Today I provide an overview of how this standard affects nonprofit revenue recognition.
ASU 2018-08: Nonprofit Contribution Recognition
The purpose of the standard is to provide guidance in regard to recognizing contributions in nonprofit organizations. This standard is conceptually consistent with Topic 606, Revenue from Contracts with Customers, which requires revenue to be recognized when performance obligations are satisfied. ASU 2018-08 requires contribution revenue recognition when conditions are met (see below).
Once ASU 2018-08 becomes effective (years ending December 31, 2019 for many nonprofits), nonprofits will recognize revenues in one of three ways:
The financial statement presentation of the revenue can be affected by the nature of the transaction.For example, there might be a conditional contribution and a donor restriction for the same monies. So contribution revenue will not be recognized until the barriers are satisfied (see below), but revenue will appear in with donor restriction or without donor restriction on the statement of activities, depending on the specifics of the transaction.
1. Exchange transaction
If a nonprofit is paid based on commensurate value, then there is an exchange transaction. The nonprofit recognizes revenue as it provides the service or goods. Apply Topic 606, Revenue from Contracts With Customers, for these transactions. An example of an exchange transaction is a nonprofit is paid market rate for painting a local store.
ASU 2018-08 makes it plain that benefits received by the public as a result of the assets transferred is not equivalent to commensurate value received by the resource provider.
2. Conditional Contribution
A conditional contribution is one where:
a barrier is present and
a right of return or right of release for the contributor exists
The following are indicators of a barrier:
Recipient must achieve a measurable, performance-related outcome (e.g., providing a specific level of service, creating an identified number of units of output, holding a specific event)
A stipulation limits the recipient’s discretion on the conduct of the activity (e.g., specific guidelines about incurring qualifying expenses)
A stipulation is related to the primary purpose of the agreement (e.g., must report on funded research)
Recognize revenue when the barrier is overcome.
An example of meeting a measurable outcome would be if the donor requires the serving of meals to 1,000 homeless persons. Another example of the first indicator above is a matching requirement.
An example of limited discretion would be a requirement to hire specific individuals to conduct an activity.
Stipulation Related to Grant's Primary Purpose
An example of a stipulation related to the primary purpose of the agreement is a grant that requires the filing of an annual report of funded research. If the grantor requires repayment of the amount received should the report not be filed, then the requirement is a barrier.
Judgment is necessary to determine whether a requirement is a barrier. For example, filing routine reports to a resource provider showing progress on a funded activity may be seen as routine and not a barrier. Goals or budgets where no penalty is assessed if the organization fails to achieve them are not considered barriers.
Effect of Budgets
Are budgets an indicator of limited discretion? A line-item budget for a grant is often seen as a guardrail rather than a barrier. A June 2019 FASB Q&A states “Thus, stipulations other than adherence to a budget (for example, the need to incur qualifying expenses) would normally need to be present for a barrier to entitlement to exist.” The Q&A goes on to say, “The unique facts and circumstances of each grant agreement must be analyzed within the context of the indicators to conclude whether a barrier to entitlement exists.”
Recognition of Contribution
Per ASU 2018-08 “Conditional contributions received are accounted for as a liability or are unrecognized initially, that is, until the barriers to entitlement are overcome, at which point the transaction is recognized as unconditional and classified as either net assets with restrictions or net assets without restrictions.”
3. Unconditional Contribution
If there are no barriers or if barriers have been overcome, the receipt is unconditional.There might still be a purpose or time restriction, resulting in the funds being classified as “With Donor Restrictions” until the restriction is satisfied. Recognize the revenue either as:
Net Assets with Donor Restriction
Net Assets without Donor Restriction
A public company or a not-for-profit organization that has issued, or is a conduit bond obligor for, securities that are traded, listed, or quoted on an exchange or an over-the-counter market would apply the new standard for transactions in which the entity serves as a resource recipient to annual reporting periods beginning after June 15, 2018, including interim periods within that annual period. Other organizations would apply the standard to annual reporting periods beginning after December 15, 2018, and interim periods within annual periods beginning after December 15, 2019.
A public company or a not-for-profit organization that has issued, or is a conduit bond obligor for, securities that are traded, listed, or quoted on an exchange or an over-the counter market would apply the new standard for transactions in which the entity serves as a resource provider to annual reporting periods beginning after December 15, 2018, including interim periods within that annual period. Other organizations would apply the standard to annual reporting periods beginning after December 15, 2019, and interim periods within annual periods beginning after December 15, 2020.
Per ASU 2018-08, “Accounting for contributions is an issue primarily for not-for-profit (NFP) entities because contributions are a significant source of revenue for many of those entities. However, the amendments in this Update apply to all entities, including business entities, that receive or make contributions of cash and other assets, including promises to give within the scope of Subtopic 958-605 and contributions made within the scope of Subtopic 720-25, Other Expenses—Contributions Made.”
In this post, I provide ten steps to better audit workpapers.
Have you ever been insulted by a work paper review note?
Your tickmarks look like something my six-year old created.
Rather than providing guidance,the comment feels like an assault.
Or maybe as a reviewer you stare at a workpaper and you’re thinking, “what the heck is this?” Your stomach tightens and you say out loud, “I can’t understand this.”
There are ways to create greater audit workpaper clarity.
10 Steps to Better Audit Workpapers
Here are ten steps to make your workpapers sparkle.
Timely review. The longer the in-charge waits to review work papers, the harder it is for the staff person to remember what they did and, if needed, to make corrections. Also, consider that the staff person may be reassigned to another job. Therefore, he may not be available to clear the review notes.
Communicate the purpose.
a. An unclear work paper is like a stone wall. It blocks communication.
b. State the purpose; for example:
Purpose of Work Paper – To search for unrecorded liabilities as of December 31, 2018. Payments greater than $30,000 made from January 1, 2019, through March 5, 2019, were examined for potential inclusion in accounts payable.
Purpose of Work Paper – To provide a detail of accounts receivable that agrees with the trial balance; all amounts greater than $20,000 agreed to subsequent receipt.
If the person creating the work paper can’t state the purpose, then maybe there is none. It’spossible that the staff person is trying to copy prior year work that (also) had no purpose.
c. All work papers should satisfy a part of the audit program (plan). No corresponding audit program step? Then the audit program should be updated to include the step—or maybe the work paper isn’t needed at all.
3. The preparer should sign off on each workpaper(so it’s clear who created it).
4. Audit program steps should be signed off as the work is performed (not at the end of the audit–just before review). The audit program should drive the audit process—not the prior year workpapers.
5. Define tickmarks.
6. Reference work papers. (If you are paperless, use electronic links.)
7. Communicate the reason for each journal entry.
The following explanation would not be appropriate:
To adjust to actual.
A better explanation:
To reverse client-prepared journal entry 63 that was made to accrue the September 10, 2018, Carter Hardware invoice for $10,233.
8. When in doubt, leave it out.
Far too many documents are placed in the audit file simply because the client provided them. Moreover, once the work paper makes its way into the file, auditors get “remove-a-phobia“–that dreaded sense that if the auditor removes the work paper, he may need it later.
If you place those unneeded documents in your audit file and do nothing with them, they may create potential legal issues. I can hear the attorney saying, “Mr. Hall, here is an invoice from your audit file that reflects fraud.”
Again, does the work paper have a purpose?
My suggestion for those in limbo: Place them in a“file 13” stack until you are completely done. Then–once done–destroy them. I place these documents in a recycle bin at the bottom of my file.
9. Complete forms. Blanks should not appear in completed forms (use N/A where necessary).
10. Always be respectful in providing feedback to staff. It’s too easy to get frustrated and say or write things we shouldn’t. For instance, your audit team is more receptive to:
Consider providing additional detail for your tickmark: For instance–Agreed invoice to cleared check payee and dollar amount.
This goes over better than:
You failed to define your tickmark–again?
What other ways do you make your audit workpapers sparkle? Comment below.
The AICPA has issued SSARS 25. It is titled Materiality in a Review of Financial Statements and Adverse Conclusions. Below I tell you how this standard affects your future review engagements.
Materiality in Review Engagements
Until SSARS 25, there was no requirement for you to document materiality in review engagements. Some firms, like my own, decided to do so any way. Others have not. Now, there's no choice. SSARS 25 explicitly requires that we determine and use materiality.
Makes sense. The accountant's conclusion says we are not aware of any material modifications that should be made. The conclusion paragraph follows:
Based on our review, we are not aware of any material modifications that should be made to the accompanying financial statements in order for them to be in accordance with accounting principles generally accepted in the United States of America.
It would be difficult to plan or conclude a review engagement without knowing what materiality is. SSARS 25 requires that we design and perform analytical procedures and inquiries to address all material items in the financial statements. This includes disclosures.
New Inquiry Requirements
SSARS 25 adds new inquiries of management including:
Material commitments, contractual obligations, or contingencies
Material nonmonetary transactions
Significant changes in the business activities or operations
Significant changes to the terms of contracts that materially affect the financial statements
Significant journal entries
Status of any uncorrected misstatements from the previous review engagement
How management determined that significant estimates are reasonable
Management's assessment of the entity's ability to continue as a going concern, and whether there are conditions that cast doubt about the entity's ability to continue as a going concern
Related Party Transactions
Additionally, SSARS 25 requires that the accountant remain alert for related party transactions that were not disclosed by management. The accountant should inquire of management about transactions outside the normal course of business. You want to know if related party transactions are being used to make the financial statements look better than they really are.
Next, you will see that the standard now permits adverse conclusions.
Adverse Conclusions in Review Engagements
In the past, adverse conclusions in a review engagement were not allowed. SSARS 25 changes this. If the financial statements are materially and pervasively misstated, you can issue an adverse conclusion.
SSARS 25 provides an illustrative accountant's review report with an adverse conclusion. (See illustration 7 on pages 85 and 86 of SSARS 25.) That example states the financial statements are not in accordance with accounting principles generally accepted in the United States of America.
Here's the adverse review report conclusion:
Based on my (our) review, due to the significance of the matter described in the Basis for Adverse Conclusion paragraph, the financial statements are not in accordance with accounting principles generally accepted in the United States of America.
One more thing, SSARS 25 requires a statement in the review report regarding independence.
Independence in Review Reports
Independence is still required to perform a review engagement. What is different, however, is the accountant must include a statement in the review report saying he or she is independent. That phrase, to be included in the Accountant's Responsibility section of the report, reads as follows:
We are required to be independent of ABC Company and to meet our other ethical responsibilities, in accordance with the relevant ethical requirements related to our review.
See examples of the independence wording in the illustrative reports in SSARS 25. Those reports start on page 75 of the standard.
So when is SSARS 25 effective?
SSARS 25 Effective Date
The effective date for SSARS 25 is for periods ending on or after December 15, 2021. Early implementation is permitted.
Control risk continues to create confusion in audits. Some auditors assess control risk at less than high when they shouldn't. Others assess control risk at high when it would be better if they did not. The misunderstandings about this risk can result in faulty audits and problems in peer review. In this article, I explain what control risk is and how you can best leverage it to perform quality audits in less time.
Control Risk Defined
What is control risk? It’s the chance that an entity’s internal controls will not prevent or detect material misstatements in a timely manner.
Companies develop internal controls to manage inherent risk. The greater the inherent risk, the greater the need for controls.
Audit Risk Model
As we begin this article, think about control risk in the context of the audit risk model:
Audit risk = Inherent risk X Control risk X Detection risk
Recall the client’s risk is made up of inherent risk and control risk. And the remainder, detection risk, is what the auditor controls. Auditors gain an understanding of inherent risk and control risk. Why? To develop their audit plan and lower their detection risk (the risk that the audit will not detect material misstatements). Put more simply, the auditor understands the client’s risk in order to lower her own.
After the auditor gains an understanding of the entity and its environment, including internal controls, control risk is often assessed at high. Why? Two reasons: one has to do with efficiency and the other with weak internal controls.
Assessing Control Risk at High
Consider the first reason for high control risk assessments: efficiency.
Control risk can be assessed at high, even if—during your walkthroughs— you see that controls are properly designed and in use. But why would you assess this risk at high when controls are okay?
Let me answer that question with a billing and collection example.
Risk At High: Efficiency Decision
You can test billing and collection internal controls for effectiveness (assuming your walkthrough reveals appropriate controls). But if this test takes eight hours and a substantive approach takes five hours, which is more efficient? Obviously, the substantive approach. And if you use a fully substantive approach, you must assess control risk at high for all relevant assertions.
At this point, you may still be thinking, But, Charles, if controls are appropriately designed and implemented, why is control risk high? Because a test of controls is required for control risk assessments below high: the auditor needs a basis (evidence) for the lower assessment. And a walkthrough is not (in most cases) considered a test of controls for effectiveness: it does not provide a sufficient basis for the lower risk assessment. A walkthrough provides an initial impression about controls, but that impression can be wrong. That’s why a test of controls is necessary when control risk is below high, to prove the effectiveness of the control.
In our example above, a substantive approach is more efficient than testing controls. So we plan a substantive approach and assess control risk at high for all relevant assertions.
Risk at High: Weak Controls
Now, let’s look at the second reason for high control risk assessments: weak internal controls. Here again, allow me to explain by way of example.
If the billing and collection cycle walkthrough reveals weak internal controls, then control risk is high. Why? Because the controls are not designed appropriately or they are not in use. In other words, they would not prevent or detect a material misstatement. You could test those controls for effectiveness. But why would you? They are ineffective. Consequently, risk has to be high. Why? Again, because there is no basis for the lower risk assessment. (Even if you tested controls, the result would not support a lower risk assessment: the controls are not working.)
If, on the other hand, controls are appropriate, then you might test them (though you are not required to).
Assessing Control Risk at Less than High
What if, based on your walkthrough, controls are okay. And you believe the test of controls will take four hours while a substantive approach will take eight hours? Then you can test controls for effectiveness. And if the controls are effective, you can assess the risk at less than high. Now you have support for the lower risk assessment.
But what if you test controls for effectiveness and the controls are not working? Then a substantive approach is your only choice.
Many auditors don’t test controls for this reason: they are afraid the test of controls will prove the controls are ineffective. For example, if you test sixty transactions for the issuance of a purchase order, and seven transactions are without purchase orders, the sample does not support effectiveness. The result: the test of controls is a waste of time.
Some auditors mistakenly believe they don’t need an understanding of controls because they plan to use a fully substantive audit approach. But is this true?
Fully Substantive Audit Approach
Weak internal controls can result in more substantive procedures, even if you normally use a substantive approach.
Suppose you assess control risk at high for all billing and collection cycle assertions and plan to use a fully substantive approach. Now, consider two scenarios, one where the entity has weak controls, and another where controls are strong.
Billing and Collection Cycle - Weak Controls
Think about a business that has a cash receipt process with few internal controls. Suppose the following is true:
Two employees receipt cash
They both work from one cash drawer
The two employees provide receipts to customers, but only if requested
They apply the payments to the customer’s accounts, but they also have the ability to adjust (reduce or write off) customer balances
At the end of the day, one of the two employees creates a deposit slip and deposits the money at a local bank (though this is not always done in a timely manner)
These same employees also create and send bills to customers
Additionally, they reconcile the related bank account
Obviously, a segregation of duties problem exists and theft could occur. For example, the clerks could steal money and write off the related receivables. Child’s play.
Billing and Collection Cycle - Strong Controls
But suppose the owner detects theft and fires the two employees. He does background checks on the replacements. Now the following is true:
A separate cash drawer is assigned to each clerk
The controller is required to review customer account adjustments on a daily basis (the controller can’t adjust receivable accounts)
The cash receipt clerks reconcile their daily activity to a customer receipts report, and the money along with the report is provided to the controller
The controller counts the daily funds received and reconciles the money to the cash receipts report
Then the controller creates a deposit slip and provides the funds and deposit slip to a courier
Once the deposit is made, the courier gives the bank deposit receipt to the controller
A fourth person (that does not handle cash) reconciles the bank statement in a timely manner
The monthly customer bills are created and mailed by someone not involved in the receipting process
Moreover, the owner reviews a monthly cash receipts report
Now, let me ask you: would you use the same substantive audit procedures for each of the above scenarios? Hopefully not. The first situation begs for a fraud test. For example, we might test the adjustments to receivables on a sample basis. Why? To ensure the clerks are not writing off customer balances and stealing cash.
Audit Procedures: Basic and Extended
Basic audit procedures for the billing and collection cycle might include:
Test the period-end bank reconciliation
Create substantive analytics for receivable balances and revenues
Confirm receivable accounts and examine subsequent receipts
We perform these basic procedures whether controls are good or weak. But we would add—when controls are weak and might allow theft—extended substantive procedures such as testing accounts receivable adjustments.
Do you see how the understanding of controls impacts planning (even when control risk is assessed at high)? If we were unaware of the control weaknesses, we would not plan the needed fraud detection procedures.
In summary, we need to understand controls even if we plan to use a fully substantive approach, and even if risks are assessed at high for all assertions. More risk means more audit work.
A Simple Summary
Control risk is the probability that an entity’s internal controls will not prevent or detect material misstatements in a timely manner
Internal control weaknesses may require a control risk assessment of high
Control risk can only be assessed below high when a test of control proves the control to be effective (the test of control provides the basis for the lower risk assessment)
If walkthroughs show controls to be appropriately designed and implemented, the auditor can (1) assess control risk at high and use a fully substantive approach, or (2) assess control risk below high and test controls for effectiveness, whichever is most efficient
Even if an auditor intends to use a fully substantive approach, walkthroughs are necessary to determine if additional substantive tests are needed; additional substantive procedures may be necessary when material fraud is possible due to internal control weaknesses
For additional information about risk assessment, see the AICPA's SAS 145, Understanding the Entity and Its Environment and Assessing the Risk of Material Misstatement. The guidance was issued in October 2021.
Statement on Auditing Standards No. 145 (SAS 145), Understanding the Entity and Its Environment and Assessing the Risks of Material Misstatement, updates the risk assessment standards. Auditors need to be aware of these upcoming changes.
Conceptually, risk assessment remains the same, but some particulars are different and significantly affect how you audit. SAS 145 is voluminous, but below I summarize the salient points to make it easy for you to digest--or, at least, as easy as I could.
Separate assessments of inherent risk and control risk
You’ll see several new definitions below. Understanding those is critical to understanding SAS 145.
SAS 145 Topics
This article addressesthe following SAS 145 topics:
Separate inherent and control risk assessments
Assessing control risk at the maximum level
Inherent risk factors and spectrum of risk
Significant classes of transactions, account accounts, and disclosures
Information technology (IT) controls
System of internal control
Increasing complexity of entities and auditing
Effective date of SAS 145
Separate Inherent and Control Risk Assessments
Most auditors have assessed inherent and control risk separately for some time, but those separate assessments were previously not required. SAS 145, however, requires that auditors individually assess these two risks at the assertion level. Interestingly, documenting a combined inherent and control risk assessment is not required.
You can assess inherent risk and control risk in various ways; the standard does not specify a particular means of doing so. For instance, you might use high, moderate, or low; or use a scale of one to ten (more about this in a moment).
Assessing Control Risk at the Maximum Level
Many auditors assess control risk at high or maximum, regardless of the internal control structure--whether the controls are designed appropriately and implemented or not. You might plan to use a fully substantive approach; for example, when substantive procedures take less time than testing controls for effectiveness.
If you decide not to test controls for effectiveness, SAS 145 requires that you assess control risk at the maximum (or high) so that the risk of material misstatement is the same as the inherent risk assessment.
So, if control risk is assessed at maximum, can the evaluation of the design and implementation of controls (i.e., walkthroughs) still impact the planned audit procedures? Yes. Increased risk leads to a change in nature, timing, and extent of planned audit procedures. For example, if your walkthrough reveals a lack of segregation of duties, you may need to add more substantive procedures to address fraud risk.
On the other hand, if a test of controls for effectiveness supports a lower control risk, you can bring the assessment below maximum. But you cannot lower control risk without the support of a test of controls for effectiveness.
Your inherent risk assessment is crucial if you use a fully substantive approach. Why? Because SAS 145 requires that inherent risk be the same as the risk of material misstatement. If your inherent risk is assessed higher than it should be, you’ll perform unnecessary work to address the risk and waste time.
The Auditing Standards Board provides a new definition for significant risks. The first part of the definition (see paragraph 12 of SAS 145 for the full definition) is as follows:
A significant risk is an identified risk of material misstatement for which the assessment of inherent risk is close to the upper end of the spectrum of inherent risk due to the degree to which inherent risk factors affect the combination of the likelihood of a misstatement occurring and the magnitude of the potential misstatement should that misstatement occur.
(Note - the blog author bolded some words in the definition above for emphasis.)
The prior significant risk definition focused on the response to the risk, not the risk itself. That guidance said it was a risk that needed special audit consideration.
The new definition focuses on the risk itself. To be clear, the risk of material misstatement. Notice the new definition requires consideration of likelihood and magnitude. In other words, probability and dollar impact. Also, notice the description is based solely on inherent risk, with no consideration of control risk. (See my article about significant risks.)
Inherent Risk Factors and Spectrum of Risk
SAS 145 defines inherent risk factors as:
Characteristics of events or conditions that affect the susceptibility to misstatement, whether due to fraud or error, of an assertion about a class of transactions, account balance, or disclosure, before consideration of controls. Such factors may be qualitative or quantitative and include complexity, subjectivity, change, uncertainty, or susceptibility to misstatement due to management bias or other fraud risk factors insofar as they affect inherent risk.
Depending on the degree to which the inherent risk factors affect the susceptibility of an assertion to misstatement, the level of inherent risk varies on a scale that is referred to as the spectrum of inherent risk.
(Note - the blog author bolded some words in the definition above for emphasis.)
Inherent Risk Factors
Consider the likelihood of misstatement in light of the inherent risk factors, including:
Susceptibility to misstatement due to management bias or other fraud risk factors (in terms of how they affect inherent risk)
So as you consider the inherent risk of an assertion, use these factors to determine the likelihood of misstatement. Then consider the magnitude of the potential misstatement. If the risk is close to the upper end of the spectrum of risk (for inherent risk) and the potential misstatement is material, then the entity has a significant risk.
Ten-Point Scale, An Example
I like to evaluate significant risks on a ten-point scale, with ten being the highest risk. While SAS 145 does not use such an illustration, a nine or a ten is a significant risk, provided it can lead to a material misstatement. For example, a bank’s allowance for loan losses is usually a significant risk because it is a complex estimate in a material account balance. In making this assessment, we disregard internal controls.
One additional change is SAS 145 removes the requirement to determine whether there are significant risks at the financial statement level.
The term relevant assertion has also changed.
Using SAS 145, relevant assertions are based on classes of transactions, account balances, and disclosures with an identified risk of material misstatement.
Before SAS 145, we looked at relevant assertions as they related to material classes of transactions, account balances, and disclosures. And relevant assertions were those that had a meaningful bearing on whether an account was fairly stated. (I never knew what meaningful bearing meant.)
The new relevant assertion definition is clearer. Assertions are considered in light of:
Likelihood of misstatement
Magnitude of misstatement
Relevant Assertion Definition
In SAS 145, a relevant assertion is defined as:
An assertion about a class of transactions, account balance, or disclosure is relevant when it has an identified risk of material misstatement. A risk of material misstatement exists when (a) there is a reasonable possibility of a misstatement occurring (that is, its likelihood), and (b) if it were to occur, there is a reasonable possibility of the misstatement being material (that is, its magnitude). The determination of whether an assertion is a relevant assertion is made before consideration of any related controls (that is, the determination is based on inherent risk).
(Note - the blog author bolded some words in the definition above for emphasis.)
Probability and Dollar Impact
A relevant assertion is an identified risk of material misstatement when a reasonable possibility of its occurrence is present. Reasonable possibility means a more than a remote chance of happening. And if it happens, a material misstatement must be possible. Again we see an emphasis upon probability and dollar impact. And again, internal controls are ignored in making this determination. That is, inherent risk is the basis for determining which assertions are relevant.
As an example, suppose high-technology components comprise inventory that becomes obsolete quickly. Your valuation assertion is inherently risky, and if inventory is a significant account balance, then valuation is a relevant assertion. Notice we made this determination without regard for the related controls. Moreover, we believe there is a reasonable possibility of obsolescence.
Once again, we see that inherent risk is vital in SAS 145.
We said that relevant assertions relate to significant classes of transactions, account balances, and disclosures. But what are significant classes?
Significant Classes of Transactions, Account Balances, and Disclosures
In SAS 145, significant classes of transactions, account balances, or disclosures are defined in the following manner:
Significant class of transactions, account balance, or disclosure. A class of transactions, account balance, or disclosure for which there is one or more relevant assertions.
So a significant class is one with a relevant assertion--one where the likelihood of material misstatement is more than remote.
So, if an account balance like receivables, for example, has a relevant assertion, it’s a significant class.
Purpose of the Definition
The purpose of this definition is to provide clarification concerning the scope of the auditor’s work. In other words, this definition tells us where to focus. We’ll perform risk assessment procedures and assess risk in the significant classes of transactions, account balances, and disclosures. It is in these areas where we will plan responses to the identified risks therein. SAS 145 requires substantive procedures for each significant class of transactions, account balances, and disclosures with relevant assertions.
Consider this: if plant, property, and equipment (PP&E) is material, but there is no relevant assertion for the account balance, it is not a significant area. Suppose a company has $10 million in PP&E (a material balance) and it purchases no new capital assets during the year. There is only one PP&E asset, a building, which has appreciated. Is there a relevant assertion? Probably not. Why? There is little likelihood of material misstatement.
Now change the scenario and suppose the building suffers an earthquake. Is PP&E a significant class? Yes, if substantial damage occurred. Why? Because you now have a relevant assertion: valuation.
Once you have designated all significant classes of transactions, account balances, and disclosures, evaluate all remaining material areas to see if the initial scope determination is appropriate. Is there a remaining account balance, transaction class, or disclosure that needs our attention, even though it did not qualify as a significant area? If yes, then plan audit procedures accordingly.
The main point here is that the auditor focuses upon significant classes of transactions, account balances, and disclosures first(those with relevant assertions) and then remaining material amounts (which don’t have relevant assertions). For instance, say you choose cash, receivables/revenues, payables/expenses, and payroll as your significant areas, but not plant, property, and equipment (PP&E) because it has no relevant assertion. In the stand-back phase, ask yourself if PP&E deserves audit scrutiny. If it does, plan PP&E audit procedures.
A company might have disclosures that are not significant (e.g., executive compensation), but you decide to audit it anyway. Why? You believe the scope of your planned audit is incomplete without it.
The purpose of the stand-back provision is to ensure completeness of the auditor’s identification of transactions, account balances, and disclosures--the areas the auditor plans to audit.
The complexity of an entity’s activities and environment drive the scalability of applying SAS 145.
Size and complexity do not necessarily correlate. Smaller entities tend to be less complex, but some are not--they are complex. Larger entities tend to be more complicated, but some are not. So consider the accounting system, the industry, the internal controls including information technology, and other factors in applying SAS 145.Complexity, not the entity’s size, determines how you use this standard.
Some entities may lack formal internal control policies. Even so, such a system of internal controls can still be functional. Therefore, auditors can vet these informal controls with inquiries, observations, and inspection of documents. In other words, risk assessment works even in small entities with informal controls.
The nature and extent of risk assessment procedures will vary depending upon the nature and circumstances of the entity. Therefore, auditors should exercise judgment in determining the nature and extent of risk assessment procedures. For example, risk assessment procedures can be less for a non-complex business with simple processes. In such a company, the auditor might have fewer inquiries to understand the business and fewer preliminary analytics.
Audit procedures in an initial audit may be more extensive. After the initial audit period, the auditor can focus on changes since then. (Even so, auditors still need to annually review the design and implementation of key controls related to significant transaction classes, account balances, disclosures.)
Understanding the entity and its environment, including its reporting framework, is a foundation for professional skepticism. Auditors determine the evidence needed for risk assessment in light of the entity’s nature and accounting system.
SAS 145 highlights the need for auditors to maintain professional skepticism during the engagement team discussion.
Professional skepticism allows the auditor to:
Appropriately deal with contradictory information
Evaluate the responses received from management and those charged with governance
Be alert to potential misstatement due to fraud or error
Consider audit evidence in light of the entity’s nature and circumstances
Professional skepticism is necessary for evaluating audit information in an unbiased manner, leading to better identification and assessment of risks of material misstatement.
Information Technology (IT) Controls
SAS 145 emphasizes IT controls as they affect the risk of material misstatement. The standard introduces a new term: risk arising from the use of IT. And it defines general IT controls.
So what IT controls are you to consider? Those that affect the risk of material misstatement at the assertion level.
Here’s how I think about this:
Start with the risk of material misstatement at the assertion level
Determine the IT applications that affect the assertion
Review the general IT controls that affect the IT applications
IT Relevant Assertion Example
For example, say occurrence is a relevant assertion for expenses. Then you might consider an IT control that requires a three-way match for invoice processing; the software will not allow a disbursement without matching the invoice amount, the purchase order amount, and the quantity in the receiving document. In such a system, the IT application is the payables module in the software.
An example of a general control (see definition below) for this application is the password for access to the payables module.
Why is the general IT control (the password) important? If a password was not necessary, then anyone could process payments. And this affects the occurrence assertion.
As the auditor performs a walkthrough for payables, she will (for example):
Inspect the three-way match documents.
Observe the payables module in use.
Inspect the logical access records from IT, showing who has access to the payables module.
Observe the entry of a password by a payables clerk.
You don’t need to review all general controls, only those related to risks arising from the use of IT.
Risk Arising from the Use of IT
SAS 145 defines risk arising from the use of ITas:
Susceptibility of information-processing controls to ineffective design or operation, or risks to the integrity of information in the entity’s information system, due to ineffective design or operation of controls in the entity’s IT processes.
Lower IT Risk
Entities are less likely to be subject to risks arising from the use of IT when they:
Use stand-alone applications
Have low volumes of transactions
Have transactions supported by hard-copy documents
Higher IT Risks
Entities are more likely to be subject to risks arising from the use of IT when they:
Have interfaced applications
Have high volumes of transactions
Have applications that automatically initiate transactions
General IT Controls
SAS 145 defines general IT controls as:
Controls over the entity’s IT processes that support the continued proper operation of the IT environment, including the continued effective functioning of information-processing controls and the integrity of information in the entity’s information system.
Examples of general IT controls include firewalls, backup and restoration, intrusion detection, passwords, physical security, and antivirus protection.
Increasing Complexity of Entities and Auditing
SAS 145 recognizes the increasing complexity of entities and auditing. It does so by highlighting audit methods and tools such as:
Remote observation of assets using drones or video cameras
Use of data analytics software and visualization techniques to identify risks of material misstatement
Performing risk assessment on large volumes of data, including analysis, recalculations, reperformance, and reconciliations
System of Internal Control
SAS 145 replaces the term internal control with system of internal control. It defines system of control as:
The system designed, implemented, and maintained by those charged with governance, management, and other personnel to provide reasonable assurance about the achievement of an entity’s objectives with regard to reliability of financial reporting, effectiveness and efficiency of operations, and compliance with applicable laws and regulations. For purposes of GAAS, the system of internal control consists of five interrelated components:
i. Control environment
ii. The entity’s risk assessment process
iii. The entity’s process to monitor the system of internal control
iv. The information system and communication
v. Control activities
It appears the Auditing Standards Board is highlighting the holistic nature of internal controls by including all five of the COSO control elements.
SAS 145 Documentation Requirements
Auditors must document their evaluation of the design of identified controls and their determination of whether such controls were implemented.
Additionally, auditors must document their rationale for significant judgments regarding identified and assessed risks of material misstatement. In other words, how did you identify a risk of material misstatement, and why did you assess it as you did?
What is the criterion for determining whether the risk assessment documentation is appropriate? As in the past, it’s whether an experienced auditor having no previous experience with the audit understands the nature, timing, and extent of the risk assessment procedures. So, document the rationale for your risk assessment work and your conclusions.
Effective Date of SAS 145
SAS 145 is effective for audits of financial statements for periods ending on or after December 15, 2023.