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CPE for Government Auditors

CHAPTER 18 – Working Papers

Chapter Objectives

§ Distinguish among the elements of a working paper

§ Describe the standards for working paper documentation


The dreaded working papers!

I snicker when I hear auditors say they are not creative, because we are! Very. We create – out of thin air – all sorts of documentation to support our conclusions! We conjure up evidence, put it in order, make it look pretty, and bind it in folders – from air to wallets full of paper (or computers full of files). Artists do the same thing; they pull a bunch of stuff together to create something “new.”

Please enjoy this excerpt from Leita’s e-book ESSENTIAL SKILLS FOR THE GOVERNMENT AUDITOR worth 10 CPE credits available at www.yellowbook-cpe.com.

 

What do we have to document, you ask? I hate to tell you this, but the audit standards are not very helpful when it comes to working papers. They leave an awful lot up to our “professional judgment.” What does “professional judgment” mean, people? It means we are on our own!

None of the audit standards dictate the contents, sequence, or format of your audit documentation. The standards make very general suggestions regarding the content of audit documentation and leave the form of the documentation up to your professional judgment. In other words, your idea of what the working papers should look like is just as good as mine.

Sharon and Andrew

I once had the pleasure of working with an audit supervisor named Sharon. Sharon was very meticulous and had high expectations for her working papers.

All cross-references had to be two-way (coming and going). Every paper in the binder had to contain a description of the source, purpose, procedure, results, and conclusions of the individual working paper. Each working paper had to be uniquely titled and numbered.

Much of what she required had nothing to do with the standards and everything to do with making her life as a reviewer easier. If you have ever reviewed working papers, you know how hard it is to follow an auditor’s trail without applying some of Sharon’s techniques.

However, what Sharon required was not universally accepted. On my next audit, in reviewing working papers of another auditor, Andrew, I noticed that he did not apply any of Sharon’s rules. I told him that he needed to cross-reference; to put source, purpose, procedures, results, conclusion on every working paper; and to stamp every page ¼ inch from the top right corner! Andrew responded, “Who says I need to do that?” I said, “Sharon.” He said, “Sharon is not on this audit. I’m not doing all that stuff.”

Whoops! But I didn’t give up that easily! I decided to go to the standards to bolster my comments regarding Andrew’s working papers. The standards failed me.

Indeed, the standards were so vague that I had to eat quite a bit of crow in front of Andrew. The standards say that an experienced auditor should be able to follow your work. And, although initially I couldn’t follow Andrew’s work, with some extra effort and some discussions I was able to figure out how he was supporting his conclusions.

What the standards require

The standards also say that you should document:

  • The nature, timing, and extent of audit procedures
  • The results of procedures performed
  • The audit evidence obtained
  • Conclusions reached
  • Supervisory review before the report is issued

Here is what the GAO requires in the Yellow Book:

6.79 Auditors must prepare audit documentation related to planning, conducting, and reporting for each audit. Auditors should prepare audit documentation in sufficient detail to enable an experienced auditor, having no previous connection to the audit, to understand from the audit documentation the nature, timing, extent, and results of audit procedures performed, the audit evidence obtained and its source and the conclusions reached, including evidence that supports the auditors’ significant judgments and conclusions. An experienced auditor means an individual (whether internal or external to the audit organization) who possesses the competencies and skills that would have enabled him or her to conduct the performance audit. These competencies and skills include an understanding of (1) the performance audit processes, (2) GAGAS and applicable legal and regulatory requirements, (3) the subject matter associated with achieving the audit objectives, and (4) issues related to the audited entity’s environment.
 6.80 Auditors should prepare audit documentation that contains evidence that supports the findings, conclusions, and recommendations before they issue their report.
 6.81 Auditors should design the form and content of audit documentation to meet the circumstances of the particular audit. The audit documentation constitutes the principal record of the work that the auditors have performed in accordance with standards and the conclusions that the auditors have reached. The quantity, type, and content of audit documentation are a matter of the auditors’ professional judgment.

Notice that the standard says nothing about cross-referencing, tick marks, stamping each page, etc. Those items are all made up by the auditing profession to keep the working papers manageable. The Yellow Book is very open to a variety of formats and styles. As long as someone else can follow your logic, any format is fine.

Working paper etiquette

I once heard etiquette defined as “little courtesies that smooth relationships.” In other words, etiquette keeps us all from slapping each other silly. It smooths awkward situations and eases your interactions with others. Can you imagine a world where no one apologized when they accidentally step on your foot or hit you with a bag? (I have had both happen today as I am sitting in an aisle seat on a plane.)

Clear working paper documentation is essential audit ‘etiquette’. It makes significant audit tasks easier and keeps your audit supervisor and peer reviewer from slapping you silly.

The Yellow Book lists the reasons why working papers are necessary; just as holding the door for someone with a huge box in their arms is necessary.

6.82 Audit documentation is an essential element of audit quality. The process of preparing and reviewing audit documentation contributes to the quality of an audit. Audit documentation serves to (1) provide the principal support for the auditors’ report, (2) aid auditors in conducting and supervising the audit, and (3) allow for the review of audit quality.

 

Do everything you can to make the reviewer’s life easier

If you have ever reviewed working papers, you know how excruciating the job can be if the creator of the working papers refuses to play nice. Working paper review is, hands down, the worst job on the audit. Just like carrying a huge box is a drag, working paper review is a drag.

If you make this task any harder for your supervisor or reviewer, you will raise their ire in a seriously large way. Why would you want to risk annoying them so severely? Don’t you need that paycheck? Open the frigging door!

The most significant thing you can do to smooth the review process: find out what they want from you

Who do we have to please here? Our supervisors, managers, quality reviewers, and peer reviewers. I suggest you find out what your reviewers like to see and do it! What rules do they want you to follow?

If they are unclear or not sure about what they want, ask them to tell you whose working papers they like. Someone in your office has created working papers that meet their standards. You know whom I’m talking about. Did I hear you whisper, “The kiss-up!”

Scrutinize the kiss-up’s working papers to discover what makes them so pleasing to your supervisor and then REPLICATE that! Or, if you really want to show off, improve on what the kiss-up has done. Instead of just holding the door, relieve the box holder of their burden and follow them to their office. How polite is that!?!

If you are a supervisor or manager reading this, please do your staff a favor and tell them what you want them to do. It is only fair that you set clear expectations of what you want to see. Otherwise, you really have no right to complain! :)

Rebels without a clue

When I first started in auditing, the Yellow Book asked us to create audit documentation that a “reasonable person” could follow. As we have seen, the Yellow Book now only requires that our papers be clear to an “experienced auditor.” If you had to be clear to any woman on the street who looked reasonable, then you would have to do a lot more documentation.

The “reasonable person standard” is the standard under which Sharon earned her audit chops. She wanted each working paper to stand on its own. Even if a hurricane blew into your working paper files and scattered your work, a woman who picks them up a few miles away should be able to discern the working paper.

The stupidity of my rebellion

As an auditor with a whole four years under my belt, I decided that, as soon as I got away from Sharon, I would make up my own standards for working papers and blow off all of her crazy, over-the-top requirements.

My next audit was an assignment I would hold for three consecutive years. The first year, having just left Sharon’s project, I did a very poor job documenting my audit work. The audit supervisor was going through a divorce, so his working paper review wasn’t super thorough (it happens). I felt vindicated; doing things my own way paid off!

But the next year, I got my come-uppance. I was assigned the same audit area, and I couldn’t follow my own working papers. In particular, I could not remember where I had gotten my evidence.

One of the client’s staff members, whom we’ll call Stan, really didn’t like me. He always sneered at me and did his best to make my life difficult. I didn’t do anything to him; I think he did not like auditors or that I am MUCH taller than he is (that also happens).

When I had to ask Stan for the same information AGAIN, in a lost, befuddled way AGAIN, he nailed me to the wall. “Weren’t you just here asking me these same questions? Don’t you write anything down?” Ewww. Nope. I didn’t. I had to eat some major crow.

Leaving that meeting, I really appreciated Sharon’s standards. If I had implemented even a few of her ideas, I would have been a lot more prepared and seemed much more credible.

If you are anything like me, you can’t remember what you did last week! How in the heck can you remember what you did a year ago, or two years ago, when your working papers undergo peer review?

Bare bones of the working papers

Looking at the Yellow Book standards, we can make sure that we document all of the basics in the working papers.

6.83  Auditors should document the following:

a. the objectives, scope, and methodology of the audit;
b. the work performed and evidence obtained to support significant judgments and conclusions, including descriptions of transactions and records examined (for example, by listing file numbers, case numbers, or other means of identifying specific documents examined, but copies of documents examined or detailed listings of information from those documents are not required); and
c. supervisory review, before the audit report is issued, of the evidence that supports the findings, conclusions, and recommendations contained in the audit report.

Here are some common standards that audit shops require of their auditors’ working papers. See whether you think these ideas are wise and practical.

  • The working paper has

– Name of project
– Title
– Auditor’s initials
– Date completed
– Page number and reference
– Source, purpose, procedures, results, conclusions
– Explanation of all tick marks
– Two-way cross-references

  • The working paper is

– Neat and legible
– Referenced to the program
– Understandable without further explanation

  • Important calculations were verified
  • Source documents are included as necessary
  • If a document was created by the client, “PBC” is written on the working paper
  • A review has been indicated and all points were cleared

Let’s look at these shop requirements more in-depth.

1. The working paper is titled, signed, and dated

Each working paper includes:

  • The name of project
  • The unique title of the working paper
  • The auditor’s initials
  • The date completed
  • A page number and reference

This is just plain practical. I see no reason to ever skip this. But hey, the standards don’t require it! Go ahead and skip it, you rebel you, and see how the review goes!

2. Source, purpose, procedures, results, and conclusion on every page

Whew. Source, purpose, procedures, results, and conclusions – Sharon made me put these so called “elements of a working paper” on every working paper! Every page, Sharon? How about the first page of each unique working paper? Yes, I like that better.

What do all of the elements of a working paper mean? Here are the questions that each element should answer:

SOURCE: Where did we get the evidence on the working paper? Who gave it to us? Which evidence did we look at? Where is the evidence and how can we get to it again?

PURPOSE: What question does this working paper seek to answer? Why was this working paper created and why was this work done? What program step does it satisfy?

PROCEDURES: What did we do on this working paper? What methodology did we use? What were the detailed steps and procedures we performed?

RESULTS: What did the procedures yield? What were the results of applying the methodologies? This should contain the same language and easily link back to the procedure element. Here we also want a lot of detail.

CONCLUSION: What is the answer to the question posed in the purpose? Was the program step satisfied? What did we do with any issues we found? Did we take the issues to a finding or a point disposition sheet?

That kind of information couldn’t be any more helpful to a reviewer. Without these elements of a working paper, the reviewer has to make all sorts of logical leaps and assumptions to get through the working papers. We all know that five people can look at the same set of data and come to five different conclusions! You, the auditor, need to be making those conclusions for the reviewer. The last thing you want as a preparer is to have some crazy, overworked supervisor making assumptions and leaping around trying to link ideas together! Guide them.

Did you notice the linkage among the elements? If you do it right, the purpose and conclusions match and the procedures and results match. Auditors, this proves your clarity of thought and supports your logical conclusions. Reviewers, if these elements do not link together, return the working papers to the auditor until they can show you that what they’ve done has meaning!

An example

Here is a simple example. (You auditors of financial aid out there, please realize I made this up on an airplane after a long day of teaching. If you must critique it, please send your comments to www.leitadoesntwannahearit.com.)

SOURCE: Student files maintained in the Student Financial Aid Office by Julie Neal. Tested fall semester 2004 students.

PURPOSE: To determine whether students receiving federal student financial aid are eligible. To satisfy program step 2 at A-PGM.

PROCEDURE: Sampled 72 files out of a population of 13,500 files. Examined each file to determine whether the proper paperwork was in the file and that the student met federal eligibility requirements. The attributes tested are as follows:

Blah blah blah blah
Blah blah blah blah
Blah blah blah blah

RESULTS: Out of all attributes tested on 72 files, we noted only one error. The student had failed to initial one of the pages of the financial aid application.

CONCLUSION: Students receiving financial aid are eligible. The one error noted is not significant and we will not take it to the report.

This is one of my favorite Sharon requirements.

3. Every tick mark is explained

What, you say, is a tick mark!?! A tick mark is a little symbol that indicates a task the auditor has completed. For instance a ∧ may indicate that a column of numbers has been summed and a √ may indicate that attribute was verified.

To explain the tick marks in the working papers, Sharon had a little tick mark legend, which included about 15 tick marks (and we had to paste into the inside cover of each binder of working papers). You were not allowed to change the meaning of those tick marks!

This sped up her working paper review because she knew what you meant without having to look at a unique legend each time.

4. All cross references are two-way

To cross reference working papers, if you got a number for working paper A from working paper B, you would write “B” on working paper A near the number. And on working paper B, you would write a reference to working paper A.

Working paper review, especially on a financial audit, is nearly impossible without two-way cross referencing.

5. Each working paper is neat and legible

Wow, I always got written up for this. Thank the heavens for computers. It saved my career; my handwriting is atrocious.

6. Each working paper is referenced to the program

If you can’t tie the working paper to a program step, then you’d better take it out. Otherwise, you are subverting the audit program.

7. Each working paper is understandable without further explanation

This is a very high standard, indeed, but a good thing to keep in mind as you document your work. Imagine yourself in a meeting with the reviewer of your working papers and she says, “What did you mean here?” and you can’t remember! Your credibility goes down the drain.

8. Important calculations were verified

Verifying important calculations is crucial on a financial audit and why most new financial auditors are required to learn how to use a 10-key calculator their first week on the job. Someone needs to sum or recalculate the numbers. For very significant numbers, the supervisor might even recalculate them, too.

9. Source documents were included as necessary

This one is tricky. What does the reviewer actually need to understand about what you tested? Make sure that you include any source documents that will help the reviewer. To determine the right level of documentation, you had better check with your own personal Sharon to find out what she wants.

For instance, if you tested 30 files to see that the program director initialed a certain document, do you have to include in the file a copy of all 30 documents? I would say no. That would unnecessarily kill trees.

In my view, you only want to include a description of the files or the forms so that, if necessary, someone could replicate your work. So you might add a description of the file including the date created, name, director’s initials, and the date of review. You might even copy one of the forms and put it in the file just so a reviewer or a subsequent auditor could easily find the forms again.

If you have a few exceptions – in our example, these might be forms without initials – you could copy those and put them in the working papers with an explanation of how the issue was resolved. Also consider whether the issue will make it into the report. If it will, you might want to make copies of or scan in the exceptions to strengthen your evidence.

10. If the client creates a document, write “PBC” on the working paper

“PBC” indicates to the reviewer who created the working paper, which matters in determining strength of evidence. Generally, evidence directly obtained by the auditor is considered stronger than evidence that the client provides. The reason is that clients are not considered to be as objective as auditors about the information.

11. A review has been indicated

This is not a Sharon standard; it is a Yellow Book and an AICPA standard. How do you do this? Following are some ways that you can fulfill this requirement. The reviewer might:

  • Initial and date each working paper.
  • Initial only significant working papers.
  • Create a checklist and include it at the front of the working papers.
  • Initial the binder.
  • Write up review comments and include them in the working papers.

Which approach is right? This is left up to your professional judgment. Sharon’s professional judgment told her to initial each working paper, fill out a review checklist, and write review comments. Like I said, she was very thorough.

Empathy or self-interest – whatever works!

I think those are all reasonable requirements. Don’t you?

If empathy for the reviewer doesn’t make you want to put that stuff on your working papers, maybe a little self-interest will. I, too, preferred what I thought was the easy way out. But the older you get, the more you see that taking the easy way out now often costs us BIG later, right?

The reviewer’s friend, the summary memo

You might call the summary memo by another name: a lead sheet, a conclusions form, or a top memo. And it might have different components than what I will describe here. As we saw from the standards, we don’t absolutely have to have them.

If you don’t like the idea of a summary memo, no one could honestly criticize you for blowing them off. Many auditors are appalled at the idea of adding more to the working papers – horrified that someone would ask them to document even more stuff than they already do. I understand that. If you can figure out some other way to pull off the same feats, more power to you.

I have tried several times to work without them, and I can’t stand it. Summary memos are too helpful to ignore.

Your may have to use summary memos to make your reviewer’s life easier. Writing these memos force auditors to clarify their thoughts before wrapping up their projects, which makes understanding the working papers easier!

What the heck is a summary memo anyway?

A summary memo summarizes in a memo a group of working papers. (You suspected that, probably).

In the hierarchy of working papers, a summary memo usually comes third, even though they may be written lastly. The hierarchy is as follows:

  1. Audit Objective
  2. Audit Program
  3. Summary Memo
  4. Detail working papers

Let’s say that you are auditing a purchasing department. After gathering information and doing a risk assessment, you decide that you will focus on compliance in this audit.

Your overarching objective is: “Does the purchasing department comply with significant purchasing policies?” Underneath that overarching objective you have three sub-objectives:

  1. Are purchases of equipment exceeding $9000 conducted in accordance with policy?
  2. Are purchasing procedures written in accordance with policy?
  3.  Are professional contracts in accordance with policy?

You will likely create a set of working papers to support each sub-objective. Let’s say that you like to use letters to designate groups of working papers.

  • Sub-objective 1 is working paper set A, which answers whether purchases of equipment exceeding $9000 were conducted in accordance with policy.
  • Sub-objective 2 is working paper set B, which answers whether purchasing procedures are written in accordance with policy.
  • Sub-objective 3 is working paper set C, which answers whether professional contracts are in accordance with policy.

Then, the summary memo for sub-objective 1 summarizes what working paper series A accomplished and how you answered the audit objective with your evidence. Then A-1, A-2, A-3, etc. speak to the performance and results of each audit program step.

The summary memo is sort of a narrative version of the audit program and might fall above or beneath the program on the hierarchy.

The working paper hierarchy might look like this:

If you like, you can create a “meta” summary memo. This type of memo summarizes in a master summary memo working paper series A, B, and C and speaks to your overarching audit objective: “Does the purchasing department comply with significant policies?”

Now, don’t freak out, but you could have a summary memo for each audit program step. See working paper series A-4 above. That series contains plenty of working papers and may deserve a summary to help the reviewer sort through the group and discern what you did.

What can you put in a summary memo?

In my audit project management training, I ask the participants to separate into groups and then decide on the components of an ideal summary memo. Each group sketches out the components of the memo on apiece of flip chart paper on the wall.

This simple exercise usually causes quite a lot of debate. It uncovers passion for the content of the summary memo that many project managers are unaware that they possess. Other teams’ memos are clearly inferior as they leave so-and-so off – and wouldn’t it be better if so-and-so were included?!?

Who is right here? All of them. Who is right in your world? Your boss is right. When you become king or queen of the audit shop, you can have it your way. But for now, consider these optional components and find out whether your boss wants them included in the summary memo:

· Source, purpose, procedure, results, conclusion

I am a BIG fan of including a narrative description of these five components on every working paper.

Here is what a simple summary memo for series A might look like (this is just a sketch, you understand).

SOURCE: Interviews, observations, and testing described in working paper series A.

PURPOSE: To answer the sub-objective “Are purchases of equipment exceeding $9000 conducted in accordance with state law?”

PROCEDURE: Satisfied program steps on A-PGM which called on us to:

§ Reiterate program step 1.

§ Reiterate program step 2.

§ Reiterate program step 3.

§ Reiterate program step 4.

RESULTS: Several significant items on non-compliance were noted in our work:

· Summarize results of program step 1.

· Summarize results of program step 2.

· Summarize results of program step 3.

· Summarize results of program step 4.

CONCLUSION: The purchasing department did not comply with significant purchasing policies regarding purchases of equipment exceeding $9000. In particular, the department allows the same person to initiate, approve, and receive equipment purchases over $9000. This issue has been developed into a finding at REPT-1. We did not find any questionable purchases.

· The summary memo can serve as an initial draft of the report

Instead of referring to a finding in a working paper outside of the summary memo, you can include it in the summary memo, or you can formalize the section where you discuss the objective and conclusion and then just pull it out later to plug into the report.

· The summary memo can be very detailed or highly summarized

A summary memo can be a restatement of each supporting working paper underneath it PLUS an overarching conclusion that sums up the whole set. Or it can be an overarching conclusion that sums up the whole set.

Which way is right? Your boss’s way is right. A good way to gauge how much detail they prefer is to ask them how long they think the summary memo should be. If they say, “One page,” then it can’t reiterate all of the program steps and the detailed results of those steps. It will have to be highly summarized. If they say, “ten or so pages,” then you know they want all the detail laid out for them in one place.

· On a financial audit, the summary memo may be mostly numbers

On a financial audit, where the objective is to determine whether the financial statements are materially accurate and presented in accordance with GAAP, the summary memo might be a portion of the financial statements – like a breakout of the significant receivables categories on an Excel spreadsheet. Financial auditors often call these ”lead sheets” and they contain a minimal amount of narrative.

· Summary memos can take care of a good number of the required contents of working papers

The standards, of course, are silent regarding summary memos – as they are about most issues regarding working papers. If you recall, the Yellow Book requires that you document the following in your working papers – somewhere.

  • Characteristics of items tested
  • Objective, scope, and methodology
  • Nature, timing, and extent of procedures
  • Audit evidence obtained and its source and the conclusions reached
  • Support for significant judgments, findings, conclusions, and recommendations
  • Evidence of supervisory review

Because the standards are vague about how to pull this off or where you should document it, you could use a summary memo to do the majority of this work for you. You could take care of only part of these requirements in the detailed, supporting working papers.

By the way, I’m not sure I’d want to document on the summary memo the characteristics of the items tested. Characteristics involve A LOT of detail (characteristics for a document you tested might include the date and number and name on the file or document, the name of the person who signed off on the document, etc.) so that someone can replicate your work if they need to. But, if your supervisor wants that much detail, lay it on ‘em!

Reviewing working papers: keeping the big picture in mind

It is often very difficult to understand what the auditor was thinking and to retrace the thought process during an audit by looking at a set of working papers. It may take hours to get a sense of the overall purpose of the working papers.

Two simple guiding principles of working paper review make the task a little less daunting. Both have to do with keeping a big picture perspective. The first is to concentrate on concept before mechanics, and the second is to review working papers beginning at the top of the working paper hierarchy.

Check concepts before mechanics

I once was part of an audit team who expressed an opinion on a university’s bond issues. One of our more senior auditors took the lead in auditing bond arbitrage – a pretty technical subject. He spent two days auditing and creating a fabulous looking working paper. It was a huge, foldout spreadsheet that had several columns and rows and had plenty of colored tick marks and numbers. It was worthy of framing.

The supervisor started her review of this lovely spreadsheet. She re-footed and re-cross-footed the columns. She checked the meaning of all the lovely tick marks and added one of her own. And then, after spending about half-a-day reviewing it, she realized that the concept behind the working paper was flawed. The senior auditor had gone down a bunny trail and tested attributes that did not pertain to our audit objective.

The whole working paper was scrapped. So, the auditor had invested two days and the supervisor had invested half-a-day, and none of it was necessary.

Had the supervisor checked the concept of the working paper before the mechanics, she could have saved herself the effort. A half-day of precious audit budget could have been reserved.

So how do you check the concept behind the working paper? If your team uses the elements of a working paper (source, purpose, procedures, results, conclusions) in your working paper, then you should read that first, paying close attention to the purpose of the working paper. The purpose should correspond to a step on the audit program.

That is the next place I recommend you look. This, of course, assumes that the audit program is good. That leads to my next point.

Follow the hierarchy of working papers

Only if the top of the hierarchy works well and is understandable do you delve into the working papers at the bottom of the hierarchy. This saves time and effort.

The hierarchy of working papers is as follows:

  1. Audit Objective
  2. Audit Program
  3. Summary Memo
  4. Detail working papers

The first thing you look at, as a reviewer, is the audit objective. If the audit objective is flawed, you can stop right there. You can give the working papers back to the auditor and tell them to work on the objective and change the working papers accordingly.

Now that you are happy with the audit objective, you can review either the summary memo or the audit program. Some folks don’t create summary memos which may force you to look at the program. Or you may have to look at the audit program because the summary memo isn’t any good.

If you see that the program is disjointed and does not help satisfy the audit objective, you can again stop your working paper review and return the working papers to the auditor. No need in your going any further until the program is rewritten.

Assuming that your audit program and summary memo are good, you then can move on to the detailed supporting working papers. Those working papers should satisfy steps of the audit program. If they have a vague purpose or bad concept (i.e., are not relevant or meaningful), then you can stop there.

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