Division of Housing and Community Renewal


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NYS Comptroller


Taxpayers' Guide to State and Local Audits

Division of Housing and Community Renewal
Quality of Internal Control Certification

Issued: October 26, 2012
Link to full audit report 2012-S-31
Link to 90-day response

To determine whether the Division of Housing and Community Renewal (DHCR) submitted timely a quality internal control certification to the Division of Budget (DOB) by April 30, 2011.

In 1987, the Legislature passed the New York State Governmental Accountability, Audit and Internal Control Act requiring State agencies and public authorities to each institute a comprehensive system of internal controls over their operations. DOB requires the head of each covered State agency and public authority to certify compliance with the Internal Control Act by April 30 of each year by submitting a certification and internal control summary detailing the internal control activities undertaken during the previous year. On April 26, 2011, DHCR submitted its annual Internal Control Certification and reported full compliance with all provisions of the Act.

Key Findings

  • DHCR's internal control certification was submitted timely. However, we identified several areas where the quality of the certification and/or the actual internal control program could be improved.
  • In two instances, DHCR's certification did not provide the required level of detail to explain the actual steps taken to implement certain provisions, including how the Comptroller's Standards for Internal Controls have been integrated into its internal program and how specific risks and corrective actions plans were being monitored.
  • Although DHCR described compliance testing programs and monitoring systems for corrective actions, evidence did not show that these systems were actually in place.
  • Although DHCR certified full compliance with all provisions of the Act, it does not have a formal internal control training program, but instead relies on informal discussions that typically occur during staff meetings. DHCR has also assigned the same person to function as both Internal Audit Director and Internal Control Officer. These duties are not compatible and impair the individual's ability to perform the audit function with the necessary degree of independence.

Key Recommendations

  • Provide more detailed responses to questions when required in the annual Internal Control Certification.
  • Ensure that compliance testing and monitoring systems are in place. When necessary, ensure corrective action is taken and monitored.
  • Establish a more formal internal control training program covering all staff.
  • Separate the duties associated with the internal control and internal audit functions.

Other Related Audits/Reports of Interest

Office for the Prevention of Domestic Violence: Quality of Internal Control Certification (2012-S-41)
Office of the Medicaid Inspector General: Quality of Internal Control Certification (2012-S-46)
Department of State: Quality of Internal Control Certification (2012-S-50)

State Government Accountability Contact Information:
Audit Director: John Buyce
Phone: (518) 474-3271; Email: StateGovernmentAccountability@osc.state.ny.us
Address: Office of the State Comptroller; Division of State Government Accountability; 110 State Street, 11th Floor; Albany, NY 12236