OMB Circular A-123 and Sarbanes-Oxley: Management's Responsibility for Internal Control in Federal Agencies / Edition 2

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Effective fiscal year 2006, federal agencies are required to comply with OMB Circular A-123, the public-sector mirror of the Sarbanes-Oxley Act (SOX), issued by the U.S. Office of Management and Budget (OMB). Building on more than two decades of practices stemming from the Federal Managers' Financial Integrity Act of 1982, Circular A-123 is not the kind of revolution for government accounting that SOX was for the private sector. Even so, it significantly increases the scope of the regulation and the responsibilities of federal managers at all levels.

OMB Circular A-123 and Sarbanes-Oxley: Management's Responsibility for Internal Control in Federal Agencies equips readers with information on complying with OMB Circular A-123 and Section 404 of SOX in a highly accessible, simple, and practical presentation to help professionals and nonprofessionals employed by the federal government know how to comply annually, armed with the information needed to efficiently meet these conditions.

Written by renowned experts in the fields of federal accounting and auditing, this single-source informative manual features:

  • Practice aids, including forms, checklists, illustrations, diagrams, and tables
  • Practical guidance on how an agency should test and evaluate its internal control
  • In-depth explanations to help the reader understand how best to approach an assessment of internal control effectiveness

Be prepared to comply with OMB Circular A-123 through the step-by-step approach found in OMB Circular A-123 and Sarbanes-Oxley: Management's Responsibility for Internal Control in Federal Agencies. Its structured treatment prepares agencies and auditors to sift through the "patchwork" of criteria for performing evaluations of internal control, including requirements unique to federal departments and agencies.

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Product Details

  • ISBN-13: 9780471768135
  • Publisher: Wiley
  • Publication date: 4/28/2006
  • Edition description: REV
  • Edition number: 2
  • Pages: 320
  • Product dimensions: 6.34 (w) x 9.49 (h) x 1.15 (d)

Meet the Author

CORNELIUS E. TIERNEY, CPA, CGFM, is the author of several books, including Federal Accounting Handbook and Federal Government Auditing, both from Wiley, and is a Director of Kearney & Company. He has forty years of experience in accounting and financial reporting and was a founding member of the Federal Accounting Standards Advisory Board (FASAB).

EDWARD F. KEARNEY, CPA, CGFM, is an author of Federal Government Auditing and the Managing Partner of Kearney & Company. His experience includes federal financial statement audits, accounting assistance, and federal management information systems consulting.

ROLDAN FERNANDEZ, CPA, CGFM, is an author of Federal Government Auditing and is the Technical Quality Control Partner with Kearney & Company on financial statement audits, internal control evaluations, and accounting assistance engagements for federal departments and agencies.

JEFFREY W. GREEN, CPA, is a partner with Kearney & Company and has seventeen years of experience providing accounting, auditing, and consulting services to federal and private sector clients.

MICHAEL J. RAMOS, CPA, author of Wiley Practitioner's Guide to GAAS 2006, How to Comply with Sarbanes-Oxley Section 404 and The Sarbanes-Oxley Section 404 Implementation Toolkit (all published by Wiley), is a consultant in auditing and accounting technical matters. He has written non-authoritative practice aids, implementation guides, training programs, and authoritative AICPA audit and accounting guides.

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Table of Contents


1. Federal Managers’ Financial Integrity Act of 1982 and Sarbanes-Oxley Act of 2002: An Overview.

Appendix 1A. Action Plan: Structuring the Project.

Appendix 1B. Requirements for Management’s Assessment Process: Cross-Reference to Guidance.

2. Internal Control Criteria.

3. Internal Control Assessment: Project Planning.

Appendix 3A. Action Plan: Project Planning .

Appendix 3B. Summary of Planning Questions.

4. Identifying Significant Control Objectives.

Appendix 4A. Action Plan: Identifying Significant Control Objectives.

Appendix 4B. Example Significant Control Objectives.

Appendix 4C. Map to the COSO Framework.

Appendix 4D. Map to the Auditing Literature.

Appendix 4E. Working with the Independent Auditors: Lessons Learned from the Initial Implementation of Sarbanes-Oxley.

5. Documentation of Significant Controls.

Appendix 5A. Action Plan: Documentation.

Appendix 5B. Evaluating the Design and Implementation  of Automated Compliance Tools.

Appendix 5C. Linkage of Significant Control Objectives to Example Control Policies and Procedures.

6. Testing and Evaluating Entity-Level Controls.

Appendix 6A. Action Plan: Testing and Evaluating Entity-Level Controls.

Appendix 6B. Survey Tools.

Appendix 6C. Example Inquiries of Management Regarding Entity-Level Controls.

Appendix 6D. Guidance for Designing a Computer General Controls Review.

7. Testing and Evaluating Activity-Level Controls.

Appendix 7A. Action Plan: Documentation.

Appendix 7B. Example Inquiries.

8. Reporting.

Appendix 8A. Examples of Current Private Industry Practices.


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