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Elaine M. Frenette, CPPM, CF NES 2011 Las Vegas, NV Reader’s Digest Version The Yellow Book 1
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Objective Provide a brief ‘snapshot’ of the Government Auditing Standards (Yellow Book) for Performance Audits (not meant to be ‘end-all’ and ‘be-all’ – you MUST read and assimilate GAGAS) 2
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Objective 3 Take a slightly smaller bite of the elephant rather than trying to swallow the elephant whole!
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Generally Accepted Government Auditing Standards (GAGAS) Yellow Book - July 2007 Revision 2010 Exposure Draft issued August 2010 –Invited comments through 22 November 2010 Issued in Final Form – 2011 –Will supersede July 2007 revision –Effective date – established when issued 4
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Major developments in the accountability & audit profession Emphasize specific considerations applicable to government environment http://www.gao.gov/govaud/ybk01.htm 5
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Performance Audits Chapters 1 – 2 – 3 Chapters 7 and 8 Apply when performing performance audits in accordance with GAGAS 6
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Performance Audits Chapter 1 Use and Application of GAGAS Chapter 2 Ethical Principles in Government Auditing Chapter 3 General Standards 7
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Chapter 1 Use and Application of GAGAS “Provide a framework for performing high- quality audit work with –Competence –Integrity –Objectivity –Independence” Standards help accomplish this –If properly applied 8
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Vocabulary Auditor “Individuals performing work under GAGAS…and, therefore, individuals who may have the titles auditor, analyst, evaluator, inspector, or other similar titles” GAO-07-731G, p. 6 9
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Vocabulary Audit Organization “Government audit organizations as well as public accounting firms that perform audits using GAGAS” GAO-07-731G, p.6 10
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Use and Application GAGAS (Yellow Book) –Provide guidance & requirements in performing audits in an ethical manner –Assist in “objectively acquiring and evaluating sufficient, appropriate evidence and reporting the results.” GAO-07-731G, p.6 11
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Professional Requirements Professional requirements identified through use of language – Two Categories –Describe degree of responsibility imposed on auditors & organizations Unconditional Requirements Presumptively Mandatory Requirements 12
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Unconditional Dictionary.com: –Not limited by conditions; absolute; complete GAGAS will use terms –MUST or IS Required IF audit based on GAGAS – REQUIRED to comply with unconditional requirement where it applies 13
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Presumptively Mandatory Presumptive Synonyms: Prospective Likely Circumstantial GAGAS terminology “should” instead of ‘must’ or ‘is required’ 14
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Presumptively Mandatory Auditors “required to comply” BUT “rare circumstances whereby an auditor may forego that particular requirement provided they document their justification for the departure and how the alternative procedures performed in the circumstances were sufficient to achieve the objectives of the presumptively mandatory requirement.” GAO-07-731G, p. 8 15
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Explanatory Material Language is considered –‘guidance’ –Further explanation of professional requirements Government expects ‘professional judgment’ to be used 16
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Explanatory Material GAGAS terminology May Might Could 17
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Explanatory Material Provides information in exercising professional judgment Does NOT mandate auditor to perform suggested procedures or actions 18
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Compliance Statements If required or choose to use GAGAS –Must comply with the standards –Make reference in final report Two types of Statements –Unmodified –Modified 19
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Unmodified Statement Unmodified –Followed ALL requirements in GAGAS Both unconditional & presumptively mandatory OR Justified any ‘departure’ from presumptively mandatory requirements –Documenting HOW objective of requirement was still achieved 20
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Modified Statement When is MODIFIED statement used? –Depends on significance of departure from requirement Scope of audit –Access unavailable to certain records/individuals (Special Programs) –Document reason for not performing audit in accordance with GAGAS 21
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Modified Statement Assess significance of the noncompliance to audit objective DOCUMENT assessment (reasons for not following requirement) Determine type of GAGAS compliance statement 22
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Other Professional Standards Authoritatively approved –International Standards for the Professional Practice of Internal Auditing, The Institute of Internal Auditors, Inc. (www.theiia.org)www.theiia.org –Guiding Principles for Evaluators, American Evaluation Association (www.eval.org)www.eval.org 23
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Other Professional Standards GAGAS should be used if conflict between the two 24
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Objectives ALL audits begin with objectives Looking for an opinion Clear and specific Or Multiple or overlapping objectives 25
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Objectives “What is the ultimate outcome of this exercise?” “What are you trying to accomplish with this audit?” “Auditing an organization’s performance, compliance with regulations, etc.?” 26
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Performance Audits “Engagements that provide assurance or conclusions based on an evaluation of sufficient, appropriate evidence against stated criteria, such as specific requirements, measures, or defined business practices.” GAO-07-731G Government Auditing Standards, p. 17 27
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Performance Audits Reasonably assured –appropriate type & amount of information was obtained to support final audit report Sufficiency & appropriateness –depends on audit objectives & conclusions 28
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Performance Audits “Dynamic Process” –Objective & procedure continually reviewed –To assure ‘sufficient, appropriate evidence against the stated criteria’ 29
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Performance Audits Goals & Objectives (audits/self assessments) –Examples: (not limited to these) Determine organization –Is in compliance with legislative, regulatory or organizational goals & objectives –Is in compliance with sound procurement practices –Has performance measures that are reliable, valid, relevant and effective in relation to their contractual obligations 30
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Chapter 2 Ethical Principles Provides fundamental principles –Public Interest acceptance of responsibility to serve the public interest –Integrity fact-based, nonpartisan, honest –Objectivity Maintain attitude of impartiality 31
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Ethical Principles Proper use of government info, resources, position Proper handling of sensitive/classified information or resources Exercising discretion not using position for personal gain Professional behavior Compliance with laws & regulations 32
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Chapter 3 General Standards Independence Free from personal, external, organizational impairments to independence – must remain impartial Avoid appearance of partiality Professional Judgment Professional skepticism (management is neither dishonest nor of unquestioned honesty) –Questioning mind –Critical assessment of evidence 33
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General Standards “Believing that management is honest is not a reason to accept less than sufficient, appropriate evidence.” GAO-07-731G Government Auditing Standards, p. 49 34
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General Standards Technical Knowledge/Competence Blending of education and experience Commitment to continued learning and development 35
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General Standards Continuing Professional Education (CPE) 24 hours of CPE every 2 years (directly relating to government auditing, government environment, or specific/unique environment of entity being audited) 56 additional TOTAL = 80 GAO-07-731G Government Auditing Standards pp. 53-54 36
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General Standards Audit organization –MUST establish system of Quality Control To provide assurance personnel comply with professional standards & legal/regulatory requirements and External Peer Review –At least once every 3 years (example: DCMA MICR) 37
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Chapter 7 Field Work Standards for Performance Audits Planning Supervising staff Obtaining sufficient, appropriate evidence Preparing audit documentation 38
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Field Work Standards Form framework for applying standards Reasonable Assurance Significance Audit Risk 39
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Reasonable Assurance Evidence is sufficient and appropriate to support findings and conclusions Sufficiency/appropriateness will vary Audit objectives Findings Conclusions 40
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Significance “Relative importance of a matter within the context in which it is being considered, including quantitative and qualitative factors.” GAO-07-731G Government Auditing Standards p.123 41
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Significance Significance Impact of the matter to the overall program Relevance of the matter Professional Judgment 42
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Audit Risk Possibility auditor’s findings, conclusions, recommendations, assurance may be Improper or incomplete WHY? Evidence NOT sufficient/appropriate Inadequate audit process Intentional omissions/misleading info due to misrepresentation/fraud 43
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Audit Risk Qualitative & Quantitative considerations – impact risk Time frames Complexity Size of program ($) Adequacy of audited system/processes to detect inconsistencies, significant errors Auditor’s access to records 44
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Audit Risk Auditor will not detect Significant errors Inconsistencies Reduce Risk Increase scope of work add experts Change methodology – obtain additional evidence 45
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Planning Must adequately plan and document the planning –Reduces audit risk to provide reasonable assurance evidence is sufficient and appropriate to support findings and conclusions 46
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Planning Define Objectives Questions about the organization/function, etc. that need to be answered Ex: How adequate is their acquisition system, maintenance or disposition program? 47
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Planning Determine –Scope (boundary) Subject matter to be assessed/reported on Ex: necessary documents/records, period of time, locations, etc. –Methodology Specific steps used to gather information Includes nature and extent of procedures used 48
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Planning Continuous Process –SHOULD Assess Risk and significance HOW?? 49
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Planning Understand the following: Nature of program being audited Internal Controls (management control) Information Systems Legal/regulatory requirements/contract provisions/grant agreements Results of previous audits 50
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Planning Identify –Criteria Ex: Policies & procedures; contract requirements –Sources of audit evidence Determine amount/type If need to modify scope/methodology Evaluate –Use work of others (auditors/experts) 51
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Planning MUST Prepare written audit plan –Form/Content – varies –Includes: Strategy Key decisions about objectives/scope/methodology Basis of decisions 52
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Planning Written Audit Plan –Provides supervisors opportunity to review work of auditors Proposed objectives – produce useful report? Plan addresses relevant risks? Scope/methodology – adequately addresses objectives? Evidence will likely be sufficient & appropriate? 53
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Chapter 7 Field Work Standards for Performance Audits Planning Supervising staff Obtaining sufficient, appropriate evidence Preparing audit documentation 54
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Supervision MUST properly supervise staff Provide sufficient guidance/direction Stay informed – significant problems Review work performed On-the-job training 55
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Chapter 7 Field Work Standards for Performance Audits Planning Supervising staff Obtaining sufficient, appropriate evidence Preparing audit documentation 56
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Evidence Sufficient and Appropriate Integral to audit 57
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Evidence Appropriateness “…measure of the quality of evidence that encompasses its relevance, validity, and reliability in providing support for findings and conclusions related to the audit objectives.” 58 GAO-07-731G Government Auditing Standards p. 147
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Evidence Sufficiency “…measure of the quantity of evidence used to support the findings and conclusions related to the audit objectives.” Has enough evidence been gathered? GAO-07-731G Government Auditing Standards pp. 147 59
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Evidence Professional Judgment –Interpret –Summarize –Analyze To determine sufficiency & appropriateness Reporting results 60
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Appropriate Evidence “…measure of the quality of evidence that encompasses its relevance, validity, and reliability in providing support for findings and conclusions related to the audit objectives.” GAO-07-731G Government Auditing Standards p. 174 61
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Appropriate Evidence Relevance –Logical relationship with/importance to issue being addressed – function being audited Validity –Evidence based on sound reasoning/accurate information Reliability –Consistency of results –Verifiable/supported Appendix I – additional guidance 62
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Evidence Different types/sources –Depends on audit objectives Observation Inquiry Inspection –Each with own strengths/weaknesses Which to choose??? Professional Judgment 63
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Sufficient Evidence Useful Presumptions Greater the audit risk – greater the quantity & quality required Stronger evidence – MAY allow less evidence to be used Large volume of evidence – DOES NOT compensate for lack of relevance, validity, or reliability 64
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Evidence Appendix I –Additional guidance regarding TYPES of evidence –Examples Internal Controls – –Effective vs. Weak/nonexistent Examination of Original Documents vs. copies Professional Judgment 65
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Findings Elements of a Finding Condition Cause Effect 66
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Findings Condition “a situation that exists” determined and documented during audit 67
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Findings Cause –Reason for the condition Could serve as basis for recommendations for corrective actions Is evidence convincing enough – reasonable to explain WHY ‘condition’ exists Many factors involved Evidence needs to clearly demonstrate link between problem and cause 68
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Effect “A clear, logical link to establish the impact or potential impact of the difference between the situation that exists (condition) and the required or desired state (criteria) –Identifies the outcomes or consequences of the condition” GAO-07-731G Government Auditing Standards, p. 156 69
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Chapter 7 Field Work Standards for Performance Audits Planning Supervising staff Obtaining sufficient, appropriate evidence Preparing audit documentation 70
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Audit Documentation MUST prepare audit Documentation Planning Conducting Reporting 71
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Audit Documentation Other experienced auditor Understands timing How audit performed – results How/what/source evidence obtained Conclusions reached & supporting evidence 72
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Audit Documentation Essential element of audit quality –SHOULD document Objectives, scope, methodology Work performed – supports significant judgments –Includes descriptions of transactions and records examined 73
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Audit Documentation Compliance Statements »Unmodified »Modified 74
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Chapter 8 Reporting Standards for Performance Audits Form Content Issuance 75
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Reporting “Auditors MUST issue audit reports communicating the results of each completed performance audit.” GAO-07-731G Government Auditing Standards, p. 160 76
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Report Form Appropriate for intended use Electronic Written Letters Briefing slides Other presentation materials 77
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Report Content Objectives, scope, methodology Audit results (findings, conclusions, recommendations) Compliance statement Nature of any confidential/sensitive information omitted (if applicable) 78
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Report Content Objectives Clear, Specific, Neutral, Unbiased Why audit performed (IAW FAR, DFARS, Company Procedures, etc.) 79
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Report Content Scope Work conducted Issues, limitations (denials of access) Relationship between population and items tested Identify organization (audited entity) Geographic locations Period covered Kinds/sources of evidence 80
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Report Content Methodology –How work supports objectives Gathering of evidence Analysis techniques (random sampling, purposive, etc.) Any specific assumptions made Criteria used 81
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Report Findings Clearly developed –Elements of a Finding Condition Cause Effect Provides understanding for need of corrective actions 82
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Report Findings Place findings in perspective Relate instances to population Number of cases examined Quantify results Dollar value, etc. 83
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Reporting Conclusions Not merely summary of findings Logical inference of overall status of program Stronger when conclusions lead to recommendations, convincing audited entity that action is needed 84
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Reporting Recommendations Effective Recommendations Encourages improvements Specific, practical, cost effective, measurable Addressed to those with authority to act 85
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Reporting Compliance Compliance Statements 86
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Reporting Views of Responsible Officials Of audited entity Any disagreements Mutual agreements Confidential or Sensitive Information Auditors may consult with legal counsel 87
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Distributing Report Those charged with governance Other appropriate officials Organizations requiring audit (ex: NASA) Other officials responsible for acting on audit findings/recommendations 88
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Appendix I Supplemental Guidance Doesn’t establish requirements Explanatory Material –Helps auditor implement standards Provides Examples of situations Information to accompany Chapters 89
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U.S. Government Accountability Office http://www.gao.gov/govaud/ybk01.htm Previous versions 2010 Exposure Draft Lots of other information 90
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Questions 91
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