Accounts Payable Advisory No. 28

Accounts Payable Advisory
Office of Operations
Bureau of State Expenditures
Advisory Name
Internal Controls Certification
Date Issued
12/11/2019
Date Last Updated
04/07/2021

Subject:

Certifying Controls over the Agency’s Payment Process

Reference:

Guide to Financial Operations:
Chapter XII, Section 4.B - Certification of Vouchers
Chapter XII, Section 4.D - Certification of Internal Controls over the Payment Process
Chapter XIII, Section 2.C - Expense Report Certification

Guidance:

Title 2, Chapter I, Part 6.6 of the New York Codes, Rules and Regulations requires the head of an agency (e.g., Commissioner, Chancellor, Executive Director) to certify to the Comptroller annually, or at any time there is a new head of the agency, that the agency has sufficient internal controls over the payment process to ensure claims are appropriate to pay. Agency heads may use a variety of resources and techniques to obtain assurance about the internal controls over the payment process as a basis for that certification.

This certification requirement is separate and distinct from DOB’s annual Internal Control Summary and Certification.

Section 110 of New York State Finance Law requires the head of the agency certify or approve vouchers for submission to the Comptroller for audit.  Other individuals may also approve vouchers if the head of the agency, or a designee, has granted that authority by a rule or written directive filed with the Comptroller.  Section 110 also requires the designee be identified in writing and filed with the Comptroller. Agencies are required to have proper internal controls over the designation of Voucher Authorizers, including appropriate system access controls.

Update: As a result of the COVID-19 public health emergency, the Guide to Financial Operations Chapter XII Section 4.D – Certification of Internal Controls over the Payment Process has been updated to extend the due date for this year’s certification to Friday, July 30, 2021.

As a reminder, in addition to certifying the internal controls over the payment process, for the certifications due by:

  • July 30, 2021, agencies will not be required to review a specific segment of the payment process or a particular payment type.  Instead, agencies must consider how changes to the work environment during the COVID-19 public health emergency have impacted agency processes, procedures, and related internal controls. 
     
  • April 30, 2022, agencies must assess their internal controls over proper use of a purchase order.

Agencies are also required to assess their internal controls over the delegation of voucher authorizers.  Annually, or upon change of the agency head, each agency should file its Voucher Authorizers and designees with the Comptroller.  To do this, the agency should complete the Voucher Authorizer Certification, including Attachment A, as part of the Certification of Internal Controls over the Payment Process. 

For more information, see Guide to Financial Operations Chapter XII, Section 4.D - Certification of Internal Controls over the Payment Process.