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Chapter 5: Reporting Standards for Financial Audits


(Revised through Amendment 2)

 
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Purpose

5.1 This chapter prescribes standards of reporting for financial audits, which include financial statement audits and financial related audits
 
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Relation to AICPA Standards

Revised July 1999

5.2 For financial statement audits, generally accepted government auditing standards (GAGAS) incorporate the American Institute of Certified Public Accountants' (AICPA) four generally accepted standards of reporting, which are:

a. The report shall state whether the financial statements are presented in accordance with generally accepted accounting principles.

b. The report shall identify those circumstances in which such principles have not been consistently observed in the current period in relation to the preceding period.

c. Informative disclosures in the financial statements are to be regarded as reasonably adequate unless otherwise stated in the report.

d. The report shall either contain an expression of opinion regarding the financial statements, taken as a whole, or an assertion to the effect that an opinion cannot be expressed. When an overall opinion cannot be expressed, the reasons therefor should be stated. In all cases where an auditor's name is associated with financial statements, the report should contain a clear-cut indication of the character of the auditor's work, if any, and the degree of responsibility the auditor is taking.

5.3 The AICPA has issued statements on auditing standards (SAS) that interpret its standards of reporting.1 This chapter incorporates these SASs and prescribes additional standards on

a. reporting compliance with GAGAS (see paragraphs 5.11 through 5.14),

b. reporting on compliance with laws and regulations and on internal control over financial reporting (see paragraphs 5.15 through 5.28),

c. privileged and confidential information (see paragraphs 5.29 through 5.31), and

d. report distribution. (See paragraphs 5.32 through 5.35.)

[NOTE 1: GAGAS incorporate any new AICPA reporting standards relevant to financial statement audits unless the General Accounting Office (GAO) excludes them by formal announcement.]

5.4 This chapter concludes by explaining which standards auditors should follow in reporting the results of financial related audits

5.5 Deleted

5.6 Deleted

5.7 Deleted

5.8 Deleted

5.9 Deleted

5.10 Deleted (Note 2 deleted)

 
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Reporting Compliance with Generally Accepted Government Standards

Revised July 1999

5.11 The first additional reporting standard for financial statement audits is

Audit reports should state that the audit was made in accordance with generally accepted government auditing standards.

5.12 The above statement refers to all the applicable standards that the auditors should have followed during their audit. The statement should be qualified in situations where the auditors did not follow an applicable standard. In these situations, the auditors should disclose the applicable standard that was not followed, the reasons therefor, and how not following the standard affected the results of the audit.

5.13 When the report on the financial statements is submitted to comply with a legal, regulatory, or contractual requirement for a GAGAS audit, it should specifically cite GAGAS. The report on the financial statements may cite AICPA standards as well as GAGAS.

5.14 The auditee may need a financial statement audit for purposes other than to comply with requirements calling for a GAGAS audit. For example, it may need a financial statement audit to issue bonds. GAGAS do not prohibit auditors from issuing a separate report on the financial statements conforming only to the requirements of AICPA standards. However, it may be advantageous to use a report issued in accordance with GAGAS for these other purposes because it provides information on compliance with laws and regulations and internal controls (as discussed below) that is not contained in a report issued in accordance with AICPA standards.

 
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Reporting on Compliance with Laws and Regulations and on Internal Control Over Financial Reporting

Revised July 1999

5.15 The second additional reporting standard for financial statement audits is

The report on the financial statements should either (1) describe the scope of the auditors' testing of compliance with laws and regulations and internal control over financial reporting and present the results of those tests or (2) refer to the separate report(s) containing that information. In presenting the results of those tests, auditors should report fraud, illegal acts, other material noncompliance, and reportable conditions in internal control over financial reporting.3 In some circumstances, auditors should report fraud and illegal acts directly to parties external to the audited entity.

[NOTE 3: These responsibilities are in addition to and do not modify auditors’ responsibilities under AICPA standards to (1) address the effect fraud or illegal acts may have on the report on the financial statements and (2) determine that the audit committee or others with equivalent authority and responsibility are adequately informed about fraud, illegal acts, and reportable conditions.]

5.16 Auditors may report on compliance with laws and regulations and internal control over financial reporting in the report on the financial statements or in separate report(s). When auditors report on compliance and internal control over financial reporting in the report on the financial statements, they should include an introduction summarizing key findings in the audit of the financial statements and the related compliance and internal control work. Auditors should not issue this introduction as a stand-alone report.

5.16.1 When auditors report separately (including separate reports bound in the same document) on compliance with laws and regulations and internal control over financial reporting, the report on the financial statements should state that they are issuing those additional reports. The report on the financial statements should also state that the reports on compliance with laws and regulations and internal control over financial reporting are an integral part of a GAGAS audit, and in considering the results of the audit, these reports should be read along with the auditors' report on the financial statements.

Scope of Compliance and Internal Control Work

5.17 Auditors should report the scope of their testing of compliance with laws and regulations and of internal control over financial reporting, including whether or not the tests they performed provided sufficient evidence to support an opinion on compliance or internal control over financial reporting and whether the auditors are providing such opinions.

Fraud, Illegal Acts, and Other Noncompliance

5.18 When auditors conclude, based on evidence obtained, that fraud or an illegal act either has occurred or is likely to have occurred,4 they should report relevant information. Auditors need not report information about fraud or an illegal act that is clearly inconsequential. Thus, auditors should present in a report the same fraud and illegal acts that they report to audit committees under AICPA standards. Auditors should also report other noncompliance (for example, a violation of a contract provision) that is material to the financial statements.

[NOTE 4: Whether a particular act is, in fact, illegal may have to await final determination by a court of law. Thus, when auditors disclose matters that have led them to conclude that an illegal act is likely to have occurred, they should take care not to imply that they have made a determination of illegality.]

5.19 In reporting material fraud, illegal acts, or other noncompliance, the auditors should place their findings in proper perspective. To give the reader a basis for judging the prevalence and consequences of these conditions, the instances identified should be related to the universe or the number of cases examined and be quantified in terms of dollar value, if appropriate.5 In presenting material fraud, illegal acts, or other noncompliance, auditors should follow chapter 7's report contents standards for objectives, scope, and methodology; audit results; views of responsible officials; and its report presentation standards, as appropriate. Auditors may provide less extensive disclosure of fraud and illegal acts that are not material in either a quantitative or qualitative sense.6

[NOTE 5: Audit findings have often been regarded as containing the elements of criteria, condition, and effect, plus cause when problems are found. However, the elements needed for a finding depend entirely on the objectives of the audit. Reportable conditions and noncompliance found by the auditor may not always have all of these elements fully developed, given the scope and objectives of the specific financial audit. However, auditors should identify at least the condition, criteria, and possible asserted effect to provide sufficient information to federal, state, and local officials to permit them to determine the effect and cause in order to take prompt and proper corrective action.]

[NOTE 6: Chapter 4 provides guidance on factors that may influence auditors' materiality judgments in audits of government entities or entities receiving government assistance. AICPA standards provide guidance on the interaction of quantitative and qualitative considerations in materiality judgments.]

5.20 When auditors detect fraud, illegal acts, or other noncompliance that do not meet paragraph 5.18's criteria for reporting, they should communicate those findings to the auditee, preferably in writing. If auditors have communicated those findings in a management letter to top management, they should refer to that management letter when they report on compliance. Auditors should document in their working papers all communications to the auditee about fraud, illegal acts, and other noncompliance.

Direct Reporting of Fraud and Illegal Acts

5.21 GAGAS require auditors to report fraud or illegal acts directly to parties outside the auditee in two circumstances, as discussed below. These requirements are in addition to any legal requirements for direct reporting of fraud or illegal acts. Auditors should meet these requirements even if they have resigned or been dismissed from the audit.7

[NOTE 7: Internal auditors auditing within the entity that employs them do not have a duty to report outside that entity.]

5.22 The auditee may be required by law or regulation to report certain fraud or illegal acts to specified external parties (for example, to a federal inspector general or a state attorney general). If auditors have communicated such fraud or illegal acts to the auditee, and it fails to report them, then the auditors should communicate their awareness of that failure to the auditee's governing body. If the auditee does not make the required report as soon as practicable after the auditors' communication with its governing body, then the auditors should report the fraud or illegal acts directly to the external party specified in the law or regulation.

5.23 Management is responsible for taking timely and appropriate steps to remedy fraud or illegal acts that auditors report to it. When fraud or an illegal act involves assistance received directly or indirectly from a government agency, auditors may have a duty to report it directly if management fails to take remedial steps. If auditors conclude that such failure is likely to cause them to depart from the standard report on the financial statements or resign from the audit, then they should communicate that conclusion to the auditee's governing body. Then, if the auditee does not report the fraud or illegal act as soon as practicable to the entity that provided the government assistance, the auditors should report the fraud or illegal act directly to that entity.

5.24 In both of these situations, auditors should obtain sufficient, competent, and relevant evidence (for example, by confirmation with outside parties) to corroborate assertions by management that it has reported fraud or illegal acts. If they are unable to do so, then the auditors should report the fraud or illegal acts directly as discussed above.

5.25 Chapter 4 reminds auditors that under some circumstances, laws, regulations, or policies may require them to report promptly indications of certain types of fraud or illegal acts to law enforcement or investigatory authorities. When auditors conclude that this type of fraud or illegal act either has occurred or is likely to have occurred, they should ask those authorities and/or legal counsel if reporting certain information about that fraud or illegal act would compromise investigative or legal proceedings. Auditors should limit their reporting to matters that would not compromise those proceedings, such as information that is already a part of the public record.

Deficiencies in Internal Control

5.26 Auditors should report deficiencies in internal control that they consider to be "reportable conditions" as defined in AICPA standards. The following are examples of matters that may be reportable conditions:

a. absence of appropriate segregation of duties consistent with appropriate control objectives;

b. absence of appropriate reviews and approvals of transactions, accounting entries, or systems output;

c. inadequate provisions for the safeguarding of assets;

d. evidence of failure to safeguard assets from loss, damage, or misappropriation;

e. evidence that a system fails to provide complete and accurate output consistent with the auditee's control objectives because of the misapplication of control procedures;

f. evidence of intentional override of internal control by those in authority to the detriment of the overall objectives of the system;

g. evidence of failure to perform tasks that are part of internal control, such as reconciliations not prepared or not timely prepared;

h. absence of a sufficient level of control consciousness within the organization;

i. significant deficiencies in the design or operation of internal control that could result in violations of laws and regulations having a direct and material effect on the financial statements; and

j. failure to follow up and correct previously identified deficiencies in internal control.8

[NOTE 8: Chapter 4's audit follow-up standard requires auditors to report the status of uncorrected material findings and recommendations from prior audits that affect the financial statement audit.]

5.27 In reporting reportable conditions, auditors should identify those that are individually or cumulatively material weaknesses.9 Auditors should follow chapter 7's report contents standards for objectives, scope, and methodology; audit results; and views of responsible officials; and its report presentation standards, as appropriate.

[NOTE 9: See footnote 5.]

5.28 When auditors detect deficiencies in internal control that are not reportable conditions, they should communicate those deficiencies to the auditee, preferably in writing. If the auditors have communicated other deficiencies in internal control in a management letter to top management, they should refer to that management letter when they report on internal control. All communications to the auditee about deficiencies in internal control should be documented in the working papers.

 
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Privileged and Confidential Information

Revised July 1999

5.29 The third additional reporting standard for financial statement audits is

If certain information is prohibited from general disclosure, the audit report should state the nature of the information omitted and the requirement that makes the omission necessary.

5.30 Certain information may be prohibited from general disclosure by federal, state, or local laws or regulations. Such information may be provided on a need-to-know basis only to persons authorized by law or regulation to receive it.

5.31 If such requirements prohibit auditors from including pertinent data in the report, they should state the nature of the information omitted and the requirement that makes the omission necessary. The auditors should obtain assurance that a valid requirement for the omission exists and, when appropriate, consult with legal counsel.

 
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Report Distribution

Revised July 1999

5.32 The fourth additional reporting standard for financial statement audits is

Written audit reports are to be submitted by the audit organization to the appropriate officials of the auditee and to the appropriate officials of the organizations requiring or arranging for the audits, including external funding organizations, unless legal restrictions prevent it. Copies of the reports should also be sent to other officials who have legal oversight authority or who may be responsible for acting on audit findings and recommendations and to others authorized to receive such reports. Unless restricted by law or regulation, copies should be made available for public inspection. 10

[NOTE 10: See the Single Audit Act Amendments of 1996 and Office of Management and Budget (OMB) Circular A-133 for the distribution of reports on single audits of state and local governmental entities and nonprofit organizations that receive federal awards.]

5.33 Audit reports should be distributed in a timely manner to officials interested in the results. Such officials include those designated by law or regulation to receive such reports, those responsible for acting on the findings and recommendations, those of other levels of government that have provided assistance to the auditee, and legislators. However, if the subject of the audit involves material that is classified for security purposes or not releasable to particular parties or the public for other valid reasons, auditors may limit the report distribution.

5.34 When public accountants are engaged, the engaging organization should ensure that the report is distributed appropriately. If the public accountants are to make the distribution, the engagement agreement should indicate which officials or organizations should receive the report.

5.35 Internal auditors should follow their entity's own arrangements and statutory requirements for distribution. Usually, they report to their entity's top managers, who are responsible for distribution of the report.

 
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Financial Related Audits

Revised July 1999

5.36 Certain AICPA standards address specific types of financial related audits, and GAGAS incorporate those standards, as discussed below:11

a. SAS No. 75, Engagements to Apply Agreed-Upon Procedures to Specific Elements, Accounts, or Items of a Financial Statement;

b. SAS No. 62, Special Reports, for auditing specified elements, accounts, or items of a financial statement;

c. SAS No. 74, Compliance Auditing Considerations in Audits of Governmental Entities and Recipients of Governmental Financial Assistance, for testing compliance with laws and regulations applicable to federal financial assistance programs;

d. SAS No. 70, Reports on the Processing of Transactions by Service Organizations, for examining descriptions of internal control of service organizations that process transactions for others;

e. Statement on Standards for Attestation Engagements (SSAE) No. 1, Attestation Standards, as amended by SSAE No. 9, Amendments to Statement on Standards for Attestation Engagements Nos. 1, 2, and 3, for examining or reviewing an entity's assertions about financial related matters not specifically addressed in other AICPA standards;

f. SSAE No. 2, Reporting on an Entity's Internal Control Over Financial Reporting, as amended by SSAE No. 9, Amendments to Statement on Standards for Attestation Engagements Nos. 1, 2, and 3, for examining an entity's assertions about its internal control over financial reporting and/or safeguarding assets;

g. SSAE No. 3, Compliance Attestation, as amended by SSAE No. 9, Amendments to Statement on Standards for Attestation Engagements Nos. 1, 2, and 3, for (1) examining or applying agreed-upon procedures to an entity's assertions about compliance with specified requirements or (2) applying agreed-upon procedures to an entity's assertions about internal control over compliance with laws and regulations; and

h. SSAE No. 4, Agreed-Upon Procedures Engagements, for applying agreed-upon procedures to (1) an entity’s assertions about internal control over financial reporting and/or safeguarding of assets or (2) an entity’s assertions about financial related matters not specifically addressed in other AICPA standards.

[NOTE 11: GAGAS incorporate any new AICPA reporting standards relevant to financial related audits unless GAO excludes them by formal announcement.]

5.37 Besides following applicable AICPA standards, auditors should follow this chapter's first (GAGAS reference), third (privileged and confidential information), and fourth (report distribution) additional standards of reporting. They should apply or adapt the other standards and guidance in this chapter as appropriate in the circumstances. For financial related audits not described above, auditors should follow the reporting standards for performance audits in chapter 7. 12

[NOTE 12: Chapter 2 provides examples of other types of financial related audits.]


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Updated 8/13/99