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COSO Releases Discussion Document with Guidance on Monitoring Internal Control

Monday, April 12, 2010

The Committee of Sponsoring Organizations of the Treadway Commission (COSO) is pleased to announce the release of a discussion document: Guidance on Monitoring Internal Control Systems. Developed by COSO and led by a diverse Grant Thornton LLP team, the guidance is designed to help organizations monitor the quality of their internal control systems. Jeff Thomson is VP of Research and Applications Development at IMA and is a COSO Board Member. Andre van Hoek, formerly Assistant Controller at J&J and now Controller at Celgene Corporation, is IMA's primary task force representative on the COSO Monitoring project.

The guidance more fully develops the monitoring component of COSO’s Internal Control - Integrated Framework. The guidance is appropriate for organizations of any size or structure to improve the quality of their internal controls systems for multiple business purposes, but especially those dealing with the reporting requirements under the U.S. Sarbanes-Oxley Act of 2002, Section 404.

In the discussion document, COSO has asked specific questions to ensure the clarity and applicability of the guidance. A copy of the discussion document can be found on IMA’s website under the Professional Partnerships section/COSO. There are two opportunities for IMA members to get engaged in this important project and to make a difference. First, as a management accounting professional, review the discussion draft guidance on monitoring and provide comments by October 31. This will ensure a high quality final product (first half of next year) and ensure that the "inside" management view of risk and performance management is embedded in the process. A link to view the document and to submit comments can be found at Please identify yourself as an IMA member when submitting comments. Secondly, in the next phase of the project later this year, COSO is looking to develop specific implementation tools and examples - so, here is an opportunity for companies represented by IMA membership to benefit other organizations by identifying best practices, tools, and lessons learned in monitoring processes. Names of organizations will be kept confidential if so desired.