Accounts Payable Best Practices Presented by: Eddy Castaneda, CPA, MBA
Accounts Payable Best Practices Top Practices
AP Top Practices Document your current AP procedures Can identify overlapping work Can identify possible weaknesses in controls Helps develop new staff Helps your auditor
AP Top Practices (Cont) Document your current AP procedures (Cont) Areas to identify: Key personnel Major classes of transactions Risks inherent in the process I.T. systems Work flow AP controls Security
AP Top Practices (Cont) Document your current AP procedures (Cont) Areas to identify: Key personnel Controller/Finance Director AP Supervisor AP Clerk Major classes of transactions Receiving invoice from vendor Payment is properly authorized Recording transaction in the AP system Preparing JE to record transaction to GL
AP Top Practices (Cont) Document your current AP procedures (Cont) Areas to identify: Risks inherent in the process Cash disbursement transactions improperly reported Purchase was not properly approved Goods received do not match invoice but paid anyway I.T. systems Accounting software AP modules
AP Top Practices (Cont) Document your current AP procedures (Cont) Areas to identify: Work flow (example) Goods are received and counted Goods are checked against packing slip Information is transmitted to AP Department AP clerk checks invoice against P.O. AP Clerk checks for mathematical accuracy Etc.
AP Top Practices (Cont) Document your current AP procedures (Cont) Areas to identify: AP controls Review and update signature authorizations periodically Goods are received and checked against packing slip Department supervisor approves payment of invoice prior to submitting invoice for payment AP Clerk checks invoice for mathematical accuracy AP Supervisor reviews all invoices for payment
AP Top Practices (Cont) Document your current AP procedures (Cont) Areas to identify: Security Secure check stock in a restricted area Restrict access to appropriate staff Lock up stock and provide key or combination to as few people as possible Keep check stock log
AP Top Practices (Cont) Establish segregation of duties Never have one person handling everything Decreases fraud risk Decreases operational risk
AP Top Practices (Cont) Establish segregation of duties (Cont) Best practice is to have different people: Approve purchases Receive ordered materials Approve invoices for payment Review and reconcile financial records Potential consequences if duties are not separated: Erroneous or fraudulent invoices approved for payment Unauthorized payments made to non-existent vendors
AP Top Practices (Cont) Review and reconcile Best practices: Review vendor invoices for accuracy by comparing to purchase orders Verify goods and services purchased have been received Perform monthly reconciliations of operating ledgers to assure accuracy of expenditures Potential consequences: Improper charges made to department Improper budget restrictions to department Payments made for items or services not provided
AP Top Practices (Cont) Train and cross-train AP staff Relying on one person increases fraud and operational risk Increases office functionality Increases employee morale and productivity Must have clear goal and plan Serves as theft deterrent
AP Top Practices (Cont) Maintain the Master Vendor File Prevents fraud Reduces duplicate payments Reduces missed payments Establishes separation of duties Enhances internal controls within AP process
AP Top Practices (Cont) Get a W-9 from every vendor Documents vendor s information Creates a paper trail Research the vendor Allows IRS to go after vendors
AP Top Practices (Cont) Pay invoices as they are billed Don t operate under a clean desk rule Prioritize invoices in order of due dates (unless vendor offers a discount) Can help relieve cash flow strain
AP Top Practices (Cont) Check for gaps and duplicate payments Run gap detection reports on check registers Keep inventory and log of check stock May identify errors in AP process
AP Top Practices (Cont) Monitor the AP process Monitoring helps identify ongoing effectiveness of AP controls Monitor departmental budget to actual expenditures Monitor open purchase orders Monitor payment activities
Accounts Payable Best Practices Purchasing Cards and Travel Reimbursement
Accounts Payable Best Practices Purchasing Cards Used as a tool to enhance the delivery of services and goods to the entity Limits are usually set by the procurement department Department heads should be responsible for oversight in their respective departments
Accounts Payable Best Practices (Cont) Purchasing Cards (Cont) Monitor purchasing cards on a periodic basis Completeness of transactions is easy to achieve Take a different approach to sampling Review department head transactions Check for authorization Check for sales tax paid Compare purchasing card transactions to Purchasing Policy
Accounts Payable Best Practices (Cont) Purchasing Cards How bad it can get? The Department of Defense uncovered its own purchasing card scandal Over an 18-month period, Air Force and Navy personnel used government-funded credit cards for the following charges: $102,400 for admission to entertainment events $48,250 for gambling $69,300 for cruises $73,950 for exotic dance clubs Compare purchasing card transactions to Purchasing Policy
Accounts Payable Best Practices (Cont) Travel Reimbursement Rates and guidelines are set by Florida Statutes Local governments may differ if approved by the governing body Authorization forms are very important Provides attestation language that travel was for the benefit of the entity Provides justification for travel
Accounts Payable Best Practices (Cont) Travel Reimbursement (Cont) Common errors No receipt for transaction Sales tax paid during trip Mileage allowance not calculated correctly Tipping exceeds authorized amount
Accounts Payable Best Practices Fraud Studies and Cases
Accounts Payable Best Practices Report to the Nations on Occupational Fraud and Abuse Report conducted every other year by the Association of Certified Fraud Examiners 51% of all fraud cases involved Billing schemes (such as shell companies and personal purchases) Expense reimbursement fraud Check tampering Vendor fraud is more commonplace
Accounts Payable Best Practices (Cont) Schemes, Risks and Perpetration Shell company Employee creates a fake vendor and bills the entity May include inflated, above-market prices on goods and services Personal purchases Employee orders personal items and submits invoice to employer for payment More commonplace among purchasing cards
Accounts Payable Best Practices (Cont) Schemes, Risks and Perpetration (Cont) Fraudulent expense reimbursement Employee files a false, inflated or fictitious expense report claim May also involve submissions of duplicate or inflated expenses Check tampering Employee steals blank checks from the entity, uses them for personal use Employee can also counterfeit bank account and routing numbers from entity
Accounts Payable Best Practices (Cont) Symptoms, Red Flags, and Detection Be on the lookout for: Causes behind increased costs, coupled with lower-quality goods or services Incomplete vendor information Address Tax identification number Unusual, unauthorized vendor names or addresses added to the vendor master file
Accounts Payable Best Practices (Cont) Symptoms, Red Flags, and Detection (Cont) Be on the lookout for: Missing or altered copies of supporting documentation P.O. s Invoices Receiving documents Changes in lifestyle Lavish trips Jewelry Personal assets
Accounts Payable Best Practices (Cont) Symptoms, Red Flags, and Detection (Cont) Be on the lookout for: Increase in purchases from favored vendors or unusually close relationships with suppliers Goods received but not ordered, or goods ordered but not received Links between employee information and vendor master file Address Bank account Related parties
Accounts Payable Best Practices (Cont) Controls, Countermeasures, and Prevention Stay ahead of the curve by: Separating the vendor setup and approval process from the payment process Rigorously vet all new vendors when they are set up Frequently review the vendor master file Payment volume activity Reasonableness and consistency with known operational trends and budgets
Accounts Payable Best Practices (Cont) Controls, Countermeasures, and Prevention (Cont) Stay ahead of the curve by: Maintaining and reviewing a log of sequentially numbered checks and payables processing batches Setting up automated fraud detection tolls Positive Pay Always require original receipts and invoices NEVER, EVER sign blank checks
Accounts Payable Best Practices (Cont) Accounts Payable Case Studies Case Study 1: A purchasing agent had a very good relationship with some of the company s suppliers. On a surprise check on bids for a new project, it was discovered that the supplier chosen was charging a per unit price higher than other submitted bids. It turned out that this supplier was giving the purchasing agent a commission for each winning bid. Further investigation revealed that this supplier was chosen frequently in the past, despite bidding higher than other vendors.
Accounts Payable Best Practices (Cont) Accounts Payable Case Studies (Cont) Case Study 2: The bookkeeper typed out the checks to the suppliers, which were then signed by the company owner. The bookkeeper used an erasing typewriter to remove the payee designation and amount from the check and replace them with her name and a significantly greater amount. These amounts were entered in the disbursements journal as payments for aggregate inventory to the company s largest supplier, who received several large checks each month. More than $300,000 was stolen in this manner.
Accounts Payable Best Practices (Cont) Accounts Payable Case Studies (Cont) Case Study 3: A department head set up a dummy corporation and used his home address as the mailing address. Over a two-year period, the department head submitted false invoices for more than $250,000. This scheme was eventually detected when a new employee noticed that the vendor s address matched her boss s address. If a P.O. box had been used, this scheme might have continued indefinitely.
Accounts Payable Best Practices (Cont) Accounts Payable Case Studies (Cont) Case Study in Depth - ING: A corporate mistake opened the door for Nathan J. Mueller s fraud. Two years after the error was made, he discovered he was authorized to request and approve checks of up to $250,000. A co-worker also was accidentally granted the same privileges, while a subordinate was authorized to request checks. Mueller, his subordinate, and the co-worker often logged on as one another to get work done. This allowed Mueller to request checks under one identity and then approve them under his own account.
Accounts Payable Best Practices (Cont) Accounts Payable Case Studies (Cont) Case Study in Depth - ING: Mueller and his subordinate were allowed to physically pick up checks. This allowed Mueller to take physical checks to the bank to be deposited into the account of a fake vendor he set up. Mueller hid his debits in ledger accounts that he controlled. Better separation of duties could have helped to prevent the scheme.
Accounts Payable Best Practices (Cont) Accounts Payable Case Studies (Cont) Case Study in Depth - ING: The fraud netted nearly $8.5 million in four years. The money was used to buy expensive cars, watches, and nighttime entertainment, as well as to pay for numerous trips from Minnesota to Las Vegas. Mueller told his wife his extra money was from gambling winnings. After a while, she began to doubt that explanation, and they divorced.
Accounts Payable Best Practices (Cont) Accounts Payable Case Studies (Cont) Case Study in Depth - ING: The fraud was uncovered when Mueller s ex-wife expressed her doubts about his income to his co-worker. The co-worker spotted questionable transactions in the company records and brought them to management s attention. The scheme unraveled quickly after that. Mueller was sentenced to 97 months in federal prison after pleading guilty to fraud. He is due to be released in September after 5½ years in prison.
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