Instructions: The may be used to document a review of the existing procedures and activities that make up your internal control system, or serve as a guide in developing additional controls. The provides examples of procedures or tasks to consider as part of your accounts payable internal control system. The checklist is merely a guideline of some control activities. This checklist should be used in accordance with your company s finance and accounting policies. The types and implementation of internal controls in your company will depend upon the size of your organization, industry, and internal resources. The checklist is organized based on functional areas within a generic AP department. Tailor the controls on this list to suit the particulars of your company. Each area also has blank input fields that allow you to add other controls unique to your organization. Definitions Procedure/Activity Enter the procedure or task description. Responsibility Enter the name of the person or department responsible for the procedure or task. Enter the date the procedure or task was last reviewed. Other Comments Enter any other comments about the procedure or task; this could also include action items and any notes for the next review. www.app2p.com
INCOMING MAIL Control Objectives: (1) Separation of Duties (2) Control date of receipt for payment processing benchmarking. Incoming mail is date-stamped upon opening, documenting the date received. Vendor statements are routed to the AP manager and another designated manager who is not involved in the daily AP operations to review past due amounts.
NEW VENDOR SET-UP/MAINTENCE Control Objectives: (1) Separation of duties (2) Accuracy of data (3) Prevent irregularities by restricting access authorized personnel (4) Compliance with federal and state regulations New vendors are set up from the New Vendor Set-Up form and are preapproved by authorized personnel documented on the form. Vendor master file access is restricted to authorized employees documented in the company policy. All new vendors are required to provide signed certified Form W-9 or equivalent document prior to set-up in the system. All vendors are assigned a taxpayer ID and flagged as to whether they are subject to 1099 reporting. All recurring payments have a signed contract on file with a copy of the payment schedule. Certified taxpayer IDs are matched to the IRS TIN Matching program. Vendor payment limits are flagged in the system for a maximum per-payment value. Vendor address, phone number and other contact information is periodically checked by someone outside of the AP function to verify vendor data accuracy and validity. All repeat payment vendors (e.g. landlords, equipment lessors, etc.) are set up in the vendor master file with a start and end date, amount, payment interval and account distribution.
INVOICE PROCESSING Control Objectives: (1) Separation of duties (2) Accuracy of data (3) Prevent errors or irregularities (4) Detect unauthorized transactions (5) timely processing Cost centers are documented on invoices to distribute charges to the appropriate control account. All invoices are approved before being entered into the system. The numerical accuracy of the invoice is checked. Invoices for the purchase of inventory materials are matched to a purchase order and receiving report. Invoices for the purchase of services are matched to a purchase order in accord with the limits set by company policy. Recurring vendor invoice payments (e.g. rents, utilities, etc.) are reviewed and approved prior to processing. Invoice quantities, prices and terms are compared to those on the purchase order. Invoice quantities are compared to those on the receiving report. All invoices have a purchase order reference number or other reference to identify the employee who initiated the transaction. All invoices are received in a central location before distributed to processors.
INVOICE PROCESSING - Continued Copies of the purchase orders and receiving reports are received in a central location and accounted for numerically. Progress payments with contractors are approved and compared to the payment schedule in the contract prior to entry into the system. The number of invoices and total processed in a batch are compared to a system edit report. Unmatched purchase orders and receiving reports are researched in a timely fashion. Accuracy of account distribution for transactions entered into the system include: * Regular reviews of expense distribution * Reconciliation of expense distribution per the sub-ledger system versus the general ledger account A list of personnel authorized to approve expenditures and their limits is provided by the offices of the CEO & CFO. Maintenance of the list of personnel authorized to approve expenditures is performed by the manager of the accounting department. All reimbursements for employee travel and other business expenses are within the dollar limit in accordance with company policy and have requisite approval.
INVOICE PROCESSING - Continued A supervisor or manager reviews vouchered invoices for approval, completeness and accuracy. For a system check of quality control, selected invoice data is re-entered by a quality-control employee who is not the accounts payable data entry employee. Invoices lacking approval are routed back to the appropriate department and correspondence is sent to the vendor. Invoices are entered into the system from original documents. Vendor invoices subject to sales and use tax are properly charged to the sales tax control account. The appropriate personnel are promptly notified of differences between the invoice and the purchase order. Team members are assigned responsibility to monitor and take all appropriate vendor discounts. Preparation of the payment disbursement file is performed by separate personnel from those who perform data entry and vendor file maintenance/set-up. Vendor credits listed on monthly statements are reconciled to the vendor account in the system. The accounts payable invoice processors have a complete and accurate listing of repeat payment requests.
INVOICE PROCESSING - Continued Internal signature card is on file for all employees who are authorized to approve vendor invoices. Spot check signature authorizations on vendor invoices and compare to the signature card on file.
DISBURSEMENT PROCESSING Control Objectives: (1) Separation of duties (2) Accuracy of data (3) Prevent and detect unauthorized use of assets (4) Safeguard company assets (cash via check stock..) All disbursements processed are attached to the original invoice support for review. All disbursements are reviewed by a manager independent of accounts payable. (e.g., controller, VP finance, accounting manager, etc.) For checks signed via a check-signing machine, a numerical check log is maintained, reviewed and initialed by an independent manager. The check log compares the number of checks processed against the number of signature impressions per the signing machine. The check-signing machine is restricted to authorized personnel. The check-signing machine requires two independent persons to activate the machine with password codes. There is a stated dollar limit on checks that requires a second signature if exceeded. Check signature cards at the bank are updated as necessary when personnel leave the company or are no longer authorized to sign. Signature plates are kept in the custody of designated personnel and restricted so that use of the plates requires check-out and in. All ACH electronic payment files are reviewed and approved by designated personnel prior to release.
DISBURSEMENT PROCESSING - Continued All manual checks are accompanied by invoices and supporting documentation prior to signing. All manual checks are documented in the check log. All invoices paid are documented as cancelled and paid. Check remittance advice stubs are attached to paid invoices. Checks prepared as payable to "cash" or "bearer" are prohibited. The control total of the value disbursed is compared to the check register amount. All voided checks are defaced with VOID on the check and the signature portion also defaced or removed. All voided checks accounted for numerically and also provided to the check signer at the time of review and approval. Check Stock Security features: * All checks have a stale date on the face of the check near the amount.
DISBURSEMENT PROCESSING - Continued * All checks have micro printing in either the border of the check or the signature line. * All checks have a VOID pantograph that appears when a check is copied. * All checks have a paper stock to allow for "laser lock" printing. * The check stock is printed with a prismatic color scheme that changes color hues across the face of the check. * If checks are pre-numbered, there is a log identifying the check sequence on hand versus issued for printing. * If the check number and bank MICR information (i.e., check number, routing number, account number) is printed from a laser printer, the laser cartridge is secured with restricted access. * Blank check stock is secured in a restricted area and only accessible by authorized personnel. All signed and reviewed checks are routed to the mail room personnel who are independent of the persons requesting, preparing and recording the transaction.
OUTGOING MAIL Control Objectives: (1) Separation of duties (2) Prevent unauthorized use of payments (3) Safeguard company assets. All processed checks are inserted into envelopes by personnel other than the persons who requested, processed and prepared the transaction. All checks ready to be mailed are secured in envelopes and distributed to a central location in the mail room. Checks not placed in the mail on the same day they are received from accounts payable are returned to a secured location until mailed. Vendor checks are never distributed to requestors; all vendor checks are distributed via the mail.
VENDOR DEBIT BALANCE & CUSTOMER REFUNDS Control Objectives: (1) Prevent and detect errors and irregularities in vendor accounts (2) Accuracy (3) Detect unauthorized transactions All check requests for customer refunds have supporting documentation approved by the manager. Each customer refund request has a reason for the payment. The account distribution is documented for each customer refund request. Authorized personnel who review customer refund requests have restricted inquiry access to the customer's account to verify accuracy and validity. All vendor debit balances are reconciled to vendor account statements. Vendor correspondence is kept on file for validity, status and collection of vendor debit amount. Write-offs of debit balances are approved and performed independently from the person requesting, processing or paying the vendor. All vendor debit balances have documentation supporting the reason for the amount.
SYSTEM SECURITY Control Objectives: (1) Separation of duties (2) Prevent unauthorized use of payments (3) Safeguard company assets. Access to the AP system is password restricted for all personnel. Passwords are required to be changed every 90 days. Passwords require a combination of alpha and numeric characters. Access to the AP system is restricted to authorized terminals. Access within the AP system modules is restricted by user ID. A list of users of the AP system is provided to managers of each group and updated based on personnel turnover. An organizational chart is maintained and updated for personnel turnover. System controls are used to restrict changes to master data files that require approval. System user controls reject unauthorized transactions. A user control report is generated periodically to review rejected transactions.
SYSTEM SECURITY - Continued Rejected transactions are held in a suspense file for review. Edit-control reports are regularly generated and reconciled for processed transactions, to review the reasonableness of outputs and balances. The IT department receives audit alerts for unauthorized access. There are system controls on data entry, including: * A check for duplicate invoice reference numbers * A check for invalid vendor IDs * Field edit checks for improper entry of characters * Edits for improper account distribution * Warning edits for amounts exceeding limits * Warning alerts and reports for security override * Two independent persons with a pass code combination are required to allow system overrides
SYSTEM SECURITY - Continued Each terminal has "time out" security so that computers left idle for a period of time sign off the user. User access is prohibited to the system source code. There is a regular back-up of all AP system data for record retention. Archived system data is stored off-site in a secured location with restricted access to authorized personnel. Insurance coverage includes equipment, software and data. The insurance coverage is active. There is a written disaster recovery plan document that outlines the retrieval of system data and records. The disaster recovery plan is tested on an annual basis at least. The system archives real-time transactions to protect against loss of important files and programs. All security password codes are unique and not shared among employees.
SYSTEM SECURITY - Continued Security codes to the AP system are deactivated for all personnel who have terminated employment. Access codes and keys are changed when personnel terminate employment, as applicable.
SEPARATION OF DUTIES Control Objectives: Prevent collusion and override of controls Responsibilities for the requisition, purchase and receiving are separated from invoice processing and disbursement. Responsibilities are separated for the setup of new vendors, invoice processing and disbursement preparation. Responsibilities are separated for the reconciliation of accounts payable balances from invoice processing, vendor set-up and disbursement preparation. Responsibilities for disbursement preparation are separated from the approval function. Responsibilities for the processing functions in accounts payable are separate from those in the general ledger. Responsibilities for the disbursement preparation in accounts payable are separate from responsibilities for the general ledger. Bank reconciliations are performed by persons independent of the accounts payable function. The IT department is independent from the accounts payable and general accounting functions. All account reconciliations are reviewed by persons independent of person doing the actual reconciling function. An organizational chart is maintained and updated for management by function within the AP department.
SEPARATION OF DUTIES - Continued The system administrator that grants access to the AP system is independent of the AP function. Sales and use tax returns and escheatment property tax returns are performed by persons independent of the AP function.
1099 INFORMATION RETURN REPORTING Control Objectives: Compliance with federal, state and local laws All applicable vendors are flagged in the New Vendor Set-Up for 1099 reporting. Correspondence is circulated on a regular basis to vendors who have not certified their taxpayer ID. Vendor payments are only processed after receiving Form W-9 or a substitute form certifying the taxpayers ID and tax withholding status. Vendors subject to 1099 reporting are reviewed by personnel independent of the processing and disbursement functions in accounts payable. All Forms 1099 are submitted to the applicable vendors before January 31. All applicable 1099 Informational Returns are filed in accordance with the reporting deadlines. 1099 Planning Calendar
SALES & USE TAX Control Objective: (1) Compliance with federal, state and local laws (2) Accuracy of disbursements to govt agencies Products and services purchased from vendors are identified as to their tax status. A list of items and taxing jurisdictions is circulated among the appropriate personnel. Sales and use tax returns are prepared by persons independent of the accounts payable function. A monthly schedule of sales and use tax disbursements is circulated to designated accounts payable personnel. The set-up and maintenance of the rates by jurisdiction is separate from the accounts payable function. All disbursements to tax agencies are supported with the sales or use tax return.
RECONCILIATIONS Control Objective: (1) Detect errors or irregularities in financial records (2) Accuracy of financial transactions and account balances (3) Prevent unauthorized transactions Account reconciliations are performed each month. All reconciliations are reviewed and initialed by persons independent of reconciling the accounts. A list of all reconciling items is maintained with the month end financial reporting. Old items noted on the reconciliation are researched. All items written off from the account reconciliation are pre-approved by a manager independent of the accounts payable function. Adjustments to account balances arising from the reconciliation are performed by persons independent of the accounts payable function.
ACCRUED EXPENSES Control Objective: (1) Accuracy of the financial records (2) Prevent unauthorized transactions in the financial records There is a published cut off date for processing invoices to the current period in the AP system. There is a system control activated to reject the entry of an invoice into a prior period that has been closed. All unmatched receiving reports are compiled and a value determined from the corresponding purchase order. A list of received but not processed invoices is compiled at the end of a reporting period. The adjustments to account balances for accrued expenses are performed by persons independent of the accounts payable function. All accrued expense control account balances are reviewed by managers independent of the persons preparing the accruals.
EMPLOYEE/PERSONNEL Control Objective: Safeguard company assets All personnel are subject to background checks prior to being hired. Regular reviews are performed with each employee. Responsibilities are clearly stated in job descriptions for each employee. All employees are required to take their allotted vacation time. Key processing personnel are covered under a fidelity bond. All positions within the accounts payable function have job descriptions. An organizational chart is maintained and updated noting the names and titles of all personnel. When employees leave the organization, they go through an exit interview. All keys and other company property that gives access are returned by the employee upon termination.
GRANTS, ENCUMBRANCES & OTHER ENTITLEMENT PROGRAMS Control Objective: (1) Prevent unauthorized use of funds (2) Compliance with fiduciary duty (3) Detect errors or irregularities in accounts and transactions All grant disbursements are accompanied with the approved application. Correspondence is circulated to persons awarded grants as outlined in the grant program and federal or state compliance regulations. Grantee disbursements are monitored for proper compliance with the grant terms. Missing financial compliance reports are researched on a timely basis to reestablish compliance. Grantee disbursements are terminated for noncompliance per the terms of the grant. Grantees are required to file a statement of compliance with the conditions of the entitlement program. An encumbrance disbursement report is circulated to department heads for review of proper account distribution. A published list of restricted fund donations is circulated to the appropriate accounts payable personnel. Encumbrance reserves are reconciled monthly.