October 2013
COSO Updated Internal
Control – Integrated
Framework —Learning and
Implementation Plan
Now is the time for auditors to prepare their clients for the transition to the updated Internal Control – Integrated Framework, which was issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO) in May 2013 (referred to herein as the 2013 Framework). The transition period for the 2013
Framework extends through December 15, 2014, at which time the existing framework will be considered superseded. This makes the 2013 Framework effective
for calendar year 2014 audits but there may be changes in internal controls in 2013. Use this roadmap to (1) understand the changes and their impact, (2) help
train your professional staff to ensure effective and efficient implementation of the 2013 Framework, and (3) communicate with your clients proactively about the
changes they can expect and the services you can provide. You will note several tools and resources to support you in your journey, specifically the COSO
Implementation Toolkit, which provides hands-on implementation tools.
Step
1
Action
Description/Considerations
Assign owner or task force
to become an expert (and
take the lead) on
understanding and
implementing the 2013
Framework.
The 2013 Framework will impact
engagements at all phases, but
particular in planning, understanding
the entity and its environment, and
risk assessment. As clients transition
to the 2013 Framework, it will be
important to understand changes
they make to the design of their
internal control structure, which may
occur during calendar year 2013 as
they prepare for adoption of the
2013 Framework at the beginning of
their fiscal year 2014.
www.aicpa.org/pcps
Recommended
Timing
Summer 2013
Tools and Resources
Owner
[A&A Partner,
or A&A
Manager or
Technical
Reviewer]
Page 1 of 7
Step
2
Action
Description/Considerations
Familiarize yourself with the
2013 Framework.
Start with some of the overview
documents on the update process
and changes to the 2013 Framework
provided by the COSO organization.
PCPS members can access the
resources in the PCPS COSO
Implementation Toolkit, including the
Learning Guide, written in plain
English, to help you understand

www.aicpa.org/pcps
what has changed in the
2013 Framework ;

what hasn’t changed;

how the 2013 framework
may impact your audit and
attest engagements; and

services you may want to
provide to existing or new
clients to help strengthen
controls in their
organizations
Recommended
Timing
Summer 2013
Tools and Resources
Owner
COSO Resources (www.coso.org)

Internal Control – Integrated Framework, Executive Summary

COSO Internal Control – Integrated Framework, Frequently Asked
Questions
[Assigned
owner or task
force]
AICPA Resources

Journal of Accountancy Podcast
PCPS COSO Toolkit (AICPA’s PCPS Section members only)

Guide to the Changes and Impacts
CPE


Accounting and Auditing Workshop: Latest Developments (SelfStudy)
Update for Accountants and Auditors: Latest Developments (SelfStudy)
Page 2 of 7
Step
3
Action
Description/Considerations
Take a deeper look into the
substantive changes from
the existing Framework and
evaluate the impact on your
clients.
The 2013 Framework introduces 17
principles that represent
fundamental concepts associated
with each of the five internal control
components. It also introduces 81
points of focus that can be used to
demonstrate implementation of the
17 principles. You will need to
understand the structure of the 2013
Framework, including these new
principles and points of focus.
For PCPS Members: The Learning
Guide introduces the principles and
points of focus.
The 2013 Framework provides
extensive guidance on how to apply
the points of focus and principles in
designing effective internal control.
You can also purchase the Framework
in three different bundles.
Recommended
Timing
Summer 2013
Tools and Resources
Owner
COSO Resources (www.coso.org)

Internal Control – Integrated Framework, Executive Summary

COSO Internal Control – Integrated Framework, Frequently Asked
Questions
[Assigned
owner or task
force]
AICPA Resources

Journal of Accountancy Podcast
PCPS COSO Toolkit (AICPA’s PCPS Section members only)

Guide to the Changes and Impacts
Publications

Internal Control for Today’s Smart Business

Internal Control – Integrated Framework: Executive Summary,
Framework and Appendices, and Illustrative Tools for Assessing
Effectiveness of a System of Internal Control

Internal Control – Integrated Framework, Internal Control Over
Financial reporting: A Compendium of Approaches and Examples

Internal Control - Integrated Framework and Compendium Bundle
CPE

Additionally, the publication Internal
Control for Today’s Smart Business
www.aicpa.org/pcps

helps you apply the framework
concepts by providing real-life
examples;

helps you understand how the
guidance in the framework aligns
with generally accepted auditing
standards; and

provides real-life examples
illustrating how businesses of any
size can have an effective system
of internal control.

Accounting and Auditing Workshop: Latest Developments (SelfStudy)
Update for Accountants and Auditors: Latest Developments (SelfStudy)
Page 3 of 7
Step
4
Action
Description/Considerations
Apply what you have
learned about changes in
the 2013 Framework to your
firm’s audit and attest
methodology and guidance.
Revise your firm guidance and
methodology to reflect the 2013
Framework. Determine your firm’s
process for documentating and
evaluating the 17 principles and 81
points of focus, then update your
standard procedures.
Consider potential impacts
to the audits and attest
engagements your firm
performs, factoring in
considerations for smaller
entities.
Even if your firm uses a third-party
provided methodology, ensure you
understand the revised Framework
and how the methodology provider
has implemented them into their
solution.
Appendix C of the Framework, Specific
Considerations for Smaller Entities,
may be helpful in determining
efficient, effective audit procedures
for smaller clients.
Recommended
Timing
Tools and Resources
Owner
Summer and Fall
2013
PCPS COSO Toolkit (AICPA’s PCPS Section members only)

Guide to the Changes and Impacts
[Assigned
owner or task
force]
Publications

Internal Control for Today’s Smart Business

Internal Control – Integrated Framework: Executive Summary,
Framework and Appendices, and Illustrative Tools for Assessing
Effectiveness of a System of Internal Control

Internal Control – Integrated Framework, Internal Control Over
Financial reporting: A Compendium of Approaches and Examples

Internal Control - Integrated Framework and Compendium Bundle
CPE


Accounting and Auditing Workshop: Latest Developments (SelfStudy)
Update for Accountants and Auditors: Latest Developments (SelfStudy)
Ensure a quality review of the
revisions to your firm guidance and
audit methodology occurs.
www.aicpa.org/pcps
Page 4 of 7
Step
5
Action
Description/Considerations
Facilitate training for your
professional staff and
partners.
Begin early to get your audit and
attest staff ready for the transition to
the 2013 Framework. Inform educate
and train all audit and attest staff.
Recommended
Timing
Summer 2013
through Fall
2013
Provide your staff with a general
update to ensure they are aware that
the COSO framework has been
updated and have a baseline
understanding of changes. PCPS
Member Firms: Provide the Learning
Guide as a general introduction to the
changes in the new Framework.
Tools and Resources
Owner
COSO Resources (www.coso.org)

Internal Control – Integrated Framework, Executive Summary

COSO Internal Control – Integrated Framework, Frequently Asked
Questions
[Assigned
owner or task
force]
AICPA Resources

Journal of Accountancy Podcast
PCPS COSO Toolkit (AICPA’s PCPS Section members only)

Guide to the Changes and Impacts

Staff Training PowerPoint
Publications

Internal Control for Today’s Smart Business

Internal Control – Integrated Framework: Executive Summary,
Framework and Appendices, and Illustrative Tools for Assessing
Effectiveness of a System of Internal Control

Internal Control – Integrated Framework, Internal Control Over
Financial reporting: A Compendium of Approaches and Examples

Internal Control - Integrated Framework and Compendium Bundle
Follow-up the general awareness
initiative with training on the 2013
Framework. PCPS Member Firms can
facilitate a training session using the
Staff Training PowerPoint template.
Tailor the PowerPoint to fit your firm’s
needs considering your client base
and audit/attest methodology.
CPE


6
Inform your clients of the
issuance of the 2013
Framework and impacts it
may have for them.
www.aicpa.org/pcps
PCPS member firms, utilize the Client
Communication Template to
communicate with your clients about
the 2013 Framework. Consider
follow-up meetings or trainings with
the clients to facilitate their
understanding of the 2013
Framework, utilizing the client-facing
PowerPointTemplate.
Fall 2013
Accounting and Auditing Workshop: Latest Developments (SelfStudy)
Update for Accountants and Auditors: Latest Developments (SelfStudy)
PCPS COSO Toolkit (AICPA’s PCPS Section members only)

Guide to the Changes and Impacts

Client Communication Template
For your attest clients
For your non-attest clients
Newsletter/website article
Page 5 of 7
Step
7
Action
Description/Considerations
Determine how the 2013
Framework may impact each
audit and attest
engagement, considering
the client’s decision on
when transition to the 2013
Framework will occur.
Communicate with each client to
determine when they plan to
transition to the 2013 Framework and
what impacts this will have on your
audit and attest engagements.
When determing the impact
on each engagement,
review the special
considerations for smaller,
less complex organizations
or governmental entities
included in the 2013
Framework.
Although early implementation is
permitted, clients may find it
impracticable to implement the 2013
Framework in the middle of a fiscal
year. However; even if
implementation will occur for fiscal
year 2014, clients will need to evalute
if any changes are necessary to their
internal control structure to comply
with the 2013 Framework. Changes
identified will need to be
implemented with sufficient time to
be effective during the
implementation year. This could
result in changes during the fiscal
2013 year or early after year-end,
which could impact the 2013 year
engagement.
Recommended
Timing
Fall 2013 –
Summer 2014
Tools and Resources
PCPS COSO Toolkit (AICPA’s PCPS Section members only)

Client Communication Template
For your attest clients
For your non-attest clients
Newsletter/website article
Owner
[Assigned
owner or task
force]
Publications

Internal Control for Today’s Smart Business

Internal Control – Integrated Framework: Executive Summary,
Framework and Appendices, and Illustrative Tools for Assessing
Effectiveness of a System of Internal Control

Internal Control – Integrated Framework, Internal Control Over
Financial reporting: A Compendium of Approaches and Examples

Internal Control - Integrated Framework and Compendium Bundle
To make the transition to the 2013
Framework go smoothly, you may
want to identify the changes specific
to your clients on a case by case basis
(step 6). Then consider scheduling
meetings with each client to address
their specific engagement and discuss
scope changes and fees.
Review Appendix C of the Internal
Control-Integated Framework, for
scalability for size and complexity
considerations for your client base.
www.aicpa.org/pcps
Page 6 of 7
Step
8
Action
Description/Considerations
Explore service
opportunities with your nonattest clients.
The issuance of the 2013 COSO
Framework provides a great
opportunity to visit the topic of
internal controls with your non-attest
clients.
Is everyone in your practice prepared
to discuss the importance of strong
internal controls and the way you can
help? PCPS Members can use the
Learning Guide and the Client Talking
Point Template to identify service
opportunities.
Recommended
Timing
Summer 2013Fall 2014
Tools and Resources
Owner
PCPS COSO Toolkit (AICPA’s PCPS Section members only)

Guide to the Changes and Impacts

Client Communication Template
For your attest clients
For your non-attest clients
Newsletter/website article
[Assigned
owner or task
force ]
DISCLAIMER: This publication has not been approved, disapproved or otherwise acted upon by any senior technical committees of, and does not represent an official position of, the American Institute of Certified Public Accountants. It is
distributed with the understanding that the contributing authors and editors, and the publisher, are not rendering legal, accounting, or other professional services in this publication. If legal advice or other expert assistance is required, the
services of a competent professional should be sought.
Copyright © 2013 by American Institute of Certified Public Accountants, Inc. New York, NY 10036-8775. All rights reserved. For information about the procedure for requesting permission to make copies of any part of this work, please
email copyright@aicpa.org with your request. Otherwise, requests should be written and mailed to the Permissions Department, AICPA, 220 Leigh Farm Road, Durham, NC 27707-8110.
www.aicpa.org/pcps
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