compamy

non-key

NOTE 1: For testing of Restricted Access to applications, and SAS 70 status, see IT
testwork.
NOTE 2: For segregation of duties review, see flowcharts.

Control
Number

Business
Process

Sub-Process Risk Description

Control
Objective

Control Activity

Preventive (P)
or Detective (D)

SOX to ER Audits Mapping/Test Plan

Control
Risk
Control
Testing Step Performed
Activity
(H, M, Owner (Who
Frequency
L)
or Title)
(D, W, BW,
M, Q, A)

1.1

Payroll (PR)

Data Entry

Payroll changes are

valid, properly
prepared and
authorized

Payroll
changes are
approved by
HR

HR department head or manager approves all

changes (except changes to employee
exemptions).
All payroll changes are
authorized.

BW

HR Director See Payroll Audit - For 10 pay periods (from 1/07-9/07 ), reviewed
Personnel/Payroll Transmittal for evidence of HR department head or
manager approval, noting no exceptions.

1.2

Payroll (PR)

Data Entry

Payroll data are

properly recorded

Data entry is
accurate

Verification by Payroll that all approved wage

adjustments and payroll changes have been
accurately entered in the Paychex system.

BW

Jamie Price, See Payroll Audit - For 10 pay periods (from 1/07-10/07), reviewed
Supr.
Personnel/Payroll Transmittal for evidence of cross-check by someone
independent of the data entry, noting no exception.

1.3

Payroll (PR)

Processing

Timesheets are not

correctly entered in
the PR system

Data entry is
accurate

Verification by Payroll (by cross-check and

initials) that approved manual changes for nonexempt hours and salary time sheets are properly
entered into Paychex.

BW

Jamie Price, See Payroll Audit - For 5 pay periods (from 1/07-5/07), reviewed Time Edit
Supr.
Report and Salaried Time Sheets for evidence of cross-check by someone
independent of the data entry noting no exceptions.
Reviewed 5 pay periods' Time Edit Report summaries (6/18-7/1, 7/2-7/15,
7/30-8/12, 8/13-8/26, 9/10-9/23) and Salary time sheets for 5 employees for
evidence of review noting manual changes on Time Edit Report summaries
for non-exempt employees and salary timesheets were approved by
department heads and cross-checked by someone independent of the data
entry in payroll noting no exception.

1.4

Payroll (PR)

Reporting

Payroll is not
accurate, valid, or
complete

Payroll is
Payroll department summaries are reviewed for
accurate, valid, accuracy,
validity,
completeness
and
and complete. reasonableness by department heads (or
designee) subsequent to processing.

BW

1.5

Payroll (PR)

Reporting

Payroll is not
reasonable and
properly recorded

Payroll is
reasonable.

1.55

Payroll (PR)

Reporting

Payroll is not
reasonable and
properly recorded

1.6

Payroll (PR)

Reporting

Payroll is not
properly recorded.

Jamie Price, See Payroll Audit - For 10 pay periods (from 1/07-9/07), reviewed Payroll
Supr.
Journals for evidence of review by department head noting no exceptions.

Racetrack Controller prepares the payroll

journal entry. Accountant reviews and approves.

P/D

Racetrack
Controller

See Payroll Audit - Reviewed 4 payroll journal entries (March-June) for

propriety (by agreeing to supporting documentation) and evidence of review
& approval by someone independent of the preparation, noting no
exceptions.

Payroll is
reasonable.

Mktg. Fin. Mgr. prepares the gross payroll

allocation journal entries, which are reviewed
and approved by the Racing Controller.

P/D

Racetrack
Controller

Reviewed 4 Payroll Journal Entries for June-September for evidence of

review and approval by the Racing Controller noting no exception.

Payroll-related
accounts and
vacation
accrual
properly
recorded.

Payroll-related accounts (reviewed monthly by

the Accountant (as part of the month-end
checklist), with quarterly reconciliations
(performed by the Accountant) reviewed for
reasonableness and propriety and approved by
Racing Controller. (Vacation accrual

Racing
Controller

See Payroll Audit - Reviewed 1 payroll reconciliation (1st Qtr) for

propriety (by agreeing to supporting documentation & GL), noting review
& approval by someone independent of the preparation, noting no
exception.

compamy

non-key

NOTE 1: For testing of Restricted Access to applications, and SAS 70 status, see IT
testwork.
NOTE 2: For segregation of duties review, see flowcharts.

Control
Number

Business
Process

Sub-Process Risk Description

Control
Objective

Control Activity

Preventive (P)
or Detective (D)

SOX to ER Audits Mapping/Test Plan

Control
Risk
Control
Testing Step Performed
Activity
(H, M, Owner (Who
Frequency
L)
or Title)
(D, W, BW,
M, Q, A)

1.7

Payroll (PR)

Rec

Payroll payments are Payroll

not accurate.
payments are
accurate.

Bank reconciliations are reviewed and approved

by someone independent of the preparation.

Accountant

1.75

Payroll (PR)

Rec

Each employee (or departmental designee) must

initial a form evidencing receipt of their check.

P/D

BW

Jamie Price, See Payroll Audit - Reviewed 10 pay periods (1/07 - 9/07) noting receipt of
Supr.
departmental payroll checks were properly evidenced by applicable
employees, noting no exception.

1.8

Payroll (PR)

401K

BW

Payroll (PR)

401K

VP-Finance reviews and approves 401K

worksheet from Payrolland compares to Paychex
401K report for accuracy
Payroll Clerk enters amounts from spreadsheet
into Paychex, and agrees back to spreadsheet.
Payroll Supv. reviews and approves.

1.9

Payroll payments are Payroll

distributed to existing payments are
employees.
not distributed
to existing
401K information is 401K
employees.
not accurate, valid, or information is
complete
accurate, valid,
complete
401K information is or
401K
not accurate, valid, or information is
complete
accurate, valid,
or complete

BW

VP-Finance See Payroll Audit - Reviewed 8 pay periods' (1/17, 2/14, 3/28, 4/11, 5/23,
6/20,7/18, 8/15) 401K worksheets for accuracy, noting evidence of review by
VP-Finance, noting no exception.
Jamie Price, See Payroll Audit - Agreed spreadsheets (see 1.8) to Paychex, noting
Supr.
evidence of Payroll review & approval; no exceptions

1.10

Payroll (PR)

401K

401K information is 401K

not accurate, valid, or information is
complete
accurate, valid,
or complete

401K Report from Paychex is agreed to

spreadsheet, and entered into WYSTARs Track
Now spreadsheet; they confirm batch totals &
post balances to the website.

BW

1.12

Payroll (PR)

Corporate

Payroll is
unreasonable

CFO reviews and approves the payroll analysis

prepared by the Corp. Controller

Payroll is
reasonable

(See Cage testwork- 3.33) - Reviewed 4 months' bank reconciliations for

propriety (agreement to adequate supporting documentation) and proper
approval, noting no exception. (February, March, June, July)

Jamie Price, See Payroll Audit - Reviewed the same pay periods as above (1.8) for
Supr.
evidence of WYSTAR confirmation noting no exception.

CFO

Reviewed Feb.-May 2007 payroll analysis for reasonableness and evidence

of CFO review & approval, noting no exception.

compamy

SOX to ER Audits Mapping/Test Plan

Control
Number

Sample Size

Exception?

1.1

no

1.2

no

1.3

no

5 salary time sheets

5 Time Edit Report

no

1.4

no

1.5

no

1.55

no

1.6

no

compamy

SOX to ER Audits Mapping/Test Plan

Control
Number

Sample Size

Exception?

1.7

no

1.75

no

1.8

no

1.9

no

1.10

no

1.12

no

Monticello Gaming & Raceway

SOX Test Plan - 2008
Control
Number

Business Sub-Process
Process

Control Activity

Control
Control
Testing Step Performed
Activity Owner (Who
Frequency
or Title)
(D, W, BW,
M, Q, A)

Sample Size

Exception?

Initials
2.1

Purch/AP

MRMI &
Racing

The A/P Dept. reviews the purchase

documentation, noting proper required
signatures prior to data entry.

A/P Supr

2.5

Purch/AP

MRMI &
Racing

The accounting staff and VP of Finance both

review all MRMI expenditures for propriety.
VP-Finance initials his review. In the absence
of VP-Finance, the Racing Controller, Sr
Accountant, or Mktg./Fin. Mgr may initial the
final review.

2.15

Purch/AP

MRDC

VP-Finance (or Mktg/Fin Mgr.) reviews &

approves checks prior to mailing.

Rec

1.7, 2.18, Payroll

3.33,
4.48,
4.91,
2.17 Purch/AP

Review payments for MRMI & Racing for proper AP approval.

5 each (MRMI
& Racing) per
month

VP-Fin

Reviewed MRMI & Racing checks for evidence of review (initials on check
stub).

5 each (MRMI
& Racing) per
month

VP-Fin

Reviewed MRDC checks for evidence of review (initials on check stub).

Bank reconciliations are reviewed and approved

by someone independent of the preparation.

Accountant

Review bank reconciliations for proper approval (initials).

each month

MRDC

Journal entries are independently reviewed and

approved by someone independent of the
preparation.

Accountant

Review MRDC journal entries for evidence of review and approval by

someone independent of the preparation (initials).

each month

5/month

3.27

Revenue

POS/NonGaming

VGM Accountant reviews & approves the

journal entry after posting to the GL.

Accountant

Reviewe POS journal entries for evidence of VGM Accountant review &
approval.

5/month

3.31

Revenue

RV

A 2nd VGM Accountant evidences an

independent check by reviewing for propriety
and initialing the Main Bank Rec journal entry
and the VGM journal entry.

Accountant

Review VGM journal entries, noting all contain evidence of VGM

Accountant's proper review and approval (initals).

5/month

3.32

Revenue

RV

VGM Accountant reconciles the Main Bank

Reconciliation to the GL.

Accountant

Review reconciliations of the Main Bank Reconciliation to the GL for

evidence of Accountant's initials.

4.46

Mktg

Marketing Sr. VGM Accountant (or someone independent

Reimbursem of the posting) reviews and approves journal
ent
entries for restricted cash receipts and accrual of
8% of marketing allowance.

Accountant

Review journal entries for proper approval (initials) by someone

independent of the posting.

4.8

AP /
ExpenseRacing

Horsemen's Journal entries for purses and interbank transfers

Purses
are prepared by the Racing Controller and
reviewed and approved by someone independent
of the preparation

Accountant

Review journal entries for evidence of proper review and approval (initials)
by someone independent of the preparation.

each month
5/month

each month

Date

Monticello Gaming & Raceway

SOX Test Plan - 2008
Control
Number

Business Sub-Process
Process

Control Activity

Control
Control
Testing Step Performed
Activity Owner (Who
Frequency
or Title)
(D, W, BW,
M, Q, A)

Sample Size

Exception?

Initials

The VGM Senior Accountant. reviews and

approves the depreciation journal entries
prior to posting.

Accountant

Review journal entries for evidence of review and approval by VGM

Accountant.

Dir - Mktg

Review manual point adjustments for proper approval (initials) by someone

who does not perform Players Club transactions (Director, etc.)

5.9

F/S Close

Depr

each month

4.2

AP /
Expense

Players Club Marketing Dept. reviews and approves any large

manual point adjustments on a monthly basis.

1.3

Payroll
(PR)

Processing

Verification by Payroll (by cross-check and

initials) that approved manual changes for nonexempt hours and salary time sheets are properly
entered into Paychex.

BW

Jamie Price, Review Time Edit Report and Salaried Time Sheets for evidence of crossSupr.
check by someone independent of the data entry (2 initials).

1.75

Payroll
(PR)

Rec

Each employee (or departmental designee) must

initial a form evidencing receipt of their check.

BW

Jamie Price, Review that receipt of departmental payroll checks were properly
Supr.
evidenced by applicable employees (signatures)

1.5

Payroll
(PR)

Reporting

Racing Controller prepares the payroll journal

entry. Accountant reviews and approves.

Racing
Controller

Review payroll journal entries for evidence (initials) of review & approval
by someone independent of the preparation.

1 / month

1.55

Payroll
(PR)

Reporting

Mktg. Fin. Mgr. prepares the gross payroll

allocation journal entries, which are reviewed
and approved by the Racing Controller.

Racing
Controller

Review payroll journal entries for evidence of review and approval (initials)
by the Racing Controller.

1 / month

4.1

AP /
Expense

Players Club The Racing Controller reviews, approves, and

initials the VGM Accountants month-end
journal entry recording the expense and liability
for outstanding redeemable cash points.

Racing
Controller

Review outstanding redeemable points expense journal entries for evidence

of properly review and approval (initials) by the Racing Controller.

1 / month

4.5

AP /
ExpenseRacing

Horsemen's Either the second Assistant to the Racing

Purses
Controller or the Racing Controller compares
the purse totals on the Overnight Sheet to the
Purse Summary. After confirming the totals,
the Overnight Sheet is initialed.

D/W

Racing
Controller

Review Overnight Sheet for evidence of review (initials).

5/month

1 / month

1 dept. / month

1 / month

Date

Monticello Gaming & Raceway

SOX Test Plan - 2008
Control
Number

Business Sub-Process
Process

Control Activity

Control
Control
Testing Step Performed
Activity Owner (Who
Frequency
or Title)
(D, W, BW,
M, Q, A)

Sample Size

Exception?

Initials
4.7

AP /
ExpenseRacing

Horsemen's The Racing Controller or designee agrees the

Purses
weekly purse transfer to the supporting
Overnight Sheets and compares the weekly total
to the (upper limit) range established by the
Exec. VP & GM, then signs off on the purse
transfer (and then prepares an inter-bank transfer
of funds from the Purses Escrow account to the
Horsemen's purses acccount.)

Racing
Controller

Review weekly purse transfer for evidence of Racing Controller's review of

purse amounts (initials).

1 / month

5.41

F/S Close

F/S Close MRMI

MRMI reconciliations, account analyses and

revenue entries are completed in accordance
with a checklist, reviewed for propriety, and
approved by the Accountant and Racing
Controller.

Racing
Controller;
Accountant

Review checklists for evidence of review & approval (initials) by someone

independent of the preparation.

1 / month

5.40
5.43

F/S Close

F/S Close MRMI &

MRDC

VP-Finance reconciles the intra-company

balances (Racing & VGM) and signs off on draft
financials before submission to Corp. Controller.
CFO also reviews & signs off.

VP-Fin

Review financial statements for both MRMI and MRDC for evidence of
review and approval by VP of Finance and CFO (initials).

Date

Monticello Gaming & Raceway

SOX Test Plan - 2008
Control
Number

Business Sub-Process
Process

Control Activity

Control
Control
Testing Step Performed
Activity Owner (Who
Frequency
or Title)
(D, W, BW,
M, Q, A)

Sample Size

Exception?

Initials

Quarterly Controls
1.6

Payroll
(PR)

Reporting

Payroll-related accounts (reviewed monthly by

the Accountant (as part of the month-end
checklist), with quarterly reconciliations
(performed by the Accountant) reviewed for
reasonableness and propriety and approved by
Racing Controller. (Vacation accrual is annual)

5.21

F/S Close

Asset
Impairmt/Al
low for
Doubtful
Accts

MRMI periodically reviews long-lived assets to

determine if carrying values are recoverable or
should be reduced to fair value. Journal entries
for any necessary adjustments are made and
approved by a person independent to the J/E
process.

Racing
Controller

Review payroll reconciliation for evidence of review & approval (initials)

by someone independent of the preparation.

VP Fin, CFO Review evidence of the review by Management (initials) of MRMI's longlived assets for impairment.

Date