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Presented by: Michele Foster
Surviving an Ax audit Presented by: Michele Foster
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Brief INTRO Michele Foster, G&A Applications Manager, IT
AX System Administrator AXUG Board of Advisors member External / Internal audit POC for 8 years (2 companies) Audited by 2 of the big 4 audit firms Depomed, Inc. – Specialty Pharma co Highly Regulated Publicly Traded AX 2012, R2 platform
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Discussion Disclaimer
Comments are based on annual SOX audit for Depomed Your Company’s audit varies by: External auditing team used Business complexity and identified control matrix Audit observations cover Depomed experiences with: IT Finance
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Recent changes in audit world
Recent increases in: PCAOB requirements Auditor’s understanding of AX Audit requirements New expectations around: Documentation User understanding System changes PCAOB = Public Company Accounting Oversight Board (the auditor’s auditor)
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Ways DEPOMED ensures a successful audit (IT)
Providing complete code change list w/ approvals Providing user access change list w/ approvals Having clearly-defined change management policies Performing periodic, signed review of application controls and changes Having thorough understanding of AX functionality Providing answers only to questions asked (no filler comments) Periodicity of review depends on risk determined by company size, complexity, turnover, etc.
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IT – Side of audit
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Ways Depomed ensures a successful audit (finance)
Prep for walkthroughs prior to audit visit Performance of periodic, signed access reviews to in-scope applications Reviews of control narratives Do the controls reflect business reality? Are there any known control failures? Providing documented validation of Key Control reports Demonstrating thorough understanding of AX transactions Providing answers only to questions asked Walkthrough prep by employees with key responsibilities Periodicity of reviews again depends on growth of company, number of users with high-risk access (Finance)
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Complete code change list options
System-Driven list Database Trace Log Element Log or other exportable log Project List (AOT) Change Control Log (external to system) Other ticketing system change list Show Database Trace Log & Project List
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User access controls System-driven list of changes Change approvals
Audit bolt-on used by Depomed Change approvals SOD Rules Workflows for high-risk transactions Security Groups to restrict approvals Show sample change document Database trace log (DAT) Company ASM tool report SOD Table
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Clearly-defined change policies (IT)
Periodic change policy review Consistent change documentation Signatures / Dates consistent with changes Proof of Testing (QA and UAT where required) Show Sample change request template
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Periodic review of application controls (IT)
Controls are Different for each business Defined by business Controls (systematic or manual) ensure low-risk system use Manual controls = very curious auditors System controls = happy auditors Show system controls
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Finance – Side of audit
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Key reports testing (Finance)
High-level and/or detailed snapshots of business operations Used as a basis for management decisions AX Key Report types Canned / Standard (audited every 3 years) Custom (audited annually) Extracted spreadsheets (audited annually) Testing must prove Accuracy against system data Completeness against system data That changes to report are validated and approved Show sample of custom report Show change date in AOT that is reviewed by auditors
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User (POC) system understanding (It & finance)
Walk-through contacts Describe business process and related controls in AX Walk through any major changes to system code, reports or configuration Provide documentation Transaction testing users (Finance) Describe their function and use of AX Perform observed transactional tests Application testing users (IT) Describe changes to the application Perform observed application tests Given example of when user understanding went wrong Show typical application control test Show typical transactional test
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QUESTIONS?
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Contact info Michele Foster
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