OVERSIGHT Basic Enhanced Best Practice Barriers ONGOING DATA GOAL: PROACTIVELY IDENTIFY POTENTIAL AREAS FOR FRAUD OR RISK OF FRAUD REVIEW FOR ANOMALIES Strategy Periodic data review of Ongoing data review of Ongoing data review of • cost subgrantees and desk or subgrantees to determine if subgrantees with annual • staffing on-site monitoring every on-site monitoring is required. monitoring. • adequate data systems year. • skill set • lack of protocols and procedures Initial Cost high high high Operational Cost moderate moderate - high high Client Burden low low low INTERNAL GOAL: ENSURE SYSTEMS CAN IDENTIFY, ANTICIPATE AND PREVENT RISK TO PUBLIC RESOURCES CONTROL FRAMEWORK (ICF) Set of standard operating Set of standard operating Set of standard operating • support of leadership procedures in line with procedures in line with procedures in line with • funding applicable OMB circulars. applicable OMB circulars. applicable OMB circulars. • resources and staffing Comprehensive ICF that has Comprehensive ICF that has • acquiring knowledge Committee of Sponsoring COSO standards. ICF is Organizations (COSO) regularly reviewed and standards. updated. Initial Cost low - moderate high moderate Operational Cost low moderate high Client Burden low low low
OVERSIGHT Basic Enhanced Best Practice Barriers ONGOING DATA REVIEW FOR ANOMALIES GOAL: PROACTIVELY IDENTIFY POTENTIAL AREAS FOR FRAUD OR RISK OF FRAUD Strategy Periodic data review of subgrantees and desk or on-site monitoring every year. Ongoing data review of subgrantees to determine if on-site monitoring is required. Ongoing data review of subgrantees with annual monitoring. • cost • staffing • adequate data systems • skill set • lack of protocols and procedures Initial Cost high high high Operational Cost moderate moderate - high high Client Burden low low low INTERNAL CONTROL FRAMEWORK (ICF) GOAL: ENSURE SYSTEMS CAN IDENTIFY, ANTICIPATE AND PREVENT RISK TO PUBLIC RESOURCES Set of standard operating procedures in line with applicable OMB circulars. Set of standard operating procedures in line with applicable OMB circulars. Comprehensive ICF that has Committee of Sponsoring Organizations (COSO) standards. Set of standard operating procedures in line with applicable OMB circulars. Comprehensive ICF that has COSO standards. ICF is regularly reviewed and updated. • support of leadership • funding • resources and staffing • acquiring knowledge Initial Cost low - moderate high moderate Operational Cost low moderate high Client Burden low low low