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2011 Yellow Book: What You
Need to Know
West Virginia AGA
Spring Training
MOV AGA Chapter
Parkersburg, WV
May 14, 2013
Nicole M. Burkart
1
Session Objectives
The 2011 revision of Government Auditing
Standards represents a modernized version of the
standards. During this session, we will:
• Highlight major changes from the 2007 revision,
focusing on independence
 Conceptual framework for independence added
 New documentation requirements
• Highlight changes made for financial audits and
attestation engagements
• Highlight changes made for performance audits
2
Primary Yellow Book Changes
• Conceptual framework for independence added
 Identify, evaluate, and apply safeguards to address
threats to independence
 Can be applied to many variations in circumstances
• New documentation requirements
 Focus on nonaudit services
• Changes made for financial audits and
attestation engagements
 Focused on converging standards where practical
• Changes made for performance audits
 Clarified definition of validity
3
2011 Yellow Book
Applicability
• Chapters 1, 2, and 3 apply to all GAGAS
engagements
 Chapter 1: Government Auditing: Foundation and
Ethical Principles
 Chapter 2: Standards for Use and Application of
GAGAS
 Chapter 3: General Standards
• Chapter 4: Standards for Financial Audits –
applies only to financial audits
• Chapter 5: Standards for Attestation
Engagements – applies only to attestation
engagements
4
2011 Yellow Book
Applicability (Continued)
• Chapters 6 and 7 apply only to performance
audits
 Chapter 6: Field Work Standards for Performance
Audits
 Chapter 7: Reporting Standards for Performance Audits
• Appendix I: Provides supplemental guidance (not
requirements) for all GAGAS engagements
• Available on the Yellow Book webpage:
 Interpretations
 Supplemental guidance (not requirements) for areas of
particular interest or sensitivity
5
2011 Yellow Book
Effective Dates
• Effective for financial audit periods ending on
or after December 15, 2012
• Effective for attestation periods ending on or
after December 15, 2012
• Effective for performance audits starting on
or after December 15, 2011
• Independence may be impacted before the
beginning of an engagement
6
Chapter 1:
Purpose and Applicability of GAGAS
• GAGAS provides a framework for conducting
high quality audits with competence, integrity,
objectivity, and independence.
 For use by auditors of government entities and entities
that receive government awards
• Provisions of laws, regulations, contracts, grant
agreements, or policies frequently require audits
to be conducted in accordance with GAGAS.
7
Chapter 2:
Types of GAGAS Engagements
• All audits begin with objectives and those
objectives determine the type of audit to be
performed and the applicable standards to be
followed.
• The types of audits that are covered by GAGAS,
as defined by their objectives, are classified in
the Yellow Book as:
financial audits,
attestation engagements, and
performance audits.
8
Chapter 2:
Financial Audits
• Financial audits provide an independent
assessment of whether an entity’s reported
financial information is presented fairly in
accordance with recognized criteria.
 Reasonable assurance
• Financial audits performed in accordance with
GAGAS include:
 Financial statement audits
 Other types of financial audits
• GAGAS incorporates by reference AICPA SASs
and includes additional requirements
9
Chapter 2:
Attestation Engagements
• Attestation engagements can cover a broad
range of financial or nonfinancial objectives
about the subject matter or assertion depending
on the users’ needs.
• GAGAS incorporates by reference AICPA
SSAEs and includes additional requirements
• The three types of attestation engagements are:
 Examination
 Review
 Agreed-Upon Procedures
10
Chapter 2:
Attestation Engagements (Continued)
• Examination
 Opinion
 Reasonable assurance
• Review
 Conclusion
 Limited assurance
 Auditors should not perform review-level work for
reporting on internal control or compliance with
provisions of laws or regulations.
• Agreed-Upon Procedures
 Findings (NOT an Opinion or Conclusion)
11
Chapter 2:
Performance Audits
• Performance audits are defined as audits that
provide findings or conclusions based on an
evaluation of sufficient, appropriate evidence
against criteria.
• Performance audits provide objective analysis
to assist management and those charged with
governance and oversight in using the
information to:
 improve program performance and operations,
 reduce costs,
 facilitate decision making, and
 contribute to public accountability.
12
Chapter 2:
Nonaudit Services
• GAGAS does not cover nonaudit services,
which are defined as professional services other
than audits or attestation engagements.
• When audit organizations provide nonaudit
services to entities for which they also provide
GAGAS audits, they should assess the impact
that providing those nonaudit services may
have on auditor and audit organization
independence and respond to any identified
threats to independence in accordance with the
GAGAS independence standard.
13
Chapter 2:
Use of Terminology
• Requirements are identified through the use of
specific language.
 Must indicates an unconditional requirement
 Should indicates a presumptively mandatory
requirement
 Text not using the above conventions is considered
explanatory material
• Auditors have a responsibility to consider the
entire text of GAGAS in carrying out their work
and in understanding and applying the
requirements in GAGAS.
14
Chapter 2:
Stating Compliance with GAGAS
• Auditors should include one of the following
types of GAGAS compliance statements in
reports on GAGAS audits:
 Unmodified
 Modified
• Determining the appropriate GAGAS compliance
statement is a matter of professional judgment.
• Auditors may also cite the use of other standards
in reports on GAGAS audits when they have met
the requirements of those standards, as well as
GAGAS.
15
Chapter 3:
General Standards
• General standards, along with the overarching
ethical principles presented in Chapter 1,
establish a foundation for the credibility of
auditors’ work.
• Chapter 3 is comprised of four sections:
 Independence
 Professional Judgment
 Competence
 Quality Control and Assurance
16
Chapter 3:
Independence
• In all matters relating to the audit work, the audit
organization and the individual auditor, whether
government or public, must be independent.
• Independence comprises:
 Independence of Mind – state of mind that permits the
performance of an audit without being affected by
influences that compromise professional judgment
 Independence in Appearance – absence of
circumstances that would cause a reasonable and
informed third party to conclude that integrity,
objectivity, or professional skepticism had been
compromised
17
Chapter 3:
Independence (Continued)
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Chapter 3:
Independence (Continued)
• Independence Timeframes
 Any period of time that falls within the period covered
by the financial statements or subject matter of the
audit (i.e. the period of time covered by the audit)
 The period of the professional engagement
• The period of the professional engagement lasts
for the entire duration of the professional
relationship (which, for recurring audits, could
cover many periods).
19
Chapter 3:
Conceptual Framework
• GAGAS establishes a conceptual framework that
auditors use to identify, evaluate, and apply
safeguards to address threats to independence
 Can be applied to many variations in circumstances
that create threats to independence
 Allows auditors to address threats to independence
that result from activities that are not specifically
prohibited by GAGAS
 Serves as a hybrid framework that balances principle
and rules based standards
20
Chapter 3:
Conceptual Framework (Continued)
Assess condition or activity for
threats to independence
Threat identified?
No
Proceed
Yes
Is threat related to a nonaudit
service?
No
Yes
Is the nonaudit service specifically
Yes
prohibited in GAGAS paragraphs
3.36 or 3.49 through 3.58?
No
Assess threat for significance
Is threat significant?
No
Proceed
Yes
Identify and apply safeguard(s)
Assess safeguard(s)
effectiveness
Is threat eliminated or reduced to No
an acceptable level?
Yes
Document nature of threat and
any safeguards applied
Proceed
Independence
impairment; do
not proceed
21
Chapter 3:
Conceptual Framework (Continued)
• Threats to independence are circumstances that
could impair independence.
 Nature
 Significance
 Safeguards
• Threats are conditions to be evaluated using the
conceptual framework.
• Safeguards are controls designed to eliminate or
reduce to an acceptable level threats to
independence.
22
Chapter 3:
Conceptual Framework (Continued)
• Applying the Conceptual Framework
 Identify threats to independence
 Evaluate the significance of the threats identified, both
individually and in the aggregate
 Apply safeguards as necessary to eliminate the
threats or reduce them to an acceptable level
• Safeguards need to be effective in order address
threats to independence.
• If it is necessary to apply safeguards, auditors
should document the threats identified and the
safeguards applied to eliminate the threats or
reduce them to an acceptable level.
23
Chapter 3:
Conceptual Framework (Continued)
• Categories of Threats
 Self-Interest
 Self-Review
 Bias
 Familiarity
 Undue Influence
 Management Participation
 Structural
24
Chapter 3:
Conceptual Framework (Continued)
• Examples of safeguards include:
 consulting an independent third party, such as a
professional organization, a professional regulatory
body, or another auditor;
 involving another audit organization to perform or reperform part of the audit;
 having a professional staff member who was not a
member of the audit team review the work performed;
and
 removing an individual from an audit team when that
individual’s financial or other interests or relationships
pose a threat to independence.
25
Chapter 3:
Documenting Threats and Safeguards
• Threat and Safeguard Documentation
Requirements
 Document threats to independence that require the
application of safeguards (i.e. threats that are not at
an acceptable level), along with safeguards applied,
in accordance with the conceptual framework
 Document how safeguards were applied (i.e.
appropriately designed and implemented) to ensure
that an audit organization structurally located within a
government entity is independent
26
Chapter 3:
Provision of Nonaudit Services
Nonaudit Services versus Routine Activities
• Nonaudit services are consistent with auditors’
skills and expertise, but do not relate directly to
the performance of an audit.
 Providing nonaudit services may create threats to
independence.
• Routine activities related directly to the
performance of an audit are not considered
nonaudit services under GAGAS.
 Routine activities generally involve providing advice or
assistance on an informal basis as part of an audit.
 Routine activities are typically insignificant in terms of
time incurred or resources expended.
27
Chapter 3:
Documenting Nonaudit Services
• Nonaudit Service Documentation Requirements
 Document consideration of audited entity
management’s ability to effectively oversee a
nonaudit service to be provided by the auditor
 Document the auditor’s understanding with an audited
entity for which the auditor will perform a nonaudit
service
• Before providing nonaudit services, the auditor
should determine that the audited entity has
designated an individual who possesses suitable
skill, knowledge, or experience, and that the
individual understands the services to be
performed sufficiently to oversee them.
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Chapter 3:
Prohibited Nonaudit Services
Assuming Management Responsibilities
• Setting policies and strategic direction for the audited entity
• Directing and accepting responsibility for the actions of the
audited entity’s employees in the performance of their
routine, recurring activities
• Having custody of an audited entity’s assets
• Reporting to those charged with governance on behalf of
management
• Deciding which of the auditor’s or outside third party’s
recommendations to implement
• Accepting responsibility for the management of an audited
entity’s project
• Accepting responsibility for designing, implementing, or
maintaining internal control
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Chapter 3:
Prohibited Nonaudit Services
Assuming Management Responsibilities (Continued)
• Providing services that are intended to be used as
management’s primary basis for making decisions that are
significant to the subject matter of the audit
• Developing an audited entity’s performance measurement
system when that system is material or significant to the
subject matter of the audit
• Serving as a voting member of an audited entity’s
management committee or board of directors
• Performing ongoing monitoring procedures on behalf of
management
Complete List of Prohibited Nonaudit Services:
Paragraphs 3.36 and 3.49 – 3.58
30
Chapter 3:
Continuing Professional Education
No revision to overall requirements:
• Minimum of 24 hours of CPE every 2 years
 Government auditing or the government environment
 Specific or unique environment in which the audited
entity operates
• Additional 56 hours of CPE for auditors:
 Involved in any amount of planning, directing, or
reporting on GAGAS audits, or
 Charging 20 percent or more of their time annually to
GAGAS audits.
• Minimum of 20 hours of CPE each year
31
Chapter 3:
Continuing Professional Education
Changes Related to CPE:
• Clearer distinction between internal and external
specialists
 External specialists assisting in performing a GAGAS
audit are not required to meet GAGAS CPE
requirements, but should be qualified and competent in
their areas of specialization
 Internal specialists who are not involved in directing or
performing audit procedures or reporting on a GAGAS
audit are also not required to meet GAGAS CPE
requirements, but should be qualified and competent in
their areas of specialization
32
Chapter 3:
Monitoring of Quality
• The auditor organization should analyze and
summarize the results of its monitoring process at
least annually, with identification of any systemic
or repetitive issues needing improvement, along
with recommendations for corrective action.
• The audit organization should communicate to
appropriate personnel any deficiencies noted
during the monitoring process and make
recommendations for appropriate remedial action.
33
Chapter 3:
External Peer Review
• The audit organization should obtain an external
peer review at least once every 3 years.
• The peer review team uses professional judgment
in determining the type of peer review report. The
following are the types of peer review reports:
 Peer review rating of pass
 Peer review rating of pass with deficiencies
 Peer review rating of fail
34
Chapter 4:
Standards for Financial Audits
• Eliminated redundancy with AICPA standards
• Clarified additional GAGAS requirements
 Performing Financial Audits
 Reporting on Financial Audits
• Additional GAGAS considerations
 Materiality
 Early Communication of Deficiencies
• Combined 2007 GAGAS Chapters 4 and 5 into
one chapter (2011 GAGAS Chapter 4)
No new requirements were added for financial audits.
35
Chapter 5:
Standards for Attestation Engagements
• Separated attestation engagement requirements
by category of engagement
 Examination Engagements
 Review Engagements
 Agreed-Upon Procedures Engagements
• Within each category, emphasized:
 Additional GAGAS reporting requirements
 Required elements of AICPA reporting
No new requirements were added for attestation
engagements.
36
Chapters 6 and 7:
Performance Audits
• The discussion of validity as an aspect of the
quality of evidence has been revised to indicate
that it is the extent to which evidence is a
meaningful or reasonable basis for measuring
what is being evaluated.
 In other words, validity refers to the extent to which
evidence represents what it is purported to represent.
37
Chapters 6 and 7:
Performance Audits (Continued)
• The fraud reporting requirement is now limited to
occurrences that are significant within the context
of the audit objectives, with a requirement to
communicate in writing other instances of fraud
that warrant the attention of those charged with
governance.
38
Questions?
The Yellow Book is available on GAO’s website at:
www.gao.gov/yellowbook
For technical assistance, contact us at:
yellowbook@gao.gov
(202) 512-9535
39
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