Quality Assurance and Improvement Program Last updated: February 2014 International Standards for the Professional Practice of Internal Auditing (Standards) – 1300 Internal Audit’s Quality Assurance and Improvement Program (QAIP) is designed to provide reasonable assurance to the various stakeholders of the Treasury Cluster’s Internal Audit activity that Internal Audit: Performs its work in accordance with its Charter, which is consistent with The Internal Audit and Risk Management Policy for NSW Public Sector TPP 09-05 and The Institute of Internal Auditors International Standards for the Professional Practice of Internal Auditing (Standards); Operates in an effective and efficient manner; and Is perceived by stakeholders as adding value and improving Internal Audit’s operations. Internal Audit’s QAIP covers all aspects of the Internal Audit activity (1300). This Program covers: Number 1310 1311 1312 1320 1330 1340 1 Standard Description Quality Program Assessments Internal Audit should adopt a process to monitor and assess the overall effectiveness of the quality program. The process should include both internal and external assessments. Internal Internal assessments should include: Assessments Ongoing reviews of the performance of Internal Audit. Periodic reviews performed through self-assessment or by other persons within the organisation, with knowledge of Internal Audit practices and the Standards. External External assessments must be conducted at least once every five years by Assessments a qualified, independent reviewer or review team from outside the organisation. The chief audit executive must discuss with the Board1: The need for more frequent external assessments; and The qualifications and independence of the external reviewer or review team, including any potential conflict of interest. Reporting on the The Chief Audit Executive should communicate the results of external Quality Program assessments to the Board. Use of Internal auditors are encouraged to report that their activities are "conducted "Conducted in in accordance with the International Standards for the Professional Practice of Accordance with Internal Auditing." However, internal auditors may use the statement only if the Standards" assessments of the quality improvement program demonstrate that the internal audit activity is in compliance with the Standards. Disclosure of Although internal audit activity should achieve full compliance with the Noncompliance Standards and internal auditors with the Code of Ethics, there may be instances in which full compliance is not achieved. When noncompliance impacts the overall scope or operation of the internal audit activity, disclosure should be made to senior management and the board. In the Treasury Cluster, “the Board” should be read as “the Secretary or relevant CEO” (since there are Cluster entities for which the Secretary is not the CEO). For the purpose of this document “the Audit and Risk Committee” should be read as accompanying or, where the Secretary or other CEO prefers, replacing him/her; except in the case of 1340. The Chief Audit Executive (CAE) is ultimately responsible for the QAIP. NSW TREASURY QAIP 1 INTERNAL ASSESSMENTS - 1311 Ongoing Reviews Ongoing assessments are conducted through 1 Supervision of engagements. Potential Components Include There is a scheduling process for internal audit engagements and the associated project management. Internal audit engagements are supervised to assure conformance with the approved methodology for conducting internal audit engagements and conformance with the Standards. Assessment Criteria There is an up-to-date Internal Audit Manual. Treasury Assessment Yes – new update posted in March 2014 When By who Annually – next update February 2015 Updated by Internal Audit Program Manager (IAPM). Approved by CAE There is an approved Internal Audit Plan. Yes – last approved September 2013 Annually – next June 2014 Approved by Secretary. There is a formal QA signoff process over internal audit engagements. Yes. Service Provider’s quality review process completed at front of each audit report. Ongoing. Per audit. The CAE attends opening meetings and closing meetings for internal audit engagements. Yes Service Provider. Completed by IAPM. Approved by CAE Yes. Finalisation of Internal Audit – Checklist completed for each engagement. Contains QA process. Signed by CAE. NSW TREASURY QAIP Completed by Service Provider and CAE. Ongoing. Per Audit. CAE 2 Ongoing assessments are conducted through 2 3 Regular, documented review of work papers during engagements by appropriate Internal Audit staff. Audit Policies and Procedures used for each engagement to ensure compliance with applicable planning, fieldwork NSW TREASURY QAIP Potential Components Include Internal audit engagements are supervised to assure conformance with the approved methodology for conducting internal audit engagements and conformance with the Standards. There is an Internal Audit Manual of policy and procedures in place. Internal Audit has access to appropriate auditing tools and Assessment Criteria Treasury Assessment When By who Internal audit reports are signed off by the CAE. Yes. Signed off by CAE when report is formally sent to the Secretary. Ongoing. At completion of audit. CAE There is a consistent methodology for conducting internal audit engagements and for preparing working papers. Yes. Methodology is agreed in detailed scope prior to each audit and is in conformance with the Audit Manual and Risk Mgt Framework. (project briefs are in conformance with Audit Manual) Ongoing. At beginning and end of each audit. Reviewed by IAPM. All scopes signed off by CAE Draft working papers reviewed when draft report is issued. Final working papers reviewed when final report is issued. There is a formal QA signoff process over internal audit engagements. ASAE 3000 compliance reviewed as part of the Finalisation of Internal Audit – Checklist completed for each engagement. At the end of each audit. Completed by IAPM. Approved by CAE. There is an up-to-date Internal Audit Manual. Yes – new update posted in March 2014 Annually – next update February 2015 Updated by Internal Audit Program Manager (IAPM). In consultation with Service Provider Approved by CAE 3 Ongoing assessments are conducted through and reporting standards. Potential Components Include uses technology where relevant. Quality assurance and process improvement activities are monitored within Internal Audit, including formal quality assessment processes. NSW TREASURY QAIP Assessment Criteria Treasury Assessment When By who There is a consistent methodology for conducting internal audits and for preparing working papers. Yes – agreed in detailed scope in conformance with Audit Manual. Ongoing. At beginning of each audit. Reviewed by IAPM. All scopes signed off by CAE Internal Audit staff and service providers have been trained in use of the approved Internal Audit methodology. Yes – Treasury Internal Audit Program Manager and Service Provider core team are chartered accountants trained in IA methodology. In addition Service Provider staff are subject to an annual training program which includes IA methodology training. Completed. IAPM. E&Y staff. There is a formal QA signoff process over internal audit engagements. Yes. Finalisation of Internal Audit – Checklist completed for each engagement. Contains QA process. Signed by CAE. Ongoing. Per audit. Completed by IAPM. Approved by CAE There is consideration of the use of data extraction and analysis techniques, risk assessment tools, tools for internal audit engagement planning, etc. Risk Management Toolkit for the NSW Public Sector (TPP12-03) used as the gold standard in public sector. Complete Treasury Internal Audit single service provider has access to appropriate auditing tools and uses technology where relevant. Ongoing. When required. Internal Audit Service Provider in consultation with CAE 4 Ongoing assessments are conducted through 4 5 Feedback from customer survey on individual engagements. Analyses of performance metrics established to improve the IA effectiveness and efficiency. Potential Components Include Assessment Criteria Treasury Assessment When By who Post-audit customer feedback surveys of Internal Audit customers are used as a mechanism for continuous improvement. Internal Audit customer comments at closing meetings are recorded. Yes there is a section in the Finalisation of Internal Audit – Checklist for recording comments at closing meetings. At end of each audit. IAPM Internal Audit customer feedback surveys are requested from internal audit customers at completion of each internal audit engagement. Survey Questionnaire issued to: management in audited areas; service providers; and CAE and IA team, At end of each audit. IAPM Internal Audit has formal performance measures in place. Approved performance measures are in place for Internal Audit, and these are monitored and reported to the Audit Committee (ARC). Annual ARC assessment of Internal Audit conducted. Next update meeting May 2014 IAPM and CAE Reviewed and approved when issued. Formal sign off when forwarded to Secretary for approval. CAE. Branch Plan contains a number of KPIs applicable to the audit program. Both of these will be updated and reviewed by the CAE, at a minimum, at planning days conducted every 6 months. Results reported to the ARC annually. 6 All final reports and recommendations are reviewed and approved by a CAE. NSW TREASURY QAIP Final internal audit reports and recommendations are reviewed and endorsed by the CAE prior to release. The CAE reviews and signs off all final internal audit reports. The CAE reviews draft reports and signs off all final internal audit reports. Formal sign-off is at the time when report is sent to Secretary. 5 Periodic Reviews 1 Periodic assessments will be conducted through Potential Components Include Feedback from customer surveys on internal audit engagements Post-audit customer feedback surveys of Internal Audit customers are used as a basis for continuous improvement. Assessment Criteria Information received from internal audit customers in customer feedback surveys is used to improve services provided by Internal Audit. Treasury Assessment Client Survey Questionnaire issued to management of audited areas at closing stages of each review. When At end of each audit. By who IAPM. Changes to Audit Manual approved by CAE. Internal Audit Service Provider is also surveyed. Where opportunities for improvement are identified these are documented into the Finalisation of Internal Audit – Checklist and the Internal Audit Manual 2 Annual risk assessments for purposes of annual audit planning. A comprehensive internal audit risk universe of potential topics for internal audit engagements in maintained and updated. The internal audit risk universe is supplemented and updated on an ongoing basis through various means such as consultation with management. NSW TREASURY QAIP Internal Audit conducts an annual risk assessment exercise to aid its internal audit planning. The Internal Annual Plan links proposed internal audit engagements to the operational and strategic risks of the organisation. There is input from management into development of the Internal Annual Plan. Yes. Service Provider facilitated an Executive Workshop in August 2013 to identify key strategic risks within the risk universe. The 2013-14 Audit Plan is based on those risks, which include those raised by previous audits. Annually – next process to commence with an Executive workshop in March 2014. Service Provider /CAE/Group Executive Thereafter, Executive Workshop in December, with a final check by Executive the following June. 6 3 4 5 Periodic assessments will be conducted through Potential Components Include Assessment Criteria Working paper reviews for internal audit engagements in accordance with the Internal Audit Manual and with the Standards Internal audit engagements are supervised to assure conformance with the approved methodology for conducting internal audit engagements and conformance with the Standards. There is an approved methodology for conducting internal audit engagements. Review of internal audit performance metrics and benchmarking of best practices, prepared and analysed in accordance with Audit Policies and Procedures. There are performance measures in place for Internal Audit. Follow-up of recommendations contained in A follow-up database is maintained for internal audit NSW TREASURY QAIP Treasury Assessment Approved methodology documented in Audit Manual and also agreed in Scope. QA sign-off table provided with all documents received from internal audit service provider Working paper reviews are Working papers are reviewed conducted as part of at the end of each ongoing internal engagement for conformance assessments and external with Audit Manual and ASAE quality assessments. 3000 Compliance (Recorded in the Finalisation of Internal Audit – Checklist) Approved performance Renewed annually during measures are in place for branch planning and updated Internal Audit, and these where necessary. are monitored and reported to the Audit Committee. When At end of each audit. By who IAPM. There is a formal QA signoff process over internal audit engagements. External quality assessments benchmark Internal Audit against better practices in internal auditing. There is an audit follow-up system in place. There is periodic follow-up External assessment conducted every five years, as per TPP 09-05. Last review conducted in May 2011. Register of Internal Audit Recommendations and Register of Audit Office Management Letter Current performance measures to be updated May 2014. Next external review May 2016. Prior to each ARC meeting. Updated by Internal Audit Program Manager. Reviewed by Chief Audit Executive on an ongoing basis. IAPM 7 Periodic assessments will be conducted through Potential Components Include internal audit reports recommendations and action plans resulting from internal audit engagements, and also for recommendations from the external auditors. Assessment Criteria of outstanding audit recommendations to provide assurance remedial action has been implemented. Periodic reports from management on action taken is reported to the Audit Committee at each meeting There is a risk-based follow-up approach for audit recommendations which have been agreed by management. Audit follow-up activities are reported to the Audit Committee. 6 Periodic activity and performance reporting to the Audit and Risk Committee. NSW TREASURY QAIP Periodic summary reports are provided to the Audit Committee by Internal Audit, including results of quality activities, internal assessments and external quality Summary reports on the work of Internal Audit are provided to the Audit Committee. Details of internal assessments are provided to the Audit Committee Treasury Assessment When By who recommendations followed up three week prior to Audit and Risk Committee meetings, with updates reported to the ARC at alternating meetings. The Register of External Bodies Reports is followed up and reported every 6 months. Low to Moderate risk issues are followed up but not reported to the ARC unless the CAE deems necessary. The ARC requests explanations from senior management where there are significant delays in implementing recommendations. Report on the Status of Internal Audit is a standing item at each ARC meeting. Each audit is assessed immediately it is completed, by the CAE, the audited area and EY. Noteworthy exceptions are reported to the ARC. At each ARC meeting. Ongoing, following each audit IAPM IAPM 8 Periodic assessments will be conducted through Potential Components Include Assessment Criteria assessments. Reports of external quality assessments are provided to the Audit Committee. Treasury Assessment When Results of the annual assessment of the internal audit function are reported to the Audit and Risk Committee annually. The Committee contributes to the assessment. Highlights from this assessment appear in the ARC’s annual report to the Secretary. Annually. Most recent results discussed at ARC meeting of 31 October 2013. By who CAE Next assessment to report Oct 2014. External assessment report provided to ARC May 2011. May 2016 7 Periodic internal assessments of conformance to the Standards. Annually. Last review conducted March 2013. Next review March 2014. CAE/IAPM 8 Periodic internal assessments of conformance to TPP 09-05. Annually. Last review conducted December 2013. Next review December 2014 CAE. Annually. Last assessment November 2013. Next assessment November 2014 Secretary Annually (and when a member’s term is renewed). Last assessment November 2013. Next assessment before December 2014. ARC Chair Annually. Last assessment November 2013, discussed at December ARC meeting. Next assessment November 2014. ARC members 9 10 11 Periodic assessment of the Audit and Risk Committee Chairperson. Periodic assessment of the Audit and Risk Committee members. Periodic self-assessment of Audit and Risk Committee. NSW TREASURY QAIP 9 Periodic assessments will be conducted through 12 13 Potential Components Include Assessment Criteria ARC assessment of Internal Audit activities. ARC ensures that the Secretary is aware of any risk concerns raised by the Committee. Treasury Assessment Annually. Last assessment Sept 2013, discussed at Oct meeting. The Secretary provides a “Secretary’s Report” for each ARC meeting, and presents it in person whenever possible. (In 2013 there was only one meeting where the Report was given by a deputy.) The ARC has access to speak to the Secretary privately at any time on any issue they wish to raise. Secretary reads and comments on the Minutes of each ARC meeting. 14 15 ARC Principal Department and Shared Arrangements Charters and the Internal Audit Charter are reviewed annually and updated if TPP 09-05, TPP 12-04 or IPPF Standards have been updated. Audit Manual is revised annually. Updates will reflect lessons learned from the year’s assessments. 16 Fraud and Corruption risk assessment. NSW TREASURY QAIP When Next assessment by Oct 2014 Each meeting By who ARC members ARC Members and Treasury Secretary As required Each meeting Annually. New Charters posted in March 2014 Next review January 2015, (unless GSE Act changes require earlier review) CAE Yes – complete revision in October 2013, posted in March 2014 Annually – next update February 2015 IAPM/CAE Workshops commence first Internal Audit A fraud and corruption risk assessment was conducted 10 Periodic assessments will be conducted through Potential Components Include Assessment Criteria Treasury Assessment for Treasury/Crown and separately for SICorp in June 2012. The Secretary has requested new fraud and corruption workshops in 2014, leading to a second risk assessment and audit in 2015, to be reviewed every 3 years thereafter. NSW TREASURY QAIP When half 2014, preceding a Cluster audit in 2014-15. By who Service Provider 11 EXTERNAL ASSESSMENTS - 1312 External assessments will appraise and express an opinion about internal audit’s conformance with the Standards, The IIA’s Definition of Internal Auditing and Code of Ethics and include recommendations for improvement, as appropriate. External assessments will be conducted through 1 Quality assessment of Treasury Cluster Internal Audit. When Every five years, as per TPP 09-05. Last review conducted in May 2011. By who The Institute of Internal Auditors. Next review May 2016. 2 Audit Office assessment of Internal Audit’s compliance with TPP 09-05. At the Auditor General’s discretion. Last survey performed in 2012. Recommendations made in AO management letters for year ending June 2012 and implemented. NSW Audit Office. REPORTING ON QUALITY PROGRAM - 1320 Internal Assessments – Results of internal assessments will be reported to the Audit and Risk Committee annually. Highlights from the assessments will appear in the ARC’s annual report to the Secretary each June. External Assessments – Results of external assessments will be provided to the Audit and Risk Committee and the Secretary. The external assessment report will be accompanied by a written action plan in response to significant comments and recommendations contained in the report. The CAE will implement appropriate follow-up actions to ensure that recommendations made in the report and action plans developed are implemented in a reasonable timeframe. This activity is monitored by the ARC at each meeting. NSW TREASURY QAIP 12 CONDUCTED IN ACCORDANCE WITH THE STANDARDS - 1330 Internal auditors are encouraged to report that their activities are "conducted in accordance with the International Standards for the Professional Practice of Internal Auditing." However, internal auditors may use the statement only if assessments of the quality improvement program demonstrate that the internal audit activity is in compliance with the Standards. External assessments will be conducted through 1 When Use of "Conducted in Accordance with the Internal audits are conducted in accordance Standards" with ASAE 3000 on assurance engagements. Internal audit is evaluated against the Standards annually. Working papers for each internal audit are evaluated for conformance to ASAE 3000 (this is documented in the Finalisation of Internal Audit – Checklist). By who IAPM DISCLOSURE OF NON COMPLIANCE - 1340 Although the internal audit activity should achieve full compliance with the Standards and internal auditors with the Code of Ethics, there may be instances in which full compliance is not achieved. When non-compliance impacts the overall scope or operation of the internal audit activity, disclosure should be made to senior management and the board. External assessments will be conducted through 1 Disclosure of Noncompliance NSW TREASURY QAIP When Annual internal assessments of conformance to the International Standards for the Professional Practice of Internal Auditing. Last review conducted Feb 2014. Next review Feb 2015. By who CAE 13 QAIP Review History Prepared/Reviewed by Review Date Approved by Approval Date Stephen Connolly, IAPM 7/11/2011 Nadia Fletcher, CAE 11/11/2011 Stephen Connolly, IAPM 12/2/2013 Nadia Fletcher, CAE 20/02/2013 Stephen Connolly, IAPM 23/12/2013 Nadia Fletcher, CAE 23/12/2013, for posting on the website in March 2014 Next complete review due: February 2015 NSW TREASURY QAIP 14 Appendix A – Internal Audit Standard 1300 1300 – Quality Assurance and Improvement Program The chief audit executive must develop and maintain a quality assurance and improvement program that covers all aspects of the internal audit activity. Interpretation: A quality assurance and improvement program is designed to enable an evaluation of the internal audit activity’s conformance with the Definition of Internal Auditing and the Standards and an evaluation of whether internal auditors apply the Code of Ethics. The program also assesses the efficiency and effectiveness of the internal audit activity and identifies opportunities for improvement. 1310 – Requirements of the Quality Assurance and Improvement Program The quality assurance and improvement program must include both internal and external assessments. 1311 – Internal Assessments Internal assessments must include: Ongoing monitoring of the performance of the internal audit activity; and Periodic self-assessments or assessments by other persons within the organization with sufficient knowledge of internal audit practices. Interpretation: Ongoing monitoring is an integral part of the day-to-day supervision, review, and measurement of the internal audit activity. Ongoing monitoring is incorporated into the routine policies and practices used to manage the internal audit activity and uses processes, tools, and information considered necessary to evaluate conformance with the Definition of Internal Auditing, the Code of Ethics, and the Standards. Periodic assessments are conducted to evaluate conformance with the Definition of Internal Auditing, the Code of Ethics, and the Standards. Sufficient knowledge of internal audit practices requires at least an understanding of all elements of the International Professional Practices Framework. 1312 - External Assessments External assessments must be conducted at least once every five years by a qualified, independent assessor or assessment team from outside the organization. The chief audit executive must discuss with the board: The form and frequency of external assessment; and The qualifications and independence of the external assessor or assessment team, including any potential conflict of interest. Interpretation: External assessments can be in the form of a full external assessment, or a self-assessment with independent external validation. A qualified assessor or assessment team demonstrates competence in two areas: the professional practice of internal auditing and the external assessment process. Competence can be demonstrated through a mixture of experience and theoretical learning. Experience gained in organizations of similar size, complexity, sector or industry, and technical issues is more valuable than less relevant experience. In the case of an assessment team, not all members of the team need to have all the competencies; it is the team as a whole that is qualified. The chief audit executive uses professional judgment when assessing whether an assessor or assessment team demonstrates sufficient competence to be qualified. An independent assessor or assessment team means not having either a real or an apparent conflict of interest and not being a part of, or under the control of, the organization to which the internal audit activity belongs. NSW TREASURY QAIP 15 1320 – Reporting on the Quality Assurance and Improvement Program The chief audit executive must communicate the results of the quality assurance and improvement program to senior management and the board. Interpretation: The form, content, and frequency of communicating the results of the quality assurance and improvement program is established through discussions with senior management and the board and considers the responsibilities of the internal audit activity and chief audit executive as contained in the internal audit charter. To demonstrate conformance with the Definition of Internal Auditing, the Code of Ethics, and the Standards, the results of external and periodic internal assessments are communicated upon completion of such assessments and the results of ongoing monitoring are communicated at least annually. The results include the assessor’s or assessment team’s evaluation with respect to the degree of conformance. 1321 – Use of “Conforms with the International Standards for the Professional Practice of Internal Auditing” The chief audit executive may state that the internal audit activity conforms with the International Standards for the Professional Practice of Internal Auditing only if the results of the quality assurance and improvement program support this statement. Interpretation: The internal audit activity conforms with the Standards when it achieves the outcomes described in the Definition of Internal Auditing, Code of Ethics, and Standards. The results of the quality assurance and improvement program include the results of both internal and external assessments. All internal audit activities will have the results of internal assessments. Internal audit activities in existence for at least five years will also have the results of external assessments. 1322 – Disclosure of Non-conformance When non-conformance with the Definition of Internal Auditing, the Code of Ethics, or the Standards impacts the overall scope or operation of the internal audit activity, the chief audit executive must disclose the non-conformance and the impact to senior management and the board. NSW TREASURY QAIP 16