Supporting Continuous Monitoring Using Control Charts May 2003 1 Supporting Continuous Monitoring Using Control Charts Abstract There is currently much being written about increasing the frequency and timeliness of financial reporting. Comments frequently support the desirability and question the feasibility of continuous reporting. Under our current paradigm, if we report continuously, we also must monitor and audit on a continuous basis. Current audit standards generally address the outcomes, rather than the detailed procedures the auditor must follow to meet the objectives of the audit. The purpose of this paper is to propose and demonstrate a technique for continuously monitoring financial information using control charts of accounting information. In this study, financial data were collected and used to implement control charts. The authors suggest that charts similar to these can be used in conjunction with statistical and analytical techniques to detect signals that financial processes are not in control. Refinements of this technique should assist those internal and external to organizations, who are concerned with the reliability of information produced and reported by the organization. 2 Introduction Over the past two decades, the proliferation of technology has led to the increased availability of financial information. Although the timing of financial reporting has not changed significantly, currently there is much being written about increasing the frequency and timeliness of financial reporting and assurance (Vasarhelyi 2002). Technology advances have generally increased system capabilities enabling integrated packages to simplify and accelerate the mechanical process of financial reporting. Generally, people agree that increasing the frequency may be useful, but have reservations about the feasibility of the implementation of continuous reporting and assurance. For example, Searcy, Woodroof, and Behn (2003) report the following quote from a Big 4 audit partner. The process we have is good but is designed for the annual audit… We will need the ability to push a button at any point in time and have the system summarize for the engagement team process issues identified to-date that can lead to risk that the financial statements are inaccurate, rather than rely only on a traditional review of workpapers, manual summarizations of issues and followup. [We need to be able to] use technology to actually audit as opposed to using technology to automate manual auditing procedures. Although continuous assurance was proposed over a decade ago (Groomer and Murthy 1989; Vasarhelyi and Halper 1991; Vasarhelyi, Halper, and Ezawa 1991), to move assurance from the current periodic model to a continuous process, auditors will need to look to non-traditional tools 3 and techniques. Furthermore, Kogan, Sudit, and Vasarhelyi (1999) have called for and suggested research to be completed that would support the development of continuous assurance and audit. The current research suggests using control charts to assist auditors and other decisionmakers in the identification of patterns in the underlying processes that produce financial statements. Control charts have historically been used for monitoring manufacturing processes and identifying when processes become “out of control”. Once interesting patterns are identified, decision-makers may focus on the processes that generated the patterns. The objective of continuous monitoring is detecting data abnormalities as near as possible to the time of occurrence of the underlying event that generated the data. If an error or irregularity occurs and is detected, the situation can often be corrected, and the effect quickly mitigated. Overall, the purpose for monitoring financial information is to gain confidence that the systems are operating as intended, through the ability to identify and resolve errors, irregularities, or inconsistencies. The current research demonstrates a tool, the use of control charts, to detect abnormal patterns in data, providing support for additional analysis and detection of potential problems in the underlying system. The remainder of the paper is organized as follows. In the following section, background literature is provided for the research described in this paper. This background includes material addressing continuous auditing and assurance, and an overview of control charts and their use. The next section provides a description of the methods used to transform the data for use in control charts. The third major section discusses the results obtained. The final sections provide 4 descriptions of some of the limitations, future research directions, and conclusions based on this research. Background Continuous Auditing and Assurance As pointed out above, continuous audit and assurance was proposed over a decade ago. Groomer and Murthy (1989) proposed embedding audit modules into a client’s software. By using this method it would be possible to capture and evaluate relevant information in a more continuous manner. Vasarhelyi and Halper (1991) described an alternative audit approach called the Continuous Process Audit Methodology (CPAM). In this approach, they suggest that “continuous process auditing can be considered as a meta form of control and can be used in monitoring control … by scanning for the occurrence of certain patterns …” (Vasarhelyi and Harper 1991, p. 180). Furthermore, they propose that by having online systems monitored in a continuous manner, auditing will become more of an audit by exception instead of a periodic audit, i.e., when an exception occurs, an audit will be required based on the nature of the exception. In 1997, a joint committee of the AICPA and CICA issued a report that suggested CPAs and CAs will need to monitor the functioning of a firm’s systems in order to assure the reliability of the data provided by the systems (AICPA 1997). They suggested that the CPA/CA would need to “either (1) embed some level of monitoring or control in the client’s system or (2) direct regular inquiries into client processing systems/databases” (Vasarhelyi 2002, p. 261). The 5 approach described in the current paper provides the auditor an aid to determine when and where to query a client’s system. As reported by Searcy et al. (2003), a Big 4 audit partner suggests that “the use of technology tools that assist with auditing through our clients’ systems will become increasingly important.” They also provide evidence that as continuous auditing of continuous reporting increases, that the Big 4 partner’s believe that the clients’ expectations of an auditor’s ability and responsibility will increase in the areas of (1) reporting on going concern problems in a more timely manner, (2) detecting fraud, and (3) determining the reliability of financial information. Based on the above, it seems that as the audit profession moves toward a more continuous audit by exception philosophy, the auditor must be able to monitor the financial status of a client firm in a real-time manner. In the next subsection, the use of control charts is described, as a basis to raise alarms to notify an auditor to further investigate a possible problem within a client’s system. Control Charts The control chart, also known as a Shewhart chart, was created in the 1920s by Dr. Walter A. Shewhart of the Bell Telephone Labs. It was initially created to provide a way to monitor manufacturing processes in a more statistically sound manner. The control chart continues to be one of the primary tools used in statistical quality control. There are many different types of control charts; each type is essentially a run chart that plots the values of observations taken from a manufacturing process. The values are plotted around the mean. As long as the observations do not stray too far from the mean for too long, the underlying process is considered to be under control (Brassard 1989 and Harris 1996). 6 Manufacturing processes have been monitored frequently through the use of control charts (Shirland 1993). If a process is in control, the control chart will appear as if the variation in the control chart is randomly distributed. If a process is out of control, the data will appear to have a pattern or some abnormality. Even if a process is in statistical control, it does not necessarily guarantee that the process will produce a valid or usable product. However, if a process is out of control, the likelihood of the process producing a usable product is low (Shirland 1993). Wheeler (1993, 130) indicates that each signal identified on a control chart provides the decision-maker with “an opportunity to gain more insight into the process.” Metaphorically speaking, financial statement creation parallels a manufacturing process; raw materials (data) are purchased (collected) and processed providing the finished goods (financial reports). As control charts are overlaid on the process, one should be able to determine if the raw data or financial statement creation process is going “out of control.” Through the application of this manufacturing metaphor in conjunction with control charts, it is possible to identify potential problem areas within the financial statements. Such data or processing problems could be due to information systems problems, fraud, and/or accounting irregularities. The control charts only serve to raise flags to notify decision-makers that additional investigations may be necessary. Because the control charts provide an alert of a potential problem, it is important that they are operating at an appropriate sensitivity level. Control charts that are too sensitive will raise flags when not appropriate, causing unnecessary investigations and other problems for decision-makers. Control charts with too little sensitivity may lead a decision-maker to overlook serious problems that may exist. As such, control charts should be 7 only one of many tools used by decision-makers to monitor information identified as “high risk” to the financial health of an organization. Methods To illustrate the application of control charts to monitoring of financial reporting, the authors developed control charts from certain historical financial data collected from several firms within three industries. The data used to develop the control charts in this paper were collected from Compustat. Due to the increased reporting frequency over annual data, quarterly data were selected. Currently, there is not a common source of data with more frequent periodicity and reliable financial data available for companies and industries. The data selected for this study encompassed the periods from first quarter 1993 through fourth quarter 2002 (ten years). The authors selected financial information relating to three companies with a history of financial irregularities. These firms include WorldCom, Rite Aid, and Oxford Health Plans. For comparison purposes, the authors also chose two additional firms in each of the corresponding industries of the “problem” firms. For the purpose of this paper, industry is defined as companies with identical SIC codes. The two additional firms that were chosen are not known to have a history of financial irregularities. The comparison firms for WorldCom included AT & T and BellSouth, for Rite Aid, CVS, and Walgreen’s, and for Oxford Health Plans, Aetna and Cigna. 8 Selected account balances of the “problem” firms were also compared to the related account average values for their respective industries. The specific accounts investigated are based on suggestions by Mulford and Comiskey (2002) and Schilit (2002). The accounts used to illustrate the control chart concepts varied by company, based on the type of irregularity that was known to exist within the company. For WorldCom, the irregularity involved improperly classifying cost of sales as long term assets (SEC 2002a); the authors selected the cost of goods sold account to use for analysis in the current paper. Rite Aid was charged by the SEC (2002b) with a variety of accounting irregularities. Among these irregularities were erroneous inventory markdowns, leading the authors to use the inventory account as the illustrative account. The third company, Oxford Health Plans’ accounting irregularities were apparently unintentional and based on billing issues related to a computer upgrade (Schilit 2002). For Oxford Health, the authors looked at Net Income, an aggregation of the nominal accounts. For this paper, the authors extracted quarterly information for a ten year time period, providing forty data points for the preparation of control charts and data analysis. In practice, an individual monitoring the financial statements ideally should have access to the actual values in a more continuous manner. Several procedures were used to standardize the raw extracted data. For demonstration purposes, Table 1 shows only the results from standardization procedures for the first two years (eight quarters) of the Cost of Goods Sold account data for the WorldCom analysis. Table 1 begins with actual values for the Cost of Goods Sold and Sales accounts. Following Schilit (2002) and Welsh, Zlatkovich , and White (1976), the data were “common sized” by dividing the 9 selected accounts by the total sales, for the income statement accounts (Cost of Goods Sold for WorldCom and comparables), or total assets, for the balance sheet accounts (Inventory for Rite Aid and comparables), for the same period. In the Table 1 example, Cost of Goods Sold was divided by Sales (see Common-Sized Values). Second, a moving average of four data periods (quarters) was used to provide the base line for the control chart. In this case, the first period in which a moving average was computable was for Dec-92 (see Moving Averages in Table 1). Next, a moving standard deviation was computed, that in conjunction with the moving average could be used to compute a Z-score for each of the “4-period windows” (see Moving Std Deviations in Table 1). Finally, a “z-transformation” of the data was used to set the base line to zero and standardize the periodic data (see Z-Score Transformation in Table 1). Based on the ZScore values, control charts were created and analyzed (See Discussion below). There are many different rules on which to base the control chart analysis. Within this paper, the authors investigate the use of rules regarding runs in z-transformed account values to identify areas for additional investigation. For example, if the z-transformed value of a specific account has a set of seven positive (or negative) values above (or below) the moving average in seven consecutive time periods, there could be a problem with the underlying process. The probability of seven values in a row being above (or below) the mean is less than two percent. This is the so-called “rule-of-seven” (Shirland 1993). Through the application of control charts and the appropriate rules to monitor the accounts, the authors believe that it is possible to identify problem areas within the financial accounts, in a manner that it has been applied in manufacturing, before the accounts go “out of control” and potentially before irreversible consequences occur. 10 Results and Discussion The three examples of using control charts to identify potential problem areas are described in this section. First, control charts associated with WorldCom and its competitors and industry are presented. Next, control charts are presented for the data associated with Rite Aid Corporation and its competitors and industry. Finally, the results associated with Oxford Health Plans and its competitors and industry are presented in control chart format. The control charts are presented in Figures 1 through 6. In Figures 1, 3 and 5, data points that fall under the rule-ofseven are identified with an oval. Figure 1 is a control chart demonstrating the behavior of WorldCom’s cost of goods sold from the first quarter of 1992 through the fourth quarter of 2001 (data points identified by diamonds). An industry comparison for values of cost of goods sold is shown on the chart with squares. An examination of the WorldCom data shows in quarters 21 through 31 (Quarter 1, 1997 through Quarter 3, 1999 consisting of 11 data points), the data points are in “violation” of the rule of seven, indicating that there may be some systematic problem with cost of goods sold during the period. This pattern is consistent with the type of issues that are covered in the allegations made against WorldCom. The company has since restated financial results from 2001 and 2002. Had auditors considered the authors’ proposed method of analysis during 1998, it is likely that cost of goods sold would have received additional scrutiny during the period under question. As a control, the industry data for the cost of goods sold account is also presented (industry data points are shown as squares). Based on the stated criteria, there do not appear to be any systematic patterns in the industry as a whole. 11 As an additional control, Figure 2 displays cost of good sold information for two other companies in WorldCom’s industry, BellSouth (diamond) and AT&T (square). Analysis of this data also shows no systematic patterns to suggest that underlying systems used to report cost of goods sold for these companies are out of control. The example of Rite Aid is provided in Figure 3. Rite Aid’s data are shown using the diamond symbols, while the industry data are identified with squares. Rite Aid’s various problems with inventory prompted their inclusion in this study. In examining the data in Figure 3, there are two time periods that are identified when applying the rule-of-seven. The first period, includes the seven periods from the second quarter of 1996 through the fourth quarter of 1997 (inclusive). The second includes the seven periods from the first quarter of 1998 through the third quarter of 1999 (inclusive). The SEC (2002b) complaint against Rite Aid indicates problems existed from May 1997 through May 1999, a period that overlaps the time periods where Figure 3 would support additional investigation. The industry data presented in Figure 3 does not indicate the existence of a systemic problem within the industry as a whole. Figure 4 shows data collected from the two other companies selected from within Rite Aid’s industry, Walgreen’s (diamond) and CVS (square). The same methods and criteria that were used to evaluate Rite Aid do not provide support for the existence of out-of-control inventory systems at Walgreen’s or CVS. Net income data from Oxford Health Plans (diamond) is presented with the corresponding industry data (square) in Figure 5. Schilit (2002) describes the circumstances surrounding a 1997 New York State Insurance Investigation ending with a $3 million fine for Oxford and mandated $50 million increase in insurance reserves. Also in 1997, the value of the 12 company’s common stock fell 62%. At the heart of the problem was a 1996 computer upgrade that did not work properly, negatively impacting earnings. The results displayed in Figure 5 indicate the potential for a problem in the nine periods prior to the actual problem (second quarter, 1994 through second quarter 1996, inclusive). It is likely that these results do not identify the actual problem, but may identify systematic issues that precipitated the need for the system upgrades. Once again, the industry data does not provide any support for the existence of an “industry based” problem. In the final example, Figure 6 presents net income data from two members of Oxford’s industry, AETNA and CIGNA. The data provided for these companies do not indicate a problem exist in their systems or underlying data. For each company that was identified as having prior public disclosures of significant problems within their financial accounting and reporting system, the figures show relevant accounts and how using control charts and the rule-of-seven may help identify problems that might go unnoticed for a significant amount of time, increasing financial damage to the company and ultimately to its investors. Concurrently, industry data were provided that indicated the problems were not industry-wide, but rather company specific. In addition to the industry data, two other companies within each industry were presented to support the validity of the rule to not only identify problems, but also to “non-identify” companies that do not have problems. Limitations and Future Research This study is an initial attempt to investigate the usefulness of control charts, a tool created and refined for use in manufacturing environments, but applied to financial accounting 13 information systems by the authors. As an initial study, the authors recognize and acknowledge several significant limitations of the study. Many of these limitations are being addressed in other research currently in process by the authors. One of the main limitations of this research is the lack of true continuous data for the range of instances examined – multiple variables across three industries and nine companies; three of the companies with known accounting irregularities. Although the use of quarterly data is “more continuous” than annual data, it is far from continuous in reality. To address this issue will require corporate transparency; a requirement that is complicated by the need for data from companies with irregularities. Typically, one would not expect a company to agree to disclosing data if an irregularity or investigation is known to be in process. In the near future, as technologies such as XBRL are implemented, it might be possible to accumulate instances of near-continuous data for a study of active companies. In addition to issues surrounding limited continuous data availability, there are also potential limitations in applying control charts to financial processes. Since this is a new domain for this application, the rules to interpret the charts and identify “out-of-control” systems may need to be modified. Alternatively, new rules may need to be developed. Other common rules (to manufacturing) that are currently under investigation by the authors include: If an individual point is above (or below) three standard deviations from the mean, then the underlying process is potentially out of control If the values trend in the same direction (increasing or decreasing) for seven periods, then it is likely that the underlying process is out of control. 14 If the values for two or more periods are greater than two standard deviations (Z = 2), but within the actual control limits, then it is likely that the underlying process is out of control. If the values for four or more periods are greater than one standard deviation (Z = 1), but within the actual control limits, then it is likely that the underlying process is out of control. With any control chart rule, one must consider the frequency of reporting; examining the usefulness of standard control charts when monitoring accounting processes at all reporting frequencies, including continuous reporting. It is likely that companies at different levels of maturity may need to be evaluated by different rules. For example, a start-up company would likely be in a growth mode, making the likelihood of a “false” out of control identification a possibility. There also may need to be variation of rules based upon company size, if it is determined that the size of the firm has an effect on the cost or asset structure of a firm. Conclusion In this research, the authors suggest that control charts may provide a way to continuously monitor business and financial processes. Control charts have been successfully used to monitor manufacturing processes and to identify processes when they become “out-ofcontrol”. As demonstrated by the provided examples, they may also be beneficial when monitoring financial processes, by helping identify patterns that may indicate a problem with underlying accounting data. 15 Currently, the usefulness of the concept is probably highest for auditors, internal and external, as an additional analytical review procedure. Ultimately, as companies increase the frequency of reporting, the concept also may be beneficial to other decision-makers, through the identification of systemic problems within an organization. 16 Table 1: Two years of Values for Cost of Goods Sold for AT&T, Bell South WorldCom, and the Industry Based on Compustat Quarterly Account Data (March 1992-December 2001) Actual Account Values COGS – Industry WorldCom – COGS Bell South – COGS AT&T – COGS Sales – Industry WorldCom – Sales Bell South – Sales AT&T – Sales Common-Sized Values COGS – Industry WorldCom – COGS Bell South – COGS AT&T – COGS Moving Averages COGS – Industry WorldCom – COGS Bell South – COGS AT&T – COGS Moving Std Deviations COGS - Industry WorldCom - COGS Bell South - COGS AT&T - COGS Z-Score Transformations COGS - Industry WorldCom - COGS Bell South - COGS AT&T - COGS Mar-92 600.6124 105.252 2,153.10 8,578.00 1083.617 183.748 3,738.70 15,375.00 Jun-92 614.8397 112.311 2,170.10 8,788.00 1090.765 197.815 3,764.10 15,845.00 Sep-92 538.8757 116.821 2,216.10 9,023.00 1033.385 205.78 3,736.00 16,180.00 Dec-92 618.7917 123.8 2,371.20 9,713.00 1149.957 213.41 3,910.10 17,504.00 Mar-93 623.2446 129.2 2,262.00 9,517.00 1092.328 219.011 3,833.70 15,719.00 Jun-93 641.5731 148.003 2,279.60 10,263.00 1132.138 251.514 3,906.90 17,337.00 Sep-93 644.2354 158.088 2,316.70 10,284.00 1116.206 281.788 4,014.90 17,225.00 Dec-93 712.2872 222.546 2,436.30 11,571.00 1190.136 392.401 4,124.80 19,070.00 0.554266 0.572806 0.575895 0.557919 0.563678 0.567758 0.576526 0.554623 0.521467 0.567699 0.593175 0.557664 0.5381 0.580104 0.60643 0.554902 0.570566 0.589925 0.590031 0.605446 0.566692 0.588448 0.583481 0.591971 0.577165 0.561018 0.577026 0.597039 0.598492 0.567139 0.590647 0.606765 0.544378 0.572092 0.588006 0.556277 0.548452 0.576371 0.59154 0.568159 0.549206 0.581544 0.593279 0.577496 0.563131 0.579874 0.589242 0.587339 0.578229 0.576632 0.585296 0.600305 0.018571 0.005854 0.014658 0.001756 0.022776 0.010755 0.012276 0.024896 0.023486 0.010193 0.009652 0.02513 0.017238 0.013294 0.012629 0.022328 0.014184 0.014722 0.006397 0.00703 -0.33805 1.368816 1.256839 -0.78326 0.97091 1.260149 -0.12297 1.497719 0.744516 0.677388 -1.0151 0.576025 0.814154 -1.41844 -0.9673 0.43443 1.42861 -0.64481 0.83659 0.918808 17 Figure 1: Control Chart - Cost of Goods Sold WorldCom and Industry Quarterly Data (March 1992-December 2001) 2 1.5 1 0.5 WorldCom - Cost of Goods Sold 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Industry - COGS -0.5 -1 -1.5 -2 18 Figure 2: Control Chart – Cost of Goods Sold BellSouth and AT&T Quarterly Data (March 1992-December 2001) 2 1.5 1 0.5 Bell South-COGS 39 37 35 33 31 29 27 25 23 21 19 17 15 13 11 9 7 5 3 1 0 AT&T - COGS -0.5 -1 -1.5 -2 19 Figure 3: Control Chart – Inventory Rite Aid and Industry Quarterly Data (March 1992-December 2001) 2 1.5 1 0.5 Rite Aid - Inventory 0 1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 Industry - Inventory -0.5 -1 -1.5 -2 20 Figure 4: Control Chart – Inventory Walgreen and CVS Quarterly Data (March 1992-December 2001) 2 1.5 1 0.5 Walgreens - Inventory 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 CVS - Inventory -0.5 -1 -1.5 -2 21 Figure 5: Control Chart – Net Income Oxford Health Plan and Industry Quarterly Data (March 1992-December 2001) 2 1.5 1 0.5 OHP - Net Income 0 1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 Industry - Net Income -0.5 -1 -1.5 -2 22 Figure 6: Control Chart – Net Income AETNA and CIGNA Quarterly Data (March 1992-December 2001) 2 1.5 1 0.5 AETNA INC - Net Income 0 1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 CIGNA CORP - Net Income -0.5 -1 -1.5 -2 23 References American Institute of Certified Public Accountants (AICPA) Report of the Special Committee on Assurance Services, Systems Reliability Assurance Segment; 1997. 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