Internal Control Policy Manual SCHOOLS
Internal Control Policy Manual SCHOOLS
Internal Control Policy Manual SCHOOLS
INTERNAL CONTROL
MANUAL
Oak Ridge Schools Internal Control Manual (Revised 5/31/17) 1
Revised 5/31/17
Table of Contents
Introduction ................................................................................................................................. 3
Three Objectives of Internal Controls ........................................................................................ 3
Five Main Components of Internal Controls That are Required to be Addressed
Monitoring .................................................................................................................................. 19
Summary .................................................................................................................................... 21
Monitoring .................................................................................................................................. 21
Oak Ridge Schools Internal Control Manual (Revised 5/31/17) 2
Oak Ridge Schools Internal Control Manual (Revised 5/31/17) 3
INTRODUCTION
Oak Ridge Schools has the responsibility to its taxpayers, ratepayers, and constituents to
be good stewards of public monies and property. In our efforts to serve the public as Oak Ridge
Schools Board Members or Employees, Oak Ridge Schools established this Internal Control
Manual using state and federal directives, and widely recognized best practices
The internal control system consists of three objectives and five main components.
1. Reporting – reliability
2. Operations – effective and efficient
3. Compliance – compliant with applicable laws, regulations, contracts and grant
agreements
1. Control Environment
2. Risk Assessment
3. Control Activities
4. Information and Communication
5. Monitoring
The purpose of this manual is to ensure that the objectives of reporting and compliance
are established. The policies to achieve these objectives are derived from various financial best
practices, state and federal laws, and regulations. Policies may be developed to suit the specific
needs of Oak Ridge Schools’ functions and resources. Detailed procedures are developed and
documented as a means for entities to comply with its established policies.
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CONSIDERATIONS IN DEVELOPMENT OF
INTERNAL CONTROLS
Constant monitoring of all components will ensure that the ICS (which must be reviewed
and updated at least annually) is revised whenever changing conditions justify.
Since Oak Ridge School District’s policies and procedures are the control activities for its
internal control plans, it is important that they be reviewed in conjunction with the plans and
referenced where appropriate. Everyone within the Oak Ridge Schools District has a
responsibility to ensure that internal controls operate effectively.
As directed by T.C.A. 9-18-102 (a) and in accordance with the guidance issued by
Tennessee Comptroller’s Office, the Oak Ridge School District has adopted this internal control
manual. It is critical to note that the development and operation of the internal control system
involves everyone in the organization. As such, management must ensure that the manual is
shared with all of its employees. The manual is a work in process and will be assessed periodically.
The following sections document the five components of internal control and significant
financial and compliance areas that are deemed high risk.
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CONTROL ENVIRONMENT
Overview
The control environment is the foundation for all other components of internal control,
providing discipline and structure. Moreover, management establishes the tone regarding the
importance of internal control and the expected standards of conduct; and reinforces those
expectations at various levels. Control environment factors include the integrity, ethical values
and competence of Oak Ridge Schools’ District personnel; the distribution of authority and
responsibility; the development of its personnel; and the attention and direction provided by the
governing body.
Objectives
1. The governing body and management should conduct business with integrity and ethical
behavior.
2. The governing body and management should provide direction and oversight for Oak
Ridge Schools’ internal control system.
3. The governing body and management should hire qualified and competent employees.
4. The governing body and management should establish structure, authority and
responsibility to hold individuals accountable for internal control responsibilities.
Policies
1. Conflicts of interest must be disclosed before business is conducted.
2. A code of Ethics has been adopted by the Board of Education and management and is
reviewed annually with all employees.
3. The Board of Education has adopted a policy manual.
4. The Board of Education uses the budget process as a means of oversight with department
heads.
5. Organizational charts are reviewed for needed changes in regards to authority and
responsibility.
Procedures
If there is a conflict of interest, the disclosure statement from the policy manual must be
completed and signed in front of a witness and given to the appropriate supervisor.
• The policy manual and corresponding forms are available to all employees and board
members on the Oak Ridge Schools’ website.
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• The Board of Education formally adopts an annual budget. The adopted budget is given
to the City for approval by the City Council.
• Oak Ridge Schools adopted a Board of Education Policy Manual based on TSBA
guidelines. Those policies are reviewed and updated annually by the Board of Education.
• Monthly, the policy review committee reviews current policies and submits their
findings to the Board of Education.
• Based on legislative changes, TSBA provides recommended policy updates.
• The Board of Education has adopted a personnel policy related to the recruitment and
retention of highly-qualified employees for the Oak Ridge Schools District.
• All positions shall be approved through the budget process in accordance with the
organizational plan submitted by the Superintendent.
• Oak Ridge Schools’ organizational chart is available on the system website and included
in this manual to establish a defined chain of command.
• All positions require a job description and copies shall be maintained in the Executive
Director of Human Resource’s office.
• All Oak Ridge Schools’ employees are required to complete annual online training and
are encouraged to obtain additional professional and/or continuing education credits.
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RISK ASSESSMENT
Overview
Oak Ridge Schools’ officials and management assess the risk of operations continually.
The Oak Ridge Schools’ has chosen to transfer the most common types of risk through the
purchase of the following types of insurance:
There are some risks that cannot be anticipated as they relate to financial and compliance
issues. We have assessed the following areas and identified certain risks that necessitate the
development of internal control policies and procedures. Internal controls will not eliminate all
risk but will help reduce risk to gain reasonable assurance that reporting and compliance objectives
are met.
Objectives
1. Collections are complete, timely and accurate.
2. Disbursements are for valid Oak Ridge School District purposes and are properly
recorded.
3. Assets are properly safeguarded.
4. Oak Ridge Schools is incompliance with contractual, local, state and federal laws and
regulations.
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Disbursements/Drafts
• Broken law – expenditures must be appropriated
• Owing late fees and penalties
• Improper reporting in financial statements; inaccurate reporting for the governing body –
monthly budget vs actual
• Possible loss of school district funds; inappropriate disbursement; theft malfeasance
Safeguarding Assets
• Misuse or loss of assets, not just capital assets (i.e. checking accounts, investment
accounts, etc.).
• Payback of grant funds
Reconciliation of Accounts
• Misuse or loss
• Missing entries
Control of Investments
• Lower than expected rates of return
• Assessed liability for OPEB investment fund subject to change based on school district
policy
Debt Management
• Debt issuances not in compliance with state law
• Violations of the policies of the City Charter
• Additional effort with the annual budgetary practices
• Potential for defaulting on principal and interest payments
Grant Management
• Grant requirements may have changed
• The Accountant is not made aware of the grant transactions
The significant areas of risk are identified above and policies and procedures will be
documented in the next section to explain how Oak Ridge School District plans to implement
internal controls to help reduce the risks associated with these areas of operations.
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District Business Services Department Organizational Chart
District Accountant
Grant Accountant
Business Services
Specialist
Supervisor of
Payroll Specialist
Business Services
Purchasing
Specialist
Accounts Payable
Specialist
Courier and Fixed
Assets Specialist
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CONTROL ACTIVITIES
Overview
This section is where detailed implemented procedures are documented. The objectives,
policies; and procedures are described for each of the significant areas identified in the Risk
Assessment section.
COLLECTIONS (GENERAL/ACH)
Objectives
Policies
Procedures
For District Funds Collected at School Locations
• Each person involved in the receipting process must have their own cash drawer.
• All monies collected are receipted on pre-numbered receipts.
• Money receipted at the school is counted by the employee who collects the funds and
initials for accuracy. Money is then turned into the School Bookkeeper, who counts and
prepares the deposit.
• Deposit slips are prepared in duplicate and initialed by the Bookkeeper; other personnel
takes all school deposits to the bank.
• Funds are deposited daily if possible, but no later than three (3) days after receipt. If funds
are kept at school overnight, they must be kept in a secure location.
• Once deposit has been made, the bank receipt is given to the Bookkeeper and attached to
the duplicate deposit slip.
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• The Bookkeeper sends the deposit slip to the Business Specialist in the District Office who
assigns the proper revenue code and forwards to the District Accountant to receipt it to the
G/L in the proper revenue code.
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DISBURSEMENTS/DRAFTS
Objectives
1. Disbursements are for a valid school system purpose and are necessary.
2. Disbursements are timely.
3. Disbursements are accurately coded and recorded in the accounting system.
4. Disbursements are legally appropriated.
Policies
1. Accounts Payables (A/P) payments are processed daily or weekly, as needed.
2. More than one person reviews the A/P payment process.
3. Checks are printed using Financial Software based on approved AP Check Batches.
4. Separate employees will code invoices and PO’s, enter requisitions, and process check
files.
5. An electronic purchase order system with approval authorization groups is in place.
6. All vendor checks are mailed or deposited via ACH.
Procedures
Before purchases are made, electronic requisitions and purchase orders approved at a
minimum by the Superintendent of Schools or his Designee (an Executive Director) and
the Supervisor of Business Services. (Additionally, building principals, department
supervisors, and grant administrators are required to approve the requisition for their
location/area)
• The Purchase Order is printed and provided to the Vendor by the Purchasing Specialist. A
Goldenrod color copy is provided to the Department ordering the items.
• When purchases are received or a service is completed, the packing slips are matched with
the Goldenrod copy of the Purchase Order. The receiving department signs the Goldenrod
to acknowledge that the items or services have been received and submits it with any
backup information to the Purchasing Specialist.
• The Purchasing Specialist matches invoices with the received copy of the Purchase Order
and provides to the Accounts Payable Specialist for payment processing.
• The Accounts Payable Specialist audits the payment requests and invoices and enters them
into the financial software as a batch process.
• The Accounts Payable Specialist processes and prints the pre-check register and attaches a
calculator tape of all invoices to match the report. The report along with the AP Check-Off
List and all backup documentation for the payments (signed as being audited by the
Accounts Payable Specialist) is submitted to the District Accountant.
• The District Accountant audits the check register and supporting invoice(s) and purchase
order(s) to confirm the proper account code, vendor, invoice number, and amounts are used.
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• The District Accountant signs the AP Check-Off List (signed as being audited) and
forwards the check register and supporting documents to the Supervisor of Business
Services.
• The Supervisor of Business Services reviews the pre-check register and supporting
documentation and initials as evidence of review.
• The Accounts Payable Specialist processes the checks using the Financial Software. A
password allowing check printing is required prior to printing checks. This password is
entered on the Accounts Payable Specialist computer to approve the check printing
processing by the Supervisor of Business Services. (If the Supervisor of Business Services
is unavailable and approves, the District Accountant will provide the required password for
printing accounts payable checks)
• Once the Accounts Payable Checks are run, the Accounts Payable Specialist provides all
original checks and backup to the Supervisor of Business Services for review and
confirmation of the vendor name and amounts on the actual checks.
• The checks are then returned to the Accounts Payable Specialist for mailing and filing.
• At the end of the month, all checks are reconciled by the District Accountant. An
outstanding check register is pulled and filed with the bank reconciliation.
• At year-end, the District Accountant will review all of the previous years’ accounts, prior
year activity, and invoices received to help determine what is still outstanding.
SAFEGUARDING ASSETS
1. Ensure school system assets are properly valued and protected.
2. Ensure cash, accounts receivable and other asset accounts are reconciled.
3. Ensure school system assets are protected against loss, misappropriation or theft.
4. Ensure inventory items are available when needed.
5. Ensure inventory is necessary and reasonable.
6. Ensure all capital assets and inventories are properly recorded.
Policies
1. District Accountant reconciles all bank and investment accounts on a monthly basis within
10 days of receipt of a bank statement.
2. Bank accounts are appropriately collateralized.
3. Accounts Payable and Payroll checks are provided to the Banking Institution for inclusion
in the Positive Pay process (both for vendor name, check number, and amount) as an
additional level of security and protection
4. All bank accounts are held in the School System’s name.
5. All assets with a value of $500 or more must be tagged.
6. The School System keeps an asset and inventory log that is updated as assets are acquired
and disposed of.
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Procedures
• District Accountant reconciles all bank and investment accounts monthly and gives to
Supervisor of Business Services for review and approval.
• All reconciliations are kept in District Accountant’s office.
• All employees who handle school monies are bonded and all accounts are in the School
System’s name and properly collateralized.
• Prior to mailing checks, the District Accountant submits an electronic file to the Banking
institution for inclusion in the Positive Pay process (both by vendor name and check number
and amount)
• When new assets are acquired, the Fixed Assets Specialist or the Instructional Technology
Specialist records them on the appropriate list (inventory or capital assets). If the item is over
$500 he/she will affix an asset tag.
• When items are determined to be surplus, destroyed, or need to be sold, the Fixed Assets
Specialist or the Instructional Technology Specialist is responsible for editing the inventory
and asset logs.
• Annually, the District Accountant will review the fixed asset listing. The fixed asset list is
provided to auditors annually.
RECONCILIATION OF ACCOUNTS
1. Ensure that all bank and investment accounts are recorded and reconciled.
2. Ensure that change funds are secure and properly accounted for.
Policies
1. District Accountant reconciles all bank and investment accounts on a monthly basis within
10 days of receipt of the bank statement.
2. Any funds not immediately deposited are placed in vault for safe-keeping.
3. All accounts are accounted for in the general ledger.
Procedures
• Monthly, the District Accountant reconciles all general ledger accounts with the bank
statements.
• Supervisor of Business Services reviews and approves all reconciliations.
• All signed reconciliations are filed in the District Accountant’s office.
• Any funds not immediately deposited are counted daily and locked in vault for safe-
keeping.
• Deposits are made within the three (3) day rule and verified by multiple employees.
• All accounts (assets, liabilities, revenues, and expenditures) are listed within the accounting
software.
• The State of Tennessee’s Uniform Chart of Accounts is used, and all active account
numbers are in the accounting software.
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• Trial balances are periodically pulled and reviewed by the District Accountant and
Supervisor of Business Services.
CONTROL OF INVESTMENTS
1. Ensure investments are safe and in accordance with adopted investment policy.
2. Ensure that investments are authorized and provide for maximum returns with minimum
risks.
3. Ensure investments comply with legal requirements.
4. Insure investments are recorded accurately.
Policies
1. The Superintendent is authorized to invest excess funds of Oak Ridge Schools.
2. Interest earned shall be credited to the appropriate funds and revenue codes.
Procedures
Other Post-Employment Benefits (OPEB)
• The Board of Education approves OPEB trust contributions as part of the annual budget.
Upon Superintendent’s approval, the District Accountant issues payment to the OPEB
trust.
• The School System has an actuarial at least every two (2) years, and annually, auditors
record OPEB liability.
DEBT MANAGEMENT
1. Ensure that city, state, and federal regulations are understood and followed in regard to
issuance of debt.
2. Ensure that all grant regulations are understood and followed in regard to issuance of debt.
3. Ensure that note disclosures in the financial statements contain all required elements.
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Policies
1. All debt issuances are made in compliance with state law and City Code
2. All transfers are examined to ensure they do not meet qualifications to be classified as debt.
3. All debt issuances will only be made after approval of the Board of Education and City
Council.
Procedures
• Oak Ridge Schools complies with all legal requirements for notices and public meetings
related to issuing debt.
• In the interest of transparency, all associated costs (including interest, issuance, continuing,
and one-time) are disclosed in a timely manner.
• Professionals involved in debt transaction are required to disclose any conflicts of interest.
GRANT MANAGEMENT
Objectives
1. Ensure that all grant requirements are met.
2. Ensure that all grant transactions are properly recorded.
3. Ensure that matching funds are available and approved.
Policies
1. Every department must notify the District Accountant when a grant application is submitted
and awarded.
2. All grant applications must be approved by the Superintendent, and all grants with
matching requirements must be approved by the Board of Education prior to submission of
the application.
3. Once awarded, a detailed budget is prepared outlining the grant.
4. Grant management responsibilities are assigned to an appropriate employee for every grant.
Procedures
• Appropriate personnel complete grant application and submit to the Executive Director of
Teaching and Learning prior to Superintendent for approval. If the grant requires matching
funds or maintenance of effort, the application must be approved by the Board of Education
and budgeted for in annual budget or via budget amendments.
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• A copy of the grant application and award letter is given to the District Accountant. The
District Accountant assigns a project code specific to the grant for tracking in the
accounting system.
• The awarded grant has an approved budget detail in E-Plan and that budget is entered into
school system accounting software. If any amendments need to be made to the grant budget,
state approval is required.
• The Superintendent assigns grant management responsibilities to the appropriate
employee. Accounting office submits grant reimbursement requests. Grant reimbursements
are issued through ACH and receipted to the G/L. The grant manager reviews grant
monthly to ensure that funds are properly expended.
• District Uniform Grants Guidance and Policy Manual (UGG) is reviewed and updated
annually or as necessary.
Overview
Management has the responsibility to adequately communicate information to both internal
and external parties. It is important that employees know the objectives, policies and procedures
management has established and what the expectations are for internal controls. External
stakeholders may also seek information regarding objectives and reliable financial information.
Objectives
1. Necessary information for achieving the entity’s objectives is available and used.
2. Necessary information for achieving the entity’s objectives is internally communicated by
management.
3. Necessary information for achieving the entity’s objectives is externally communicated by
management.
Policies
1. Information maintained in a format should be communicated in that same format. For
example, if the general ledger is maintained on computer, the monthly budget to actual
reports should be provided through a computer-generated report from that software
package.
2. Reliable and accurate information from Oak Ridge Schools must be communicated to the
people who need it in a timely and useful format.
3. Because the credibility of Oak Ridge Schools, its Board of Education, and its employees is
at stake whenever information is released to outside parties, management should be
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confident the information being released is accurate and in compliance with policies and
procedures.
4. The Board of Education communicates the types of information required to achieve their
objectives and mitigate risk.
Procedures
• The staff of Oak Ridge Schools is required to submit quality information that allows the
Board of Education to make informed decisions and evaluate whether the school system is
achieving its objectives.
• Oak Ridge Schools clearly defines lines of communication through the policy manual and
organizational chart.
• The District has a written organizational chart for employees to show clear lines of
authority (who manages whom) and written job descriptions for all employees and open
positions.
• The internal control manual is available to all staff via the Oak Ridge Schools’ website.
• Oak Ridge Schools abides by Tennessee’s Open Records laws for communicating with
external parties, which includes the redaction of sensitive information.
• System generated reports pulled from various software programs are available in both
electronic and printed formats.
• Information presented to the Board of Education is provided on a monthly basis and is also
available upon request
MONITORING
Overview
The internal control system changes as technology, staff, objectives and policies change.
Management is charged with continually monitoring the internal control system to determine if it
is operating as designed and to ensure the policies are being followed.
Objectives
1. To practice activities that monitor the internal control system and evaluate the results.
2. To address deficiencies noted in the internal control system in a timely manner.
Policies
1. To ensure that internal controls do not deteriorate and continue to work as designed over
time, an annual risk assessment will be conducted by Oak Ridge Schools.
2. To establish more efficient and effective operations over time.
3. To ensure that accurate and reliable financial information is used in decision-making.
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Procedures
• Monitor internal control through built-in monitoring activities and separate periodic
evaluations and document the results.
• Evaluate differences to determine if:
1. Changes in internal control have occurred but have not been documented
2. Internal control has not been properly implemented
3. Internal control design changes are needed.
• All accounts with financial institutions (checking, savings, investment, etc.) will be
reconciled to the general ledger within 10 days of receipt of any statement from the
financial institution.
• The above reconciliation will include a listing of outstanding checks and will be reviewed
by the Supervisor of Business Services.
• Reports comparing actual to budget amounts for revenues and expenditures will be
generated monthly and reviewed by those in a position of authority over financial
operations. Those in a position of authority include, but are not limited to, the Bookkeeper,
Principal, Supervisor, Executive Director, District Accountant, Supervisor of Business
Services, Executive Director of Business and Operations, Superintendent, and Board of
Education
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SUMMARY
The framework of this manual complies with the state requirements and was created using
the Green Book as guidance. This manual will be reviewed annually and updated as needed. All
members of Oak Ridge Schools will be required to abide by the policies and procedures outlined
in this manual and it will be made available for reference on the school system website.
In turn, Oak Ridge School will abide by the Internal Control and Compliance Manual for
Governmental Entities and other Audited Entities in Tennessee issued by the Comptroller. This
policy manual does not supersede the requirements outlined in the Oak Ridge Schools Policies and
Procedures for Administration of Federal Education Programs Aligned with the Requirements of
the New Uniform Grant Guidance (UGG). Application of the policies and procedures will default
to whichever policy manual is most stringent in its requirements.
In addition, this policy manual does not supersede the requirements outlined in the
Tennessee Internal School Uniform Accounting Policy Manual. Oak Ridge Schools as a District
and Individual School Locations (Internal School Funds) will apply the policies and procedures to
whichever policy manual is most stringent in its requirements.
Finally, this policy manual does not supersede the requirements outlined in the Board of
Education Policies, other District policies and procedures, State regulations, rules, and policies,
and other sources. All application of the policies and procedures will default to whichever policy
manual is most stringent in its requirements.
SUPPLEMENTARY INFORMATION
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