I think that the intent of Sarbanes-Oxley 304 is often misinterprested. 304 requires a "system of internal control." This means a management system!! Most often it is interprested as a system of internal controlS. The added s means to auditors and the auditees a set of controls which is interpreted as only the data associated with controls. This is why it was such a big money maker for auditor firms. I wrote an article for September 2005 Quality Progress about COSO as the system and ISO 9001 as a supporting tool.
COSO provides a working management system. Unfortunately it is 20 years old. I'm on the team revising COSO. It's importance as a system is the ability to analyze the activities and improve them over time. This a very important part of any management system. A system of internal controlS doesn't provide improvement over time.
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Many Thanks Burton - appreciated. Beulah
Beulah Misrole said:
Book Summary.pdf
MGMT LinkFlyer-2.pdf
The issue is much bigger than a misinterpretation of the COSO guidance. (BTW I'm on the IMA team revising COSO).
The problem is the silos between finance, quality, IT and environmental and other parts of the company. I've written articles in ASQ Quality Progress since 2005. Also I just published a book: "Competitive Advantage: Linking Management Systems." Publisher is Paton Press and it's on Amazon. I've Attached two files on the book and would be glad to talk to anyone about the basic ideas and case studies. Note the special rate no longer applies. Also, page 2 of the flier contains testimonials including one by the chair of the Institute of Management Accountants. You can contact me at sandfordl@msn.com
Thank you
Beulah