activity number appropriately designed information communication result monitoring number understood acted upon remediate standard conduct management establishes standard conduct communicate expectation concerning integrity ethical entity us ethical value balance need concern different general standard conduct guide behavior organization achieving oversight oversight defines expectation ethical value standard management consider using operating guideline communicate standard conduct adherence standard conduct management establishes process evaluate performance expected standard conduct address deviation timely management us established standard conduct basis evaluating adherence integrity ethical value across management evaluates adherence standard conduct across level gain assurance standard conduct implemented management evaluates behavior individual evaluation consist ongoing monitoring separate individual personnel also report issue reporting regular staff upward feedback whistle blowing ethic oversight body evaluates adherence standard conduct well overall adherence discussion ongoing monitoring separate discussion upward separate reporting management determines tolerance level management determine entity zero tolerance deviation certain expected standard deviation others addressed warning management establishes process evaluation individual team adherence standard conduct escalates remediates management address deviation expected standard conduct timely depending severity deviation determined evaluation oversight oversight take appropriate action also need consider applicable law standard conduct management hold remain principle exercise oversight responsibility oversight body oversee internal control attribute following attribute contribute operating effectiveness oversight structure oversight internal control system input remediation deficiency oversight structure entity determines oversight structure fulfill responsibility forth applicable law relevant government feedback entity mandated selected oversight oversight body composed entity activity referenced green book performed exclude member management role oversight responsibility oversight body oversight structure entity senior senior management distinguish divisional functional management establishment oversight oversight body oversees provides constructive criticism make oversight decision entity achieves objective alignment integrity ethical qualification oversight body selecting member oversight entity applicable body defines entity relevant number possible independence needed fulfill oversight responsibility member oversight body understand related expectation addition oversight organization within federal government several body stakeholder white office management department oversight body work stakeholder understand expectation help entity fulfill expectation entity applicable body also considers expertise needed member evaluate capability expected member oversight body include integrity ethical critical problem solving determining number member oversight entity applicable body considers need member oversight body specialized skill enable offer constructive criticism make appropriate oversight specialized skill include internal control mindset professional skepticism perspective approach identifying responding risk assessing effectiveness system internal control programmatic including knowledge operational process human functional management expertise financial including financial reporting accounting standard financial reporting requirement budgetary expertise relevant system technology understanding critical system technology risk opportunity legal regulatory expertise understanding applicable law regulation authorized applicable law entity also consider including independent member part oversight government auditing december discussion member oversight body scrutinize question present alternative faced obvious suspected independent member relevant expertise provide value impartial evaluation entity operation achieving oversight internal control system oversight body oversees operation internal control oversight responsibility internal control system include control environment establish integrity ethical establish oversight develop expectation maintain accountability member oversight body risk assessment oversee assessment risk achievement including potential impact significant management override internal control activity provide oversight management development performance control information communication analyze discus information relating achievement monitoring scrutinize nature scope monitoring activity well evaluation remediation identified responsibility supported organizational structure management oversight body oversees operation organizational structure process necessary enable oversight body fulfill responsibility exist operating discussion organizational input remediation deficiency oversight body provides input plan remediation deficiency internal control system management report deficiency identified internal control system oversight oversight body oversees provides direction management remediation oversight body also provides direction deficiency cross organizational boundary interest management conflict remediation appropriate oversight body direct creation team address oversee specific matter critical achieving oversight body responsible overseeing remediation deficiency appropriate providing direction management appropriate time frame correcting discussion timely remediation principle establish authority management establish organizational assign delegate authority achieve attribute following attribute contribute operating effectiveness organizational structure assignment responsibility delegation authority documentation internal control system organizational structure management establishes organizational structure necessary enable entity assess organization achieving management develops overall responsibility objective enable entity achieve objective address related management develops organizational structure understanding overall assigns responsibility discrete unit enable organization operate control environment efficient effective comply applicable law reliably report quality based nature assigned management chooses type number discrete related part establishing organizational management considers unit interact order fulfill overall management establishes reporting line within organizational structure unit communicate quality information necessary unit fulfill overall reporting line defined level organization provide method communication flow around management also considers overall responsibility external stakeholder establishes reporting line allow entity communicate receive information external management periodically evaluates organizational structure meet objective adapted objective assignment responsibility delegation authority achieve management assigns responsibility delegate authority role throughout role position organizational structure assigned overall responsibility role relate senior management position within management considers overall responsibility assigned determines role needed fulfill assigned establishes role assign responsibility internal control role organizational retain ownership fulfilling overall responsibility assigned discussion quality discussion quality discussion internal reporting discussion external reporting page federal internal control standard control environment management determines level authority role need fulfill management delegate authority extent required achieve part delegating management evaluates delegation proper segregation duty within unit organizational segregation duty help prevent abuse entity considering need separate accounting organizational assigning role delegate authority internal control role organizational documentation internal control system management develops maintains documentation internal control effective documentation assist design internal control establishing communicating internal control execution documentation also provides mean retain organizational knowledge mitigate risk knowledge limited well mean communicate knowledge needed external external management document internal control meet operational documentation including change evidence control capable communicated responsible capable monitored evaluated extent documentation needed support operating effectiveness five component internal control matter judgment management considers cost benefit documentation requirement entity well complexity entity level necessary component internal control operating discussion segregation page federal internal control standard principle demonstrate commitment competence management demonstrate commitment retain competent attribute following attribute contribute operating effectiveness expectation competence retention individual succession contingency plan preparation expectation competence management establishes expectation competence role help entity achieve competence qualification carry assigned requires relevant gained largely professional demonstrated behavior individual carry management considers standard assigned delegated authority establishing management establishes expectation competence management also establish expectation competence personnel policy within internal control discussion personnel need possess maintain level competence allows accomplish assigned well understand importance effective internal holding individual accountable established policy evaluating competence integral retaining management evaluates competence personnel across entity relation established management act necessary address deviation established oversight body evaluates competence management well competence overall entity retention individual management retains competent personnel achieve management considers recruit conduct procedure determine whether particular candidate fit organizational need competence proposed train enable individual develop competency appropriate reinforce standard tailor training based need mentor provide guidance performance based standard conduct expectation align skill expertise help personnel adapt evolving retain provide incentive motivate reinforce expected level performance desired including training credentialing succession contingency plan preparation management defines succession contingency plan role help entity continue achieving succession plan address need replace competent personnel long whereas contingency plan address need respond sudden personnel change could compromise internal control management defines succession plan chooses succession train succession candidate assume management relies service organization fulfill assigned responsibility role management assesses whether service organization continue identifies candidate organization implement process enable knowledge sharing succession candidate management defines contingency plan assigning responsibility role entity vacated without advance importance role internal control system impact entity vacancy dictate formality depth contingency principle enforce accountability management evaluate performance hold individual accountable internal control attribute following attribute contribute operating effectiveness enforcement accountability consideration excessive pressure enforcement accountability management enforces accountability individual performing internal control accountability driven tone supported commitment integrity ethical organizational expectation influence control culture accountability performance internal control responsibility support decision management hold personnel accountable mechanism performance appraisal disciplinary management hold entity personnel accountable performing assigned internal control oversight hold management accountable well organization whole internal control management establishes management recognizes action yield unintended consequence evaluates incentive align standard management hold service organization accountable assigned internal control management contract service organization perform role organizational management communicates service organization objective entity related standard role service organization organizational assigned responsibility authority expectation competence role enable service organization perform internal control oversight oversight take corrective action necessary enforce accountability internal control environment control action range informal feedback provided direct supervisor disciplinary action taken oversight depending significance deficiency internal control consideration excessive pressure management adjusts excessive pressure personnel pressure appear entity goal established management meet objective cyclical demand various process performed year financial statement excessive pressure result personnel meet established management responsible evaluating pressure personnel help personnel fulfill assigned responsibility accordance standard management adjust excessive pressure using many different rebalancing workload increasing resource discussion significance page federal internal control standard risk assessment overview established effective control management assesses risk facing entity seek achieve assessment provides basis developing appropriate risk management assesses risk entity face external internal principle management define objective clearly enable identification risk define risk management respond risk related achieving defined management consider potential fraud responding management respond significant change could impact internal control principle define objective risk tolerance management define objective clearly enable identification risk define risk attribute following attribute contribute operating effectiveness definition objective definition risk tolerance definition objective management defines objective specific measurable term enable design internal control related specific term fully clearly forth easily measurable term allow assessment performance toward achieving objective initially part objective setting process refined incorporated internal control system management us establish control management defines objective specific term understood level involves clearly defining achieve time frame objective broadly classified three reporting objective categorized either internal external financial management defines objective alignment strategic performance management defines objective measurable term performance toward achieving objective measurable objective generally free bias number require subjective judgment dominate measurable objective also stated quantitative qualitative form permit reasonably consistent management considers external requirement internal expectation defining objective enable design internal standard setting body external requirement establishing standard entity required management risk assessment incorporates requirement management set internal expectation requirement established standard oversight organizational expectation part control management evaluates revise defined objective consistent requirement consistency enables management identify analyze risk associated achieving defined management determines whether performance measure defined objective appropriate evaluating performance achieving quantitative performance measure targeted percentage numerical qualitative management need design performance measure indicate level degree definition risk tolerance management defines risk tolerance defined risk tolerance acceptable level variation performance relative achievement risk tolerance initially part objective setting management defines risk tolerance defined objective ensuring level variation performance measure appropriate design internal control management defines risk tolerance specific measurable term clearly stated risk tolerance often measured term performance measure defined depending category risk tolerance expressed discussion standard discussion oversight discussion organizational discussion expectation page federal internal control standard operation objective level variation performance relation nonfinancial reporting objective level precision accuracy suitable user involving qualitative quantitative consideration meet need nonfinancial report financial reporting objective judgment materiality made light surrounding involve qualitative quantitative affected need financial report user size nature compliance objective concept risk tolerance doe number entity either compliant number management also evaluates whether risk tolerance enable appropriate design internal control considering whether consistent requirement expectation defined defining management considers risk tolerance context applicable standard well standard oversight organizational expectation risk tolerance defined objective number consistent requirement management revise risk tolerance achieve principle respond risk management respond risk related achieving defined attribute following attribute contribute operating effectiveness identification risk analysis risk response risk identification risk management identifies risk throughout entity provide basis analyzing risk assessment identification analysis risk related achieving defined objective form basis designing risk identify management considers type risk impact includes inherent residual inherent risk risk entity absence response residual risk risk remains response inherent lack response either risk could cause deficiency internal control management considers significant interaction within entity external change within internal external internal external factor identify risk throughout internal risk factor include complex nature organizational technology operational external risk factor include amended professional economic potential natural management considers factor entity transaction level comprehensively identify risk affect defined risk identification method include qualitative quantitative ranking forecasting strategic consideration deficiency identified audit discussion change internal control discussion level analysis risk management analyzes identified risk estimate provides basis responding significance refers effect achieving defined management estimate significance identified risk assess effect achieving defined objective entity transaction management estimate significance risk considering magnitude likelihood nature magnitude impact refers likely magnitude deficiency could result risk affected factor duration likelihood occurrence refers level possibility risk nature risk involves factor degree subjectivity involved risk whether risk arises fraud complex unusual oversight body oversee estimate significance risk tolerance properly risk analyzed individual basis grouped category related risk analyzed regardless whether risk analyzed individually management considers correlation among different risk group risk estimating specific risk analysis methodology used vary entity difference mission difficulty qualitatively quantitatively defining risk response risk management design response analyzed risk risk within defined risk tolerance defined management design overall risk response analyzed risk based significance risk defined risk risk response include acceptance action taken respond risk based insignificance avoidance action taken stop operational process part operational process causing reduction action taken reduce likelihood magnitude sharing action taken transfer share risk across entity external insuring based selected risk management design specific action respond analyzed nature extent risk response action depend defined risk operating within defined risk tolerance provides greater assurance entity achieve performance measure used assess whether risk response action enable entity operate within defined risk risk response action number enable entity operate within defined risk management need revise risk response reconsider defined risk management need conduct periodic risk assessment evaluate effectiveness risk response principle assess fraud risk management consider potential fraud responding attribute following attribute contribute operating effectiveness type fraud fraud risk factor response fraud risk type fraud management considers type fraud occur within entity provide basis identifying fraud type fraud involves obtaining something value willful whether fact fraud determination made judicial adjudicative system beyond professional responsibility assessing fraudulent financial reporting intentional misstatement omission amount disclosure financial statement deceive financial statement could include intentional alteration accounting misrepresentation intentional misapplication accounting misappropriation asset theft could include theft embezzlement fraudulent corruption bribery illegal addition management considers form misconduct waste waste using expending resource abuse involves behavior deficient improper compared behavior prudent person would consider reasonable necessary operational practice given fact includes misuse authority position personal gain benefit waste abuse number necessarily involve fraud illegal indication potential fraud illegal act still impact achievement defined fraud risk factor management considers fraud risk fraud risk factor number necessarily indicate fraud exists often present fraud fraud risk factor include incentive pressure management personnel incentive provides motive commit opportunity circumstance absence ineffective ability management override provide opportunity commit attitude rationalization individual involved able rationalize committing individual possess ethical value allow knowingly intentionally commit dishonest discussion discussion analyzing discussion management management us fraud risk factor identify fraud fraud risk greatest three risk factor factor indicate fraud information provided internal external party also used identify fraud include allegation fraud suspected fraud reported office inspector general internal external party interact response fraud risk management analyzes responds identified fraud risk effectively fraud risk analyzed risk analysis process performed identified management analyzes identified fraud risk estimating individually assess effect achieving defined part analyzing fraud management also assesses risk management override oversight body oversees assessment fraud risk risk management override control management responds fraud risk risk response process performed analyzed management design overall risk response specific action responding fraud possible reduce eliminate certain fraud risk making change activity change include stopping reorganizing certain operation reallocating role among personnel enhance segregation addition responding fraud management need develop response address risk management override fraud risk assessment process need discussion responding principle respond change management respond significant change could impact internal control attribute following attribute contribute operating effectiveness identification change analysis response change identification change part risk assessment similar management identifies change could significantly impact internal control responding change similar number part regular risk assessment change discussed separately critical effective internal control system often overlooked inadequately addressed normal course condition affecting entity environment continually management anticipate plan significant change using forward looking process identifying management risk assessment timely significant change internal external condition already occurred expected change internal condition include change program oversight organizational change external condition include change physical identified significant change communicated across entity established reporting line appropriate analysis response change part risk assessment similar management analyzes responds identified change related risk order maintain effective internal control change condition affecting entity environment often require change internal control existing control number effective meeting objective addressing risk changed management analyzes effect identified change internal control system responds revising internal control system timely maintain changing condition often prompt risk change existing risk need part analyzing responding management performs risk assessment respond risk prompted existing risk require assessment determine whether defined risk tolerance risk response need discussion internal reporting page federal internal control standard control activity overview control activity action management establishes policy procedure achieve objective respond risk internal control includes information principle management design control activity achieve objective respond management design information system related control activity achieve objective respond management implement control activity principle design control activity management design control activity achieve objective respond attribute following attribute contribute operating effectiveness response objective risk design appropriate type control activity design control activity various level segregation duty response objective risk management design control activity response objective risk achieve effective internal control control activity mechanism enforce directive achieve objective address related part control environment management defines assigns delegate authority achieve part risk assessment management identifies risk related entity including service risk risk management design control activity fulfill defined responsibility address identified risk design appropriate type control activity management design appropriate type control activity internal control control activity help management fulfill responsibility address identified risk response internal control common control activity category listed figure meant illustrate range variety control activity useful list number inclusive number include particular control activity entity figure example common category control activity level review actual performance management track major entity achievement compare objective review management functional activity level management compare actual performance planned expected result throughout organization analyzes significant management human capital effective management human essential achieving result important part internal right personnel board provided right responsibility operational success management continually assesses ability need entity entity able obtain workforce required ability achieve organizational training aimed developing retaining employee ability meet changing organizational management provides qualified continuous supervision internal control objective management design performance evaluation feedback supplemented effective reward help employee understand connection performance part human capital management also considers best retain valuable plan eventual maintain continuity needed skill control information processing variety control activity used information example include edit check data accounting transaction numerical comparing file total control controlling access discussion control information physical control vulnerable asset management establishes physical control secure safeguard vulnerable example include security limited access asset equipment might vulnerable risk loss unauthorized management periodically count compare asset control establishment review performance measure indicator management establishes activity monitor performance measure include comparison assessment relating different set data another analysis relationship made appropriate action management design control aimed validating propriety integrity entity individual performance measure segregation duty management divide segregate duty responsibility among different people reduce risk includes separating responsibility authorizing processing recording reviewing handling related asset individual control aspect transaction proper execution transaction transaction authorized executed person acting within scope principal mean assuring valid transaction commit resource initiated entered management clearly communicates authorization accurate timely recording transaction transaction promptly recorded maintain relevance value management controlling operation making applies entire process life cycle transaction event initiation authorization final classification summary management design control activity transaction completely accurately access restriction accountability resource record management limit access resource record authorized assigns maintains accountability custody management periodically compare resource recorded accountability help reduce risk unauthorized appropriate documentation transaction internal control management clearly document internal control transaction significant event manner allows documentation readily available documentation appear management administrative operating either paper electronic documentation record properly managed internal control flexible allow management tailor control activity meet special specific control activity used given entity different used others based number factor could include specific threat entity face risk difference managerial size complexity operational sensitivity value requirement system control activity either preventive main difference preventive detective control activity timing control activity within preventive control activity prevents entity failing achieve objective address detective control activity discovers entity number achieving objective addressing risk operation concluded corrects action entity achieves objective address management evaluates purpose control activity well effect deficiency would entity achieving control activity significant purpose impact deficiency would significant achieving management design preventive detective control control activity implemented either automated manual automated control activity either wholly partially automated information manual control activity performed individual minor information automated control activity tend reliable less susceptible human error typically entity relies information technology management design control activity information technology continues operate discussion information system control design control activity various level management design control activity appropriate level organizational management design control activity appropriate coverage objective risk operational process transform input output achieve management design entity level control transaction control depending level precision needed entity meet objective address related entity level control control pervasive effect internal control system pertain multiple entity level control include control related risk assessment control service management transaction control activity action built directly operational process support entity achieving objective addressing related tends associated financial process payable generally applied operational compliance purpose cover management design variety transaction control activity operational include authorization physical control supervisory control choosing entity level transaction control management evaluates level precision needed operational process meet objective address related determining necessary level precision control management evaluates purpose control activity control activity function prevent detect generally precise control activity merely identifies explains level aggregation control activity performed granular level generally precise performed higher analysis obligation budget object class normally precise analysis total obligation consistency performance control activity performed routinely consistently generally precise performed correlation relevant operational process control activity directly related operational process generally likely prevent detect control activity indirectly segregation duty management considers segregation duty designing control activity responsibility incompatible duty segregated segregation number design alternative control activity address control activity segregation duty help prevent abuse internal control management considers need separate control activity related accounting operation achieve adequate segregation segregation duty address risk management management override circumvents existing control activity increase fraud management address risk segregation absolutely prevent risk employee together commit segregation duty number practical within operational process limited personnel management design alternative control activity address risk abuse operational principle design activity information system management design information system related control activity achieve objective respond attribute following attribute contribute operating effectiveness design information system design appropriate type control activity design information technology infrastructure design security management design information technology maintenance design information system management design information system respond objective management design information system obtain process information meet operational information requirement respond objective information system technology discussion page federal internal control standard control activity management organizes dispose information system represents life cycle information used operational process enables entity process quality information system includes manual technology enabled information technology enabled information process commonly referred information part control environment management defines assigns delegate authority achieve part risk assessment management identifies risk related entity including service risk risk management design control activity fulfill defined responsibility address identified risk response information management design information system information technology considering defined information requirement operational information technology enables information related operational process become available entity timelier information technology enhance internal control security confidentiality information appropriately restricting although information technology implies specific type control information technology number control integral part control management also evaluates information processing objective meet defined information information processing objective include completeness transaction occur recorded number accuracy transaction recorded correct amount right account timely basis stage discussion quality discussion defined information page federal internal control standard validity recorded transaction represent economic event actually occurred executed according prescribed design appropriate type control activity management design appropriate type control activity information system coverage information processing objective operational information main type control general application control information system general control entity application level policy procedure apply large segment information general control facilitate proper operation information system creating environment proper operation application general control include security logical physical configuration segregation contingency application sometimes referred business process control incorporated directly computer application achieve confidentiality transaction data application application control include control master data management system design information technology infrastructure management design control activity information technology infrastructure support validity information processing information information technology requires infrastructure including communication network linking information computing resource application electricity power information information technology infrastructure shared different unit within entity outsourced either service organization location independent technology management evaluates objective entity related risk designing control activity information technology management continues evaluate change information technology design control activity change incorporated information technology management also design control activity needed maintain information technology maintaining technology often includes backup recovery well continuity operation depending risk consequence full partial power system design security management management design control activity security management information system appropriate access internal external source protect information objective security management include confidentiality mean output safeguarded unauthorized integrity mean information safeguarded improper modification includes ensuring nonrepudiation availability mean relevant information readily available user security management includes information process control activity related access right information including ability execute security management includes access right across various level operating system system physical management design control activity access protect entity inappropriate access unauthorized control activity support appropriate segregation preventing unauthorized change data program integrity protected malicious intent someone breaking technology commit terrorism management evaluates security threat information internal external external threat particularly important entity depend telecommunication network external threat become prevalent highly interconnected business continual effort required address internal threat come former disgruntled pose unique risk motivated work entity better equipped succeed carrying malicious greater access knowledge security management system management design control activity limit user access information technology authorization control activity providing unique user identification token authorized control activity restrict authorized user application function commensurate assigned supporting appropriate segregation management design control activity promptly update access right employee change function leave management also design control activity access right different information technology element connected design information technology maintenance management design control activity maintenance information management system development life cycle sdlc framework designing control sdlc provides structure information technology design outlining specific phase documenting checkpoint within control activity maintenance management design control activity change involve requiring authorization change reviewing testing designing protocol determine whether change made depending size complexity development information technology change information technology included sdlc separate management evaluates objective risk technology designing control activity management acquire information technology packaged software management incorporates methodology acquisition vendor package information technology development design control activity ongoing control activity change application software prevent unauthorized program modification existing another alternative outsourcing development information technology service sdlc developed management design control activity meet objective address related management also evaluates unique risk using service organization present validity information submitted received service principle implement control activity management implement control activity attribute following attribute contribute operating effectiveness documentation responsibility policy periodic review control activity documentation responsibility policy management document policy internal control responsibility management document policy unit responsibility operational objective related control activity operating guidance determines policy necessary operate process based objective related risk operational unit also document policy appropriate level detail allow management effectively monitor control discussion discussion corrective role unit define policy depending rate change operating environment complexity operational procedure include timing control activity occurs follow corrective action performed competent personnel deficiency management communicates personnel policy procedure personnel implement control activity assigned periodic review control activity management periodically review related control activity continued relevance effectiveness achieving objective addressing related significant change management review process timely manner change determine control activity designed implemented change occur operational information federal office management budget department treasury also change either objective entity achieve management considers change periodic overview management us quality information support internal control effective information communication vital entity achieve entity management need access relevant reliable communication related internal well external principle management quality information achieve management internally communicate necessary quality information achieve management externally communicate necessary quality information achieve principle quality information management quality information achieve attribute following attribute contribute operating effectiveness identification information requirement relevant data reliable source data processed quality information identification information requirement management design process us objective related risk identify information requirement needed achieve objective address information requirement consider expectation internal external management defines identified information requirement relevant level requisite specificity appropriate management identifies information requirement iterative ongoing process occurs throughout effective internal control change entity objective risk management change information requirement needed meet modified objective address modified relevant data reliable source management obtains relevant data reliable internal external source timely manner based identified information relevant data logical connection bearing identified information reliable internal external source provide data reasonably free error bias faithfully represent purport management evaluates internal external source data source data compliance management obtains data timely basis used effective data processed quality information management process obtained data quality information support internal control involves processing data information evaluating processed information quality quality information meet identified information information communication requirement relevant data reliable source quality information provided timely management considers characteristic well information processing objective evaluating processed information make revision necessary information quality management us quality information make informed decision evaluate performance achieving objective addressing management process relevant data reliable source quality information within information information system technology management organizes dispose principle communicate internally management internally communicate necessary quality information achieve attribute following attribute contribute operating effectiveness communication throughout entity appropriate method communication communication throughout entity management communicates quality information throughout entity using established reporting quality information communicated around reporting line level management communicates quality information across reporting line enable personnel perform role achieving addressing supporting internal control management assigns internal control responsibility discussion information processing discussion information page federal internal control standard management receives quality information operational process flow reporting line personnel help management achieve oversight body receives quality information flow reporting line management information relating internal control communicated oversight body includes significant matter adherence change issue arising internal control upward communication necessary effective oversight internal personnel separate reporting line around upward reporting line line law regulation require entity establish separate line whistleblower ethic communicating confidential management informs employee separate reporting information remain appropriate method communication management selects appropriate method communicate management considers variety factor selecting appropriate method factor consider audience intended recipient communication nature information purpose type information communicated availability information readily available audience needed cost resource used communicate information legal regulatory requirement requirement law regulation impact communication based consideration management selects appropriate method written hard copy electronic face face management periodically evaluates method communication organization appropriate tool communicate quality information throughout entity timely principle communicate externally management externally communicate necessary quality information achieve attribute following attribute contribute operating effectiveness communication external party appropriate method communication communication external party management communicates obtains quality information external party using established reporting open external reporting line allow external party include service external government general management communicates quality information externally reporting line external party help entity achieve objective address related management includes communication information relating event activity impact internal control management receives information reporting line external information communicated management includes significant matter relating issue impact internal control communication necessary effective operation internal management evaluates external information received characteristic quality information information processing objective take necessary action information quality discussion information processing oversight body receives information reporting line external information communicated oversight body includes significant matter relating issue impact internal control communication necessary effective oversight internal external party separate reporting line external reporting line law regulation require entity establish separate line whistleblower ethic communicating confidential management informs external party separate reporting information remain appropriate method communication management selects appropriate method communicate management considers variety factor selecting appropriate method factor consider audience intended recipient communication nature information purpose type information communicated availability information readily available audience needed cost resource used communicate information legal regulatory requirement requirement law regulation impact communication based consideration management selects appropriate method written hard copy electronic face face management periodically evaluates method communication organization appropriate tool communicate quality information throughout outside entity timely government entity number report head regulator general public federal entity number report president congress also general entity consider appropriate method communicating broad monitoring overview since internal control dynamic process adapted continually risk change entity monitoring internal control system essential helping internal control remain aligned changing internal control monitoring assesses quality performance time promptly resolve finding audit corrective action necessary complement control activity order achieve principle management establish operate monitoring activity monitor internal control system evaluate management remediate identified internal control deficiency timely principle perform monitoring activity management establish operate monitoring activity monitor internal control system evaluate attribute following attribute contribute operating effectiveness establishment baseline internal control system monitoring evaluation result establishment baseline management establishes baseline monitor internal control baseline current state internal control system compared design internal control baseline represents difference criterion design internal control system condition internal control system specific point baseline consists issue deficiency identified internal control management baseline criterion evaluating internal control system make change reduce difference criterion management reduces difference management either change design internal control system better address objective risk entity improves operating effectiveness internal control part management determines revise baseline reflect change internal control internal control system monitoring management monitor internal control system ongoing monitoring separate ongoing monitoring built performed responsive separate evaluation used periodically provide feedback effectiveness ongoing management performs ongoing monitoring design operating effectiveness internal control system part normal course ongoing monitoring includes regular management supervisory routine ongoing monitoring include automated increase objectivity efficiency electronically compiling evaluation control management us separate evaluation monitor design operating effectiveness internal control system specific time specific function scope frequency separate evaluation depend primarily assessment effectiveness ongoing rate change within entity separate evaluation take form include cross operating unit cross functional separate evaluation also include audit evaluation involve review control design direct testing internal audit evaluation mandated performed internal external inspector external separate evaluation provide greater objectivity performed reviewer number responsibility activity management retains responsibility monitoring effectiveness internal control assigned process performed service management us ongoing separate combination obtain reasonable assurance operating effectiveness service internal control assigned monitoring activity related service organization include work performed external service reviewed discussion service evaluation result management evaluates document result ongoing monitoring separate evaluation identify internal control management us evaluation determine effectiveness internal control difference result monitoring activity previously established baseline indicate internal control including undocumented change internal control system potential internal control management identifies change internal control system either occurred needed change entity external party also help management identify issue internal control complaint general public regulator comment indicate area internal control system need management considers whether current control address identified issue modifies control principle evaluate issue remediate deficiency management remediate identified internal control deficiency timely attribute following attribute contribute operating effectiveness reporting issue evaluation issue corrective action reporting issue personnel report internal control issue established reporting line appropriate internal external party timely basis enable entity promptly evaluate discussion internal reporting line discussion external reporting personnel identify internal control issue performing assigned internal control personnel communicate issue internally person role responsible internal control associated process least level management depending nature personnel consider reporting certain issue oversight issue include issue across organizational structure extend outside entity service supplier monitoring issue number remediated interest sensitive information regarding fraud illegal depending regulatory compliance entity also required report issue externally appropriate external standard setting body establish standard entity evaluation issue management evaluates document internal control issue determines appropriate corrective action internal control deficiency timely management evaluates issue identified monitoring activity reported personnel determine whether issue rise level internal control internal control deficiency require evaluation remediation internal control deficiency operating effectiveness internal control related management determines type internal control deficiency appropriate corrective action remediate internal control deficiency timely management assigns responsibility delegate authority remediate internal control corrective action management completes document corrective action remediate internal control deficiency timely corrective action include resolution audit depending nature either oversight body management oversees prompt remediation deficiency communicating corrective action appropriate level organizational structure delegating authority completing corrective action appropriate audit resolution process begin audit review result reported completed action taken corrects identified discussion discussion evaluation internal control page federal internal control standard produce demonstrates finding recommendation number warrant management oversight oversight monitor status remediation effort completed timely following list requirement included green five component internal control must effectively operating together integrated internal control system paragraph principle support effective operation associated component represent requirement necessary establish effective internal control principle requirement green book oversight body management demonstrate commitment integrity ethical oversight body oversee internal control management establish organizational assign delegate authority achieve management demonstrate commitment retain competent management evaluate performance hold individual accountable internal control management define objective clearly enable identification risk define risk management respond risk related achieving defined management consider potential fraud responding management respond significant change could impact internal control management design control activity achieve objective respond management design information system related control activity achieve objective respond management implement control activity management quality information achieve management internally communicate necessary quality information achieve management externally communicate necessary quality information achieve management establish operate monitoring activity monitor internal control system evaluate management remediate identified internal control deficiency timely documentation necessary part effective internal control level nature documentation vary based size entity complexity operational process entity management us judgment determining extent documentation documentation required demonstrate operating effectiveness internal control green book includes minimum documentation requirement management determines principle number management support determination documentation includes rationale absence associated component could operated paragraph management develops maintains documentation internal control paragraph management document policy internal control responsibility paragraph management evaluates document result ongoing monitoring separate evaluation identify internal control paragraph management evaluates document internal control issue determines appropriate corrective action internal control deficiency timely paragraph management completes document corrective action remediate internal control deficiency timely paragraph comptroller advisory council standard internal control federal government honorable chair department office inspector general brett baker national science office inspector general lisa casias department commerce carole clay department state melinda decorte crowe horwath stephen eells jersey office legislative office state auditor carol eyermann national science foundation bill hughes morganfranklin consulting scot janssen kpmg john kaschak pennsylvania office bureau audit david landsittel committee sponsoring organization treadway commission honorable samuel condor international kenneth mory city texas murrin ernst young annette pridgen jackson state university sandra richtermeyer xavier university neil ryder department justice peggy sherry department internal revenue service michael taylor hanover county virginia david moll commonwealth virginia office state comptroller david zavada kearney company project team steven managing director james director robert chief accountant jacquelyn deputy assistant general counsel kristen assistant director grant senior auditor christie senior auditor staff acknowledgment addition project team named also contributing francine marci peter brian debra heather jason judy william alan mary arnold mary doris kimberly glossary following term provided assist clarifying standard internal control federal relevant paragraph number provided application control control incorporated directly computer application purpose confidentiality transaction data application application control include control master data management system control paragraph attribute additional information provides explanation principle documentation requirement effective internal control paragraph baseline difference criterion design internal control system condition internal control system specific point time paragraph competence qualification carry assigned responsibility paragraph complementary user entity control control management service organization design implemented user necessary achieve control objective stated description service identified description paragraph component five required element internal internal control component control risk control information monitoring paragraph contingency plan process defined address need respond sudden personnel change could compromise internal control system paragraph control activity mechanism enforce directive achieve objective address related risk paragraph control objective purpose specified control objective address risk related achieving objective paragraph deficiency operation control doe number allow management normal course performing assigned achieve control objective address related risk paragraph detective control activity designed discover entity number achieving objective addressing risk operation concluded corrects action entity achieves objective address risk paragraph entity level control control pervasive effect internal control entity level control include control related risk assessment control service management monitoring paragraph fraud involves obtaining something value willful misrepresentation paragraph general control policy procedure apply large segment information general control include security logical physical configuration segregation contingency planning paragraph green book commonly used name standard internal control federal government foreword information system technology management organizes dispose information paragraph information technology technology enabled information process paragraph inherent risk risk entity prior considering response risk paragraph internal control process effected oversight personnel provides reasonable assurance objective entity achieved paragraph internal control system continuous built component effected provides reasonable absolute objective achieved paragraph role position organizational structure assigned overall responsibility entity paragraph likelihood occurrence level possibility risk occur paragraph magnitude impact severity deficiency could result risk affected factor duration impact paragraph management personnel directly responsible activity including operating effectiveness internal control system paragraph must denotes requirement management must comply requirement component internal control paragraph organizational structure operating operational structure management us achieve objective paragraph oversight body responsible overseeing operation internal control system paragraph performance measure mean evaluating performance achieving objective paragraph policy statement responsibility operational objective related control activity operating effectiveness paragraph preventive control activity designed prevent entity failing achieve objective addressing risk paragraph principle fundamental concept integral operating effectiveness associated component paragraph qualitative objective objective management need design performance measure indicate level degree milestone paragraph quality information information relevant reliable data provided timely meet identified information requirement paragraph quantitative objective objective performance measure targeted percentage numerical value paragraph reasonable assurance high degree number absolute confidence paragraph reporting line communication internal level organization provide method communication flow around organizational structure paragraph residual risk risk remains response inherent risk paragraph risk possibility event occur adversely affect achievement objective paragraph risk tolerance acceptable level variation performance relative achievement objective paragraph security management information process control activity related access right information technology paragraph segregation duty separation accounting operation paragraph service organization external party performs operational process entity paragraph denotes principle requirement management must comply except rare circumstance requirement number relevant entity paragraph succession plan process address need replace competent personnel long term paragraph transaction event occur financial process paragraph transaction control activity action built directly operational process support entity achieving objective addressing related risk paragraph please print recycled government accountability investigative exists support congress meeting constitutional 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