International program staff are responsible for managing internal controls. The Chief Administrative Officer (CAO), assisted by administrative staff, has the responsibility of providing leadership by establishing, properly documenting, disseminating, regularly reviewing, and improving the internal controls. Staff training and documentation of policies and procedures are also elements of control. Supervisors must ensure new employees know their responsibilities for managing internal controls. In addition, close supervision is vital to ensure that control systems are working and that weaknesses will be identified and corrected. Key elements of internal controls address:
Conflict of Interest
The international program’s conflict of interest policies should be consistently applied and enforced.
For additional information, refer to the Conflict of Interest (Faculty Handbook).
Time and Effort Reporting
Staff should ensure that in instances where multiple sources support an operation, the time and effort dedicated to each is correctly documented and properly charged to each to the appropriate funding source.
For additional information, refer to the Effort Reporting Policy.
Segregation of Duties
An operation must ensure that no employee or group of employees is put in a position where it is possible to both perpetrate and to conceal errors or fraud in the normal course of their duties. The duties to be segregated include: sourcing, approval, disbursement, validation and auditing. Administrative and financial systems rely on assigning certain responsibilities to different individuals or segregating incompatible functions. The general premise is to prevent one person from having both access to assets and responsibility for maintaining the accountability of those assets.
When applying this principle within the constraints of limited staff in an international location, the Guidelines on Segregation of Duties in an International Outpost could be helpful.