Internal Review Practices Essay

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Internal review practices ensure timely information, provide guidance, and promote confidence about whether an organization’s activities are well designed and effectively carried out. Internal controls must be selected for appropriateness and consistently applied to protect against malfeasance and inefficiency. With appropriate standards established, performance audits determine whether programs are being successfully managed with proper regard for such factors as finances and efficiency. Effective internal review is particularly critical in criminal justice organizations, which are uniquely susceptible to corruption and must bear a heightened level of public scrutiny. In the criminal justice system, a variety of departments, committees, and administrators are charged with developing and maintaining internal review practices.

Financial Controls

Annual audits examine whether financial statements are in accordance with generally accepted accounting principles and ensure that transactions conform to laws and regulations. Control procedures are documented and distributed to all managers and department heads, who are then responsible for implementing them. Such practices can guide auditors and ensure the quality of the practice. The overall success of a system of internal controls is dependent on how effectively each of these elements functions and how well they are coordinated and integrated with each other.

The Committee of Sponsoring Organizations (COSO) of the Treadway Commission, an initiative by major accounting associations dedicated to improving the quality of financial reporting through ethics, effective internal controls, and corporate governance, recommends fostering a favorable control environment, conducting risk assessment, designing and implementing control activities in the form of policies and procedures, providing for effective communication throughout the organization, and conducting ongoing monitoring of the effectiveness of control-related policies and procedures. The separation of responsibilities, which ensures that no individual manages all aspects of a procedure in isolation, not only prevents errors, but also makes oversights or malfeasance more easily detectable. Well-trained employees empowered with clear channels of communication assist in the monitoring and detecting of unscrupulous activity, help mitigate risks, and reduce the chances of misunderstanding among colleagues. Audit committees and internal auditors have the responsibility to provide oversight and enhance the effectiveness of internal review practices.

Audit committees, more commonly found in the corporate environment, can help the board that is in charge of governing understand and collaborate with the annual (external) audit process. The traditional responsibilities of the audit committee are to review and discuss with the external auditor the risk assessment developed as part of its audit planning process, to receive and review the draft audit report and management letter, to assist the board in interpreting these documents, and to make a recommendation to the board regarding the acceptance of the annual audit report.

Continuous comprehensive review seeking what is working well and isolating instances where there are issues cannot but allow the opportunity to “fix any areas of confusion.” This is not only valuable to the organization but to the people who use such services. To be trustworthy and to retain confidence by the public, all members of an agency must do their part to ensure the organization retains the public’s trust.

Internal Review Within the Criminal Justice System

The entity responsible for scrutiny in the correctional setting is the Program Review Division of the Central Office of the Bureau of Prisons. The division comprises the Program Review Branch (PRB) and the External Auditing Branch (EAB), which includes responsibility for the Office of Management and Budget initiatives and ensures that an adequate system of internal controls is in place to promote compliance and protect resources from fraud, waste, abuse, and mismanagement.

Another component of the criminal justice network is the judiciary. At the federal level in the United States, the judiciary is overseen by the Judicial Conference Committee on Audits and Administrative Office Accountability (AO). Judge David Katz, who served as chair of the committee in 2011, asserted that oversight and review are essential to the “integrity of operations” of the federal judiciary. Dependability, conscientiousness, reliability, and trustworthiness are considered core values for the judiciary in its accomplishment of its mission. Answerability, according to Katz, entails “stringent standards, self-enforcement, fiscal and operational integrity.” Effective and efficient use of resources is vital to sustaining public trust. Protection against error, loss, waste, unauthorized access, or abuse is carried out through systems of internal control. The development of internal control requirements, according to Katz, is a long process. Rigorous standards demand sufficient investments in time and resources but are necessary to ensure the integrity and efficiency of the judiciary.

Law enforcement agencies generally have internal affairs departments that receive and investigate complaints of misconduct by police or agents. Timely scrutiny is essential. For example, between 2001 and 2008, nearly 800 violations were reported to the Federal Bureau of Investigation (FBI) Internal Oversight Board (IOB). More than a third involved FBI violations of rules governing internal oversight of intelligence investigations. Delays in such reporting or tardiness of the process can make internal review practices ineffectual. For the same time period, it was reported that on an average, 2.5 years elapsed between a violation’s occurrence and its eventual reporting to the IOB.

Misconduct at any level of the criminal justice system may compromise both the effectiveness of the system and the public trust. Law enforcement is the most likely to be targeted by complainants because of the frequency of contact with citizens and the often objectionable nature of that contact—investigating suspicious or disorderly conduct and making arrests. Critics of internal affairs departments within law enforcement agencies question the propriety of allowing police officers to investigate complaints against their own colleagues. The blue wall of silence, it is argued, effectively prevents officers who are witnesses of alleged misconduct to testify against fellow officers, and citizen witnesses at the scene are naturally suspect and may be considered hostile, and therefore unreliable. The sympathies and biases of internal affairs officers can be expected to be in favor of their colleagues and against citizens or suspects who complain of being treated unfairly. Without appeal to external review, victims of police misconduct have no other recourse, and legitimate charges against officers may go unanswered or even unmade.

Police organizations argue that those experienced in the ethical complexities of law enforcement are best able to assess the reasonableness of officers’ behavior under the uniquely difficult circumstances the job entails. Shifting responsibility for internal review and disciplinary action to an outside entity, it is argued, might have the undesirable effect of diminishing the sense of accountability among managers.

In 2011, an undercover FBI investigation into deputy-on-inmate violence in Los Angeles County jails revealed a pervasive culture of condoned abuse. With 18,000 employees, it is the largest jail system in the United States. When Undersheriff Paul Tanaka reorganized the command structure of the Los Angeles Sheriff’s Department (LASD), which runs the jail system, both internal affairs units were made to report more directly to him, eliminating a level of oversight. Repeated scandals followed, sparking the FBI’s investigation and resulting in the installation of two separate “watchdogs” and a large citizens oversight committee. Deputies willing to testify spoke of inner circles, favoritism, and unwritten policies encouraging violent retribution against inmates and forbidding disciplinary actions against deputies who beat prisoners or failed to intervene in prisoner-on-prisoner attacks. By 2013, Tanaka had resigned, but incidents continued. The consultants complained that many of their reforms were approved by the oversight committee but ignored by the LASD.

Communicating risks and failures to those charged with assessing performance and investigating accusations of misconduct is critical, but management must be able and willing to design effective controls when new risks are identified and to implement corrective measures where failures occur. The level of assurance that a system offers depends on the amount and quality of monitoring conducted by management. Careful attention to internal review practices by those in the chain of command makes clear the importance of adhering to established standards of conduct. Conversely, when controls are neglected, officers and other employees may feel that they are being allowed a degree of discretion that is not officially recognized.


  1. Bobb, Merrick. “Internal and External Police Oversight in the United States.” Police Assessment Resource Center (2005). (Accessed October 2013).
  2. Katz, David. “Oversight and Review at Core of Stewardship.” The Third Branch. (2011). (Accessed October 2013).
  3. Leonard, Jack, and Robert Faturechi. “Incidents Expose Flaws in Civilian Oversight of Sheriff’s Dept.” Los Angeles Times (September 24, 2012).,0,3319285.story (Accessed October 2013).
  4. “Patterns of Misconduct: FBI Intelligence Violations from 2001–2008.” Electronic Frontier Foundations. (2011). (Accessed July 2013).
  5. Shantz, Jeffrey. “Internal Review Practices.” In Police and Law Enforcement. Thousand Oaks, CA: Sage, 2011.

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