Internal Control Program
Providing reasonable assurance that our campus uses its resources (including its human resources) to address established objectives and goals and take steps to decrease the risk.
Why Internal Control?
Internal controls provide reasonable assurance that an organization uses its resources — including its human resources — to address established objectives and goals and take steps to decrease the risks to the organization. While it is the law that the college has an internal control program, it also makes good sense for the college to operate as efficiently as possible.
If we do not have internal controls in place, we could lose resources and opportunities. Such losses could prevent us from fully meeting our goals and objectives and negatively impact our mission.
In 1987, The New York State Governmental Accountability Act was enacted to formalize a system of productivity and accountability in all state agencies including SUNY campuses. The Act included provisions for strengthening campus internal controls and for measuring their effectiveness. Agencies received the following mandates:
- Establish and maintain guidelines for a formal internal control program.
- Establish internal control reviews for departmental managers to identify risks, weaknesses and corrective actions.
- Ensure that all employees understand the concept of internal control and their respective roles and responsibilities.
- Formally state the organization’s policies and standards for all employees.
- Determine the manner of fulfilling the internal audit function.
- Designate an internal control officer to coordinate the program.
As required by law, SUNY Plattsburgh must annually certify that its Internal Control Program is in compliance with the Internal Control Act. In addition to the six standard requirements, the state may, from time to time, identify additional activities campuses are expected to complete as part of the on-going internal control program.
Since internal control depends on the participation of all employees at every position level, all employees should be aware of the college’s goals and their participating roles in attaining those goals. They should routinely exercise judgment and act to protect the institution and its resources from loss, waste, or damage. All employees need to exhibit the personal and professional traits of the responsible and productive person in seeking areas for improvement and acting in the best interests and protection of the institution and the public.
The success of an internal control program depends upon good communication throughout the organizational structure.
Often the best manner of evaluating operational and program effectiveness is at the unit (department) level. Program reviews and critical area testing may be employed.
Identified weaknesses and recommendations for corrective action or general improvement should flow smoothly through the organizational structure with thorough review and response at each succeeding level.
Acknowledgment and further communication (feedback) to the operating level will confirm the extent of the noted weakness and the best corrective course of action.
It is this two-way communication which best serves to address issues and concerns in a timely manner and to reach solutions, benefiting from both the first-hand skills at the departmental level and the collective knowledge and resources of the institution.
The principles of internal control, executed by whatever manner or approach, ensure the best possible service to the college's students and clientele in the most cost-effective manner. The cost-benefits to SUNY Plattsburgh will be real and measurable.
As members of a New York State public tax-supported institution, we all serve as stewards of the public trust. The citizens of the State expect that quality education, research, and public service will be provided through the best utilization of resources provided. It is our responsibility to fulfill that public trust.
Internal controls are daily operating practices and procedures that minimize the possibility of inappropriate use of resources; loss, waste or damage of resources; overspending; or other actions inconsistent with policy or in violation of law. Simply stated, the college's Internal Control Program is designed to review, critique, and strengthen existing systems and procedures.
The Internal Control Program at SUNY Plattsburgh is comprised of several major internal control systems. Elements of the college's internal control systems that affect the daily operation and management of SUNY Plattsburgh include, but are not limited to:
- External (federal, state, and local) laws, regulations, policies, and procedures
- Regulations/requirements of accreditations associations (Middle States, etc.)
- Policies of the SUNY Board of Trustees
- Executive Council policy statements
- Approved Faculty Senate policies and bylaws
- Agreements with UUP, CSEA and other labor unions
- Statements of policy and procedure in the College handbook and/or catalog
- Student registration, billing, and payment procedures
- Personnel procedures
- Employee performance programs/evaluations
- Time and attendance reporting
- Property (equipment) control Financial and operational procedures
- Electronic data and network security
- Public safety, environmental safety, code compliance practices
- Service contracts, revocable permits
- Building door lock systems and key control
- Student and employee identification cards
- Department and program specific policies and procedures
- Internal Control Memo — October 1, 2023
A memo from Interim Vice President for Administration and Finance Todd Moravec:
October 1, 2023
As public employees, we have a responsibility to ensure that we are safeguarding college resources and being good stewards of the public trust.
Guiding us in these efforts are our internal controls. Internal controls are the activities that we engage in to ensure the college’s resources are used effectively and efficiently. These activities minimize inappropriate use of resources; loss, waste or damage of resources; overspending; or other actions inconsistent with policy or in violation of law.
Examples of our internal controls in action include:
- Conducting timely employee performance evaluations, including updating performance programs and job duties.
- Annual physical inventories of equipment
- Monthly review of accounts by account owners to determine if expenditures remain on track
- New employee training
- Physical control over assets (e.g. locks on doors)
- Separation of duties in the purchasing and payment processes
- Supervisor pre-approval of transactions (e.g. purchases, travel authorizations)
- System access controls (such as passwords)
- Updating policies and procedures
Internal controls help us to ensure that precious resources are aligned with and support achievement of our mission and mitigate risks that could impede our progress.
What You Can Do
- Familiarize yourself with our Internal Control Program.
- Follow campus policies and procedures, as well as those in place for your job.
- When assigned, complete your compliance training.
- If asked, participate in an internal control review or risk assessment.
- Communicate problems, ask questions and suggest improvement to your supervisor or department chair.
- Use college resources only in support of our goals, objectives and programs.
What To Do If You Suspect A Problem
There can be occasions when faculty, staff, students, community members intentionally or unintentionally misuse state funds, equipment and supplies or participate in unethical activities or practices. If you suspect or know of such actions, you can make a report to the anonymous internal control hotline (voice mailbox) at 866-633-6112. If you notice something unusual, report it. Learn more about the internal control hotline
Should you have questions about the Internal Control Program, please contact Todd Moravec, Internal Control Officer (ICO), at 518-564-4061 or Lauren Currie, Internal Control/Risk Management Officer, at 518-564-2538.
Internal Control Committee
Internal Control Positions
- Internal Control Officer
Internal Control Officer (ICO)
The internal control officer spearheads the college’s Internal Control Program. The internal control officer at SUNY Plattsburgh is:
Todd Moravec, Interim Vice President for Administration and Finance and Internal Control Officer
The ICO is responsible for:
- Monitoring and evaluating the organization’s overall internal control system.
- Coordinating the development and implementation of the college’s Internal Control Program.
- Monitoring identified weaknesses and required corrective actions.
- Ensuring that employees are informed of applicable policies and receive appropriate training in internal control.
- Reporting to the president on the college’s overall internal control system
- Completing central administration required reporting requirements.
- Internal Control/Risk Management Officer
Internal Control/Risk Management Officer
This Internal Control/Risk Management Officer is responsible for overseeing the work of the Internal Control Committee. The Internal Control/Risk Management Officer at SUNY Plattsburgh is:
Lauren Currie, Internal Control/Risk Management Officer; Administration & Finance
- Internal Control Committee
SUNY Plattsburgh has established an Internal Control Committee that is responsible for monitoring, testing and reporting to the internal control officer about the college’s internal controls.
The Internal Control Committee is composed of individuals from a cross section of campus departments and offices. The membership on the Internal Control Committee may increase or decrease depending on the tasks undertaken at any time.
Internal Control Committee Members
- Lauren Currie, Internal Control/Risk Management Officer
- Dave Gregoire, Assistant Vice President of Institutional Advancement
- Tiffany Kirk, Facilities Accountant, Facilities, Maintenance, and Operations
- Michael Morales, Director, Center for Neurobehavioral Health
- Todd Moravec, Interim Vice President for Administration and Finance
- Trisha Pellerin, Campus Housing Director, Campus Housing and Community Living
- Magen Renadette, Director, Budget & Financial Reporting Services
- Michael Simpson, Director of Sponsored Research
- Segmentation of the College
The first step in the internal control process is the segmentation of the college. Segmentation is the process of identifying the programs and administrative functions necessary for the campus to carry out its mission. Functions identified through this process are called “assessable units” and provide the framework for the Internal Control Program.
- Risk Assessment
After the campus is segmented into assessable units, the risk of each unit (division, department, office, center) is then assessed. This process is done through a self-assessment survey or a one-on-one discussion between the unit manager and member(s) of the Internal Control Committee. Some of the factors examined in the risk assessment are: inherent risk of the unit, management's attitude toward internal controls, physical location, frequency of review, and the rate of personnel turnover. The information provided in the risk assessment allows the Internal Control Committee to evaluate the campus’s susceptibility to conscious or unintended abuses and to determine how to improve operational efficiencies.
- Internal Control Review
Depending upon an assessable unit’s rating, the Internal Control Committee may conduct a review of a unit’s procedures and policies to insure they are functioning as intended and that they assist the unit in meeting its goals and objectives. Examples of procedures and policies that may be reviewed include, planning activities, program evaluations, the budget cycle, personnel transactions, and information systems, cash activities, contract management and capital programs.
Upon completion of the internal control review, the Internal Control Committee may make recommendations to the unit. The recommendations may require adding, deleting or changing internal controls or procedures for the unit. If recommendations are accepted, a timetable for implementation is agreed upon.
- Follow-UpThe final component in the internal control process is follow-up. This step is performed to verify that the recommended actions have been properly implemented and that the unit continues to function as intended.
Another factor essential to the success of SUNY Plattsburgh’s Internal Control Program is adequate training in the area of internal controls. Training should familiarize employees with the objectives of the internal control program, how it operates and the benefits it provides.
The Internal Control Committee will oversee development of a training program that will help all employees understand the importance of their role in the campus’s system of internal controls.
The internal control/risk management officer is responsible for reporting to the internal control officer on the status of the college’s internal control plan, review of procedures and policies and recommendations to lower ratings. The Internal Control Committee is responsible for assisting the internal control/risk management officer in preparing the reports.
- State Government Resources
- Standards for Internal Control in New York State Government
- Internal Controls Online Training Course
- Governmental Internal Control and Internal Audit Requirements - New York State Division of the Budget
- NYS Internal Control Task Force
- New York State Office of Information Technology Services
- New York State Internal Control Association
- SUNY Internal Control Program
- NYS Division of the Budget, Budget Policy and Reporting Manual Item B-350
- Access to State Agency Records- External Audits, NYS Public Officers Law §87(2)(g)(iv) (Freedom of Information Law)
- Federal Government Resources
- Association Resources