Reporting Views of Responsible Officials

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GAO-03-673G Government Auditing Standards > Chapter 6 General, Field Work, and Reporting Standards for Attestation Engagements > Reporting Views of Responsible Officials


6.41 The standard related to reporting the views of responsible officials for attestation engagements performed in accordance with GAGAS is:

If the auditors’ report on the attestation engagement discloses deficiencies in internal control, fraud, illegal acts, violations of provisions of contracts or grant agreements, or abuse, auditors should obtain and report the views of responsible officials concerning the findings, conclusions, and recommendations, as well as planned corrective actions.

6.42 One of the most effective ways to ensure that a report is fair, complete, and objective is to obtain advance review and comments by responsible officials of the audited entity and others, as may be appropriate. Including the views of responsible officials results in a report that presents not only the deficiencies in internal control, fraud, illegal acts, violations of provisions of contracts or grant agreements, or abuse the auditors identified, but also what the responsible officials of the audited entity think about the deficiencies in internal control, fraud, illegal acts, violations of provisions of contracts or grant agreements, or abuse and what corrective actions the officials plan to take. Auditors should include in their report a copy of the officials’ written comments or a summary of the comments received.

6.43 Auditors should normally request that the responsible officials submit in writing their views on the auditors’ reported findings, conclusions, and recommendations, as well as management’s planned corrective actions. Oral comments are acceptable as well, and, in some cases, may be the only or most expeditious way to obtain comments. Cases in which obtaining oral comments can be effective include circumstances in which there is a time-critical requirement to meet a user’s needs; the auditors have worked closely with the responsible officials throughout the conduct of the work and the parties are familiar with the findings and issues addressed in the draft product; or the auditors do not expect major disagreements with the draft report’s findings, conclusions, and recommendations, or perceive any major controversies with regard to the issues discussed in the draft report. Before finalizing the report, auditors should prepare a summary of the officials’ oral comments and provide a copy of the summary to officials of the audited entity to verify that the comments are accurately stated.

6.44 Comments should be fairly and objectively evaluated and recognized, as appropriate, in the final report. Comments, such as a promise or plan for corrective action, should be noted but should not be accepted as justification for deleting a significant finding or a related recommendation.

6.45 When the audited entity’s comments oppose the report’s findings, conclusions, or recommendations, and are not, in the auditors’ opinion, valid, or when planned corrective actions do not adequately address the auditors’ recommendations, the auditors should state their reasons for disagreeing with the comments or planned corrective actions. The auditors’ disagreement should be stated in a fair and objective manner. Conversely, the auditors should modify their report as necessary if they find the comments valid.


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