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CPE for Government Auditors

The 2018 Yellow Book is OUT!

The GAO issued the 2018 version of Generally Accepted Government Auditing Standards Tuesday.

Find the online version here: https://www.gao.gov/assets/700/693136.pdf.

Find an audio summary of the changes to the standards here: https://www.gao.gov/multimedia/podcast/692926

I suggest you scan chapter 4 and specifically section 4.16 to make sure you are compliant with the CPE requirements.

Also notice that the GAO has defined the roles of a supervisor and a reviewer inside the quality control chapter in sections 5.36-5.40.

And that the Green Book (Standards for Internal Control in the Federal Government) are mentioned several times in the document: 4.23, 6.30, 7.32, 8.41 & 8.130.

I’ll get back to you soon with a more thorough analysis of the changes and what they mean for you.

Stay cool!

What is an auditor?

Please enjoy this first chapter of self-study book Essential Skills for Government Auditor  available on YellowBook-CPE.com.

So here you are, an auditor. No other job title is more likely to be a conversation stopper at a dinner party.  No one likes to be audited.

But auditors do have an important role to play because, unfortunately, government leaders can’t trust program managers when they say, “Everything here is fine.  Don’t worry about us!” Government leaders and citizens do worry and want assurance from someone they can trust that everything is going well.  The auditor is that professional whom the leaders and the citizens can trust.

One definition of auditor is:  An independent professional who evaluates a subject matter against agreed-upon criteria.

This definition has several important components: independence, subject matter, and criteria.  Let’s look at each of those components in turn.

Independence

Auditors must be independent of their clients and the subject matter they are auditing.  But who are these clients?

The Government Accountability Office (GAO), the federal audit organization that writes the governmental auditing standards (a.k.a. the Yellow Book) has a very broad definition of client.  The GAO says, “A distinguishing mark of an auditor is acceptance of responsibility to serve the public interest.” And they define public interest as “the collective well-being of the community and entities the auditors serve.”  Did you know you had such a noble job?

CPAs are held to the same standard. They are certified “public” accountants after all. They have a primary responsibility to the public and a secondary responsibility to their audit client.

Clients in the government realm include management of the auditee, governing bodies, oversight bodies, special interest groups, other citizens, and the people who actually benefit from the government’s services.

If you think about it, auditors are often the only professionals involved in an organization or in a program who can comfortably speak the truth because they are, hopefully, shielded from backlash because they are independent.

GAGAS (Yellow Book) 20113.04     Auditors and audit organizations maintain independenceso that their opinions, findings, conclusions, judgments, and recommendations will be impartial and viewed as impartial by reasonable and informed third parties. Auditors should avoid situations that could lead reasonable and informed third parties to conclude that the auditors are not independent and thus are not capable of exercising objectiveand impartial judgment on all issues associated with conducting the audit and reporting on the work.

The recipients of governmental funds aren’t likely to uncover their own risks or highlight their own weaknesses because they could lose their funding. And the oversight bodies might be so far removed from the program that they don’t have a sense of what is really happening.

You can make quite a difference in an organization. The GAO’s Yellow Book says that you are “essential to the nation’s governing process!” Wow, that is quite a responsibility!

Consulting vs. Auditing

Some professionals who call themselves auditors are actually consultants. They help the client implement systems or spend months working to help the client with a technical issue. Consultants are allowed to get involved in the day-to-day operations of a department.

The Institute of Internal Auditors (one of the standard setting bodies that I will explain further in the next chapter) encourages consulting and has created consulting standards for their members.

The Government Accountability Office (GAO) calls consulting by another name, “non-audit services,” and puts up numerous barriers to prevent auditors from also serving as consultants. The GAO believes that you cannot both consult regarding an audit subject matter and later serve as objective, independent evaluator of the same subject matter.

In this text, our focus will be on auditing and auditing standards.

Subject matter and criteria

Auditors opine or conclude on whether a subject matter meets a certain criteria.

All auditors struggle to keep their audits limited in size and scope. It is extremely easy to create monstrous projects that are hard to reign in and report on.

In response to this struggle, most audit standards require that you develop a finite objective and scope for each engagement.   Imbedded in the audit objective are the audit subject and the criteria the auditor will use to evaluate the audit subject.

The GAO has this to say about the audit objective and scope in the Yellow Book:

GAGAS6.08The objectives are what the audit is intended to accomplish. They identify the audit subject matter and performance aspects to be included, and may also include the potential findings and reporting elements that the auditors expect to develop. Audit objectives can be thought of as questions about the program that the auditors seek to answer based on evidence obtained and assessed against criteria. The term “program” is used in GAGAS to include government entities, organizations, programs, activities, and functions.GAGAS 6.09

Scope is the boundary of the audit and is directly tied to the audit objectives. The scope defines the subject matter that the auditors will assess and report on, such as a particular program or aspect of a program, the necessary documents or records, the period of time reviewed, and the locations that will be included.

The objective and scope define what the project is, as well as what it is not. Objectives are assessed against agreed upon criteria, which are benchmarks established by law, governing organizations, or company policies and procedures. (For more on criteria, read Chapter 6.)

To satisfy the audit objective, you will gather and document audit evidence.  The techniques that you use to gather evidence are called audit methodologies.

6.10     The methodology describes the nature and extent of audit procedures for gathering and analyzing evidence to address the audit objectives. Audit procedures are the specific steps and tests auditors perform to address the audit objectives. Auditors should design the methodology to obtain reasonable assurance that the evidence is sufficient and appropriate to support the auditors’ findings and conclusions in relation to the audit objectives and to reduce audit risk to an acceptable level.

All three of these elements – the objective, scope, and methodology – are essential to describe what you seek to accomplish on the audit. (For more on methodology, see Chapter 15.)   The GAO requires that auditors both document these three defining elements in the working papers and disclose them in the audit report.

Audit deliverables

As Stephen Covey says, you should begin with the end in mind.  So before we dig in to the steps of conducting an audit, let’s look at what you will have when you are all done.  Auditors create three deliverables from an audit project:

  • The answer to the audit objective – called either an audit conclusion or an audit opinion
  • Findings – issues that the auditor would like to see addressed or corrected by the client
  • Working papers –documentation of the evidence the auditor gathered to support the conclusions and the findings.

If you are following GAO’s audit standards (The Yellow Book) for performance audits, you must put this promise – word for word – in your audit report:

7.30     We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

As you seek to satisfy your audit objectives, you will gather evidence using audit methodologies.  Some auditors call audit methodologies audit tests or audit program steps.  The results of applying these methodologies must be documented.

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.

Questions auditors answer

In order to give the client assurance regarding an audit subject, you must answer questions that naturally arise as you seek the answer to your audit objective.

Notice that these questions assume that something is wrong.  Auditors tend to think that way!  Because of time constraints, auditors focus on risks, negative events, and the issues that need fixing instead of proving the good that occurs in an organization.  In that way, auditors are like journalists.

  1. What is the current state of affairs? (condition)
  2. What should be the current state of affairs? (criteria)
  3. What has caused the current state of affairs? (cause)
  4. Why is the current state of affairs undesirable? (effect)
  5. What should be done to correct the current state of affairs? (recommendation)

You will see these questions used in later chapters and referred to as the “elements of a finding.” Auditors following IIA & GAO standards use them to write audit findings when they find something that needs to be corrected, such as an internal control weakness, non-compliance, fraud, and/or abuse.

What I hope to do in this text is show you the steps auditors follow to create their three main deliverables (the conclusion/opinion, the findings, and the audit documentation) as well as give you the tools to answer these questions for your clients.

Let’s tweak that definition of an auditor

Now that we have discussed independence, audit subject matter, audit criteria, and audit deliverables, we should tweak our definition of an auditor. We began the chapter with this definition: An independent professional who evaluates a subject matter against agreed-upon criteria.

Please allow me to enhance it a bit based on what we just read: An auditor is an independent professional who concludes whether a subject matter meets an agreed upon criteria by gathering evidence through performing custom-designed audit methodologies.  Aren’t you glad I didn’t start with that?

Yellow Book Ethics

Enjoy this excerpt from the self-study text: The Yellow Book Interpreted which qualifies for 15 hours of CPE.

 

The GAO has a few things to say about a government auditor’s ethical responsibilities and, thus, added a large section on ethics to the 2007 revision of the Yellow Book.  The same ethical principles appear in the 2017 exposure draft.

Themes of GAGAS
GAGAS is a very high-minded document.  And, in order to understand the GAO’s perspective on ethics, we need to talk about three themes of the Yellow Book that kick off the first chapter of the standards.

These three themes — accountability, transparency, and service -­- put us in the right frame of mind when auditing in the government environment.

Accountability
What is accountability? I had heard the term tossed around the government so frequently that I never even thought about its meaning.  Now I know that accountability does not mean that you got it right. It just means that you take ownership of it.

I met a cowboy auditor in West Texas who said, “You might be right or you might be wrong, but you’d better the hell document it.”  That sums up accountability quite nicely.  When things go bad, you are there to say, “Yes, that was me.  I’m sorry.”  When things go well, you can keep your job.

Recently on CNN, I saw a high school coach who was responsible for the death of one of his teenage football players.  And instead of being contrite, he said something like, “Everyone is forgetting that I suffered a loss, too, and that I will hold on to this for the rest of my life.”  That is not exactly what the parents of that boy wanted to hear. He deflected accountability and tried to engender empathy for himself.  I doubt that will serve him well in his community.

The GAO repeatedly reminds us that we are accountable to the taxpaying public for our actions and that we, as auditors, have a role in holding government leaders accountable.

1.01      The concept of accountability for use of public resources and government authority is key to our nation’s governing processes.

1.03     Government auditing is essential in providing accountability to legislators, oversight bodies, those charged with governance, and the public. Audits provide an independent, objective, nonpartisan assessment of the stewardship, performance, or cost of government policies, programs, or operations, depending upon the type and scope of the audit.

One of the tough things about the GAO standards is they are not written for government officials (although government officials are mentioned a few times); they are written as standards for auditors.  So, while we hold public officials and employees accountable for their actions, we are accountable for our actions, too.

Transparency
Actions and information that is transparent is open for everyone’s inspection and review.

1.05     Audits performed in accordance with GAGAS provide information used for oversight, accountability, transparency, and improvements of government programs and operations. GAGAS contains requirements and guidance to assist auditors in objectively acquiring and evaluating sufficient, appropriate evidence and reporting the results. When auditors perform their work in this manner and comply with GAGAS in reporting the results, their work can lead to improved government management, better decision making and oversight, effective and efficient operations, and accountability and transparency for resources and results.

The state of Texas has put every single transaction online – LIVE— and rates the transparency of local government as well.  I can, with a few clicks of the mouse, see that the Texas Department of Transportation bought a van, how much the van was, who they bought it from, why they need it, and what color of funds (general revenue, special revenue, enterprise revenues) paid for it.

Why?  Because citizens own the government, and we have a right to know.  Google “windows on Texas state government” to start your own exploration.

Service
If you audit Hurst Construction, your ultimate audience for the audit report is Mr. Hurst, his board of directors, and the bank.  But, if you audit a public housing project, your ultimate clients are not the managers of the project, the boards of directors, or the banks.  Your ultimate beneficiaries of the report are not even the grantors.  The ultimate beneficiaries of your work are the low-income children who live in the housing project.

We have to remember, as governmental auditors, that we are checking to see whether tax dollars are being used for their intended purpose and whether the public is being served by our auditee’s efforts.

1.16      A distinguishing mark of an auditor is acceptance of responsibility to serve the public interest. This responsibility is critical when auditing in the government environment. GAGAS embodies the concept of accountability for public resources, which is fundamental to serving the public interest.

We hold our clients to a higher standard of behavior than we do in the commercial sector. While it was OK for AIG to go on a lavish $500,000 spa junket before the US taxpayers bailed them out, it certainly was not OK after the bailout.

Later, we will see that the GAO asks you to report even more bad behaviors than the AICPA does.  If Mr. Hurst wants to put his jet-setting, never-worked-a-day-in–their-life kids on the payroll, more power to him. Auditors in the commercial realm do not have a responsibility to say anything about that. But in the government realm, we call that abuse, and we do have a responsibility to report it.  We’ll discuss more about abuse later.

Five main sections of the ethics section
The ethics discussion is divided into five main principles:

a.   The public interest
b.   Integrity
c.   Objectivity
d.   Proper use of government information, resources, and position
e.    Professional behavior

Let’s discuss each one in turn.

The public interest 
A city auditor once told me that he sees a higher purpose in his work.  It is his job to make sure that the monies collected by the city are turned back to support those who need services and who may not have a voice in the government.  He works on the citizens’ behalf, and because of this higher purpose, he doesn’t care whether he makes his auditees upset with his reports.  Now that is integrity!

1.15      The public interest is defined as the collective well-being of the community of people and entities the auditors serve. Observing integrity, objectivity, and independence in discharging their professional responsibilities assists auditors in meeting the principle of serving the public interest and honoring the public trust. The principle of the public interest is fundamental to the responsibilities of auditors and critical in the government environment.

In my business I transfer in and out of two worlds – the government world and the commercial world – and indeed they are different.

An auditor from the GAO made the distinction between the two by saying that in the commercial world fortunes are made by doing what is not expressly prohibited; in the government world action won’t be taken unless it is expressly permitted.

Commercial entities do not seek transparency.  At the Apple corporate headquarters store, they sell a T-Shirt that says, “I visited the Apple Corporate Offices in Cupertino… and that is all I can say about it.”

But government auditors must shine light in dark places in order to serve their customer, the public.  And taxpayers get very, very upset if even a tiny bit of their hard-earned tax dollars are squandered.

Not long ago, I was helping a government employee retirement system develop a training event. Afterwards, to celebrate our success, we all went out to a first-rate steakhouse in Dallas – you know the type, where you pay $45 for an à la carte steak. We had wine and appetizers, and one guy ordered a $35 brandy. I was very uncomfortable. I thought that if any of their members walked in and recognized them as the folks in charge of their retirement funds, the retirement system would have a lot of explaining to do. The retirees don’t want their money squandered on high living for government employees!

If you work for a corporation, go ahead and enjoy the perks and the luxuries. But when you work for government, don’t be surprised if you can’t even get a cup of coffee!

Integrity & Objectivity
Many seasoned professionals have told me that they believe that auditor independence is an unattainable ideal; an external auditor’s independence is compromised when the auditee writes a check to pay the auditor’s fee and an internal auditor takes a salary from the entity they audit. They argue, that at best, an auditor can provide an objective viewpoint and maintain integrity by making sure that external pressures do not force them to cover up the truth.

Later in this text, when we examine the GAO’s guidance for independence, the concepts of integrity and objectivity introduced here in the ethics chapter are raised again.

Both the integrity and objectivity sections of the ethics chapter of the Yellow Book mention auditor independence and freedom from political or ideological bias.

Integrity
1.17      Public confidence in government is maintained and strengthened by auditors performing their professional responsibilities with integrity. Integrity includes auditors conducting their work with an attitude that is objective, fact-based, nonpartisan, and nonideological with regard to audited entities and users of the auditors’ reports… 

1.18      … In discharging their professional responsibilities, auditors may encounter conflicting pressures from management of the audited entity, various levels of government, and other likely users. Auditors may also encounter pressures to inappropriately achieve personal or organizational gain. In resolving those conflicts and pressures, acting with integrity means that auditors place priority on their responsibilities to the public interest.

Objectivity
1.19      The credibility of auditing in the government sector is based on auditors’ objectivity in discharging their professional responsibilities. Objectivity includes independence of mind and appearance when providing audits, maintaining an attitude of impartiality, having intellectual honesty, and being free of conflicts of interest…The concepts of objectivity and independence are closely related…

Proper use of government information, resources, and position
A professor at UT Arlington teaches ethics and leadership to government leaders in Romania. He develops case studies for them to ponder each week.

One case study asked the students to discuss the ethical dilemma posed when a mayor used city employees to build a brick barbecue pit in his backyard – clearly an improper use of government resources. The professor didn’t hear back from his students in Romania for a month.

After several Skype conversations, the Romanians finally admitted that they just didn’t understand the ethical issue in the scenario. Using the labor of government employees for personal benefit is one of the perks of being a government leader in Romania! That professor has a lot of work to do!

1.20     Government information, resources, and positions are to be used for official purposes and not inappropriately for the auditor’s personal gain or in a manner contrary to law or detrimental to the legitimate interests of the audited entity or the audit organization. This concept includes the proper handling of sensitive or classified information or resources.

1.23     Misusing the position of an auditor for financial gain or other benefits violates an auditor’s fundamental responsibilities. An auditor’s credibility can be damaged by actions that could be perceived by an objective third party with knowledge of the relevant information as improperly benefiting an auditor’s personal financial interests or those of an immediate or close family member; a general partner; an organization for which the auditor serves as an officer, director, trustee, or employee; or an organization with which the auditor is negotiating concerning future employment.

Professional behavior
Any behavior that could cause someone to question your professionalism can detract from your credibility. And credibility helps sell audit recommendations.

1.24     High expectations for the auditing profession include compliance with all relevant legal, regulatory, and professional obligations and avoidance of any conduct that might bring discredit to auditors’ work, including actions that would cause an objective third party with knowledge of the relevant information to conclude that the auditors’ work was professionally deficient…

Consider the following true scenario (with a few small changes to protect identities): You are the internal audit director of a large city. You recently hired a new auditor fresh out of college and assigned him to conduct a performance audit of your city’s police department.

Everything has been going well until last week when you saw a photo of him in the local newspaper at the city’s Mardi Gras celebration. He was pictured near the top of a street light without his shirt wearing dozens of bead necklaces. The police stood below and appeared to be yelling at him to come down.

You show him the picture and he becomes immediately defensive and tells you that what he does on his own time is none of your business. He reasoned that he had some college buddies in town and it was natural for him to show them a good time.

This standard on professional behavior does not mention that it applies only to an auditor’s work life. But does this auditor’s behavior during his personal time compromise his credibility with the police force? Yes, indeed!  How is he going to face the officers during an exit conference?

To maintain your shop’s professional image, you will probably have to remove this young auditor from the engagement and replace him with another auditor from your shop.

Auditors are paid for our credible, objective, high integrity opinions and conclusions about an audit subject.  And this young man blew all that away with his antics.

Borrowing from the later discussion on independence in chapter 3:

3.04     Auditors and audit organizations maintain independence so that their opinions, findings, conclusions, judgments, and recommendations will be impartial and viewed as impartial by reasonable and informed third parties. Auditors should avoid situations that could lead reasonable and informed third parties to conclude that the auditors are not independent and thus are not capable of exercising objective and impartial judgment on all issues associated with conducting the audit and reporting on the work.

In our next chapter, we will address the types of audits covered by Yellow Book standards.

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