AGA CGFM - CGFM Certified Government Financial Manager

ï‚·Why Verify Transit Use Before Taxi Use?

The program is intended for employees who commute by public transit. Verifying transit use on the day the taxi service was used ensures employees are adhering to program rules.

Random sampling is cost-effective and practical for identifying abuse without needing to review all records.

ï‚·Why Other Options Are Incorrect:

A. Looking for individuals using the service more than 10 times:This only identifies overuse but does not confirm whether program rules were followed.

B. Checking destination addresses for hospitals/clinics:This assumes all emergencies involve medical visits, which is not always the case.

C. Matching destination addresses to home addresses:This does not confirm transit use and may not identify abuse of the program.

ï‚·References and Documents:

GAO Fraud Prevention Guide:Recommends using random sampling to check compliance with program rules.

Best Practices for Internal Controls in Benefit Programs:Emphasizes verifying eligibility and usage to detect potential abuse.

Responsibility for Internal Controls:

Managementholds the primary responsibility for establishing, implementing, and maintaining an organization’s internal control system.

This responsibility is outlined in frameworks such as COSO’sInternal Control - Integrated Frameworkand the GAO’sGreen Book.

Roles of Other Parties:

A. Accountants: While accountants may assist in designing or assessing controls, they are not primarily responsible.

B. Internal auditors: Their role is to evaluate the effectiveness of controls, not establish them.

D. Audit committee: Provides oversight but does not implement or design controls.

References:

COSO,Internal Control - Integrated Framework.

GAO,Standards for Internal Control in the Federal Government (Green Book).

Benford's Law and Fraud Detection:

Benford's Lawis a statistical principle that predicts the frequency of leading digits in naturally occurring datasets.

Deviations from the expected distribution (e.g., a higher-than-expected frequency of a specific leading digit) can indicate manipulation or fraud.

For example, if too many payments start with the number "3," it suggests potential tampering.

Explanation of Answer Choices:

A. A higher-than-expected number of payment amounts to one vendor start with the number three: Correct. This aligns with how Benford’s Law is used to detect anomalies in numerical data.

B. A large number of contracts are awarded to one vendor: While concerning, this is not related to Benford’s Law.

C. A large contract is awarded to the director's close relative: This indicates a conflict of interest but is unrelated to Benford’s Law.

D. An employee receives kickbacks from real estate developers: This is fraud but cannot be identified using Benford’s Law.

References:

Association of Certified Fraud Examiners (ACFE),Fraud Detection Using Benford’s Law.

GAO,Fraud Risk Management Framework.

ï‚·Why Shared Services Agreements Are Cost-Effective:

A shared services agreement allows multiple school districts to pool resources and share the costs of special education services, such as specialized staff, transportation, or facilities.

This reduces duplication of services, increases efficiency, and helps lower costs without reducing the quality of education provided.

ï‚·Why Federal Maintenance of Effort (MOE) Requirements Matter:

Under federal law, schools must maintain a certain level of funding for special education services to receive federal grants. Cutting budgets or shifting costs directly to parents would likely violate MOE requirements.

ï‚·Why Other Options Are Incorrect:

A. Shift a portion of the costs in the form of a fee to parents:This violates federal regulations, as public schools cannot charge parents for special education services.

B. Decrease budget allocation for special education services:This would also violate MOE requirements and reduce services for students with special needs.

D. Outsource special needs services to a private contractor:While outsourcing can be an option, it may not always reduce costs and could introduce additional risks (e.g., quality concerns or compliance issues).

ï‚·References and Documents:

Individuals with Disabilities Education Act (IDEA):Mandates federal MOE requirements for special education funding.

GAO Report on Shared Services in Education:Highlights cost-saving benefits of shared services agreements.

Compliance Reporting Under Government Auditing Standards (GAS):

GAS requires auditors to assess compliance with applicable laws, regulations, contracts, and grant agreements during audits.

Compliance reporting typically includes:

Identifying areas of noncompliance.

Describing the auditor's responsibility for compliance testing.

Outlining the scope of compliance testing.

Explanation of Answer Choices:

A. Areas of noncompliance: Included in compliance reporting to highlight where the entity failed to meet requirements.

B. The auditor's responsibility for tests of compliance: GAS requires auditors to clarify their role in compliance testing.

C. Review of major internal control cycles: Correct. While internal controls may be assessed, reviewing "major internal control cycles" is not a direct component of compliance reporting.

D. The scope of the compliance testing: GAS mandates that the scope of testing be disclosed in the compliance report.

References:

GAO,Government Auditing Standards (Yellow Book).

AICPA,Compliance Reporting Guidance for Government Audits.

Collusion as a Threat to Monitoring:

Collusion occurs when two or more individuals work together to circumvent internal controls.

Even with strong controls in place, collusion can undermine monitoring because it allows individuals to bypass controls without detection.

Explanation of Answer Choices:

A. Theft has occurred: Incorrect. While theft is a problem, it is often detected if controls and monitoring are functioning properly.

B. Financial data is inaccurate: Incorrect. Inaccurate financial data can compromise decision-making, but strong monitoring can help detect and correct errors.

C. Performance data is inaccurate: Incorrect. While inaccurate performance data is problematic, it does not directly compromise the monitoring of financial control weaknesses.

D. Collusion is present: Correct. Collusion is the most significant threat because it undermines the effectiveness of internal controls and makes monitoring ineffective.

References:

GAO,Standards for Internal Control in the Federal Government (Green Book).

Association of Certified Fraud Examiners (ACFE),Fraud Risk Management Framework.

Performance Audit Objectives:

Performance audits evaluate theeffectiveness,efficiency, andeconomyof government programs, operations, or activities.

These audits focus on improving operations, achieving program goals, and ensuring responsible use of public resources.

Explanation of Answer Choices:

A. Providing an opinion on the entity's financial statement: This is the objective of a financial statement audit, not a performance audit.

B. Assessing program effectiveness, economy, and efficiency: Correct. This is the primary objective of performance audits.

C. Providing an opinion on a subject matter that is the responsibility of another party: This aligns with attestation engagements, not performance audits.

D. Issuing a report of findings based upon an agreed-upon procedure: This describes agreed-upon procedures engagements, not performance audits.

References:

GAO,Government Auditing Standards (Yellow Book).

Association of Government Accountants (AGA),Performance Auditing Guidance.

ï‚·What Does OMB Circular A-50 Require?

OMB Circular A-50establishes policies for resolving and following up on audit findings and recommendations. It assignspersonal responsibilityto anaudit follow-up officialwithin the agency for ensuring that disagreements with audit findings are resolved and that corrective actions are implemented.

ï‚·Why Is the Audit Follow-Up Official Responsible?

The follow-up official ensures the agency responds appropriately to audit findings, tracks corrective actions, and resolves disagreements in a timely manner. This ensures accountability and compliance with audit recommendations.

ï‚·Why Other Options Are Incorrect:

A. Comptroller General:The Comptroller General leads the GAO and oversees audits but is not responsible for resolving disagreements within agencies.

B. OMB Deputy Director for Management:Provides guidance on audit policies but does not hold personal responsibility for resolving disagreements.

C. Inspector General:Performs audits and investigations but does not resolve disagreements over audit findings.

ï‚·References and Documents:

OMB Circular A-50:Specifies that the audit follow-up official holds responsibility for resolving disagreements.

GAO Yellow Book:Discusses the roles and responsibilities of various officials in audit processes.