Struggling to incorporate the COSO recommendations into your audit process?
Here’s one audit shop’s winning strategy.
By Dennis Applegate and Ted Wills
December 1999 issue of Internal Auditor
Published by The Institute of Internal Auditors
In 1992, the committee of sponsoring organizations of the Treadway Commission (COSO) issued a landmark report on internal control. Internal Control—Integrated Framework, which is often referred to as "COSO" provides a sound basis for establishing internal control systems and determining their effectiveness.
Following the report’s publication, The Boeing Company adopted the COSO principles partly as the basis for its internal control policies and procedures. As a result, our internal audit department began to rate the quality of internal controls covered in each audit. We soon discovered that incorporating these standards into actual practice proved challenging. While informative, our ratings were mostly subjective, lacking the systematic analysis and documented support normally reflected in our reports. To achieve a higher quality result, we reengineered our existing audit methodology—from inception, through fieldwork, to final reporting—to fit the COSO framework.
Our effort was a success. No longer incidental to our processes, COSO now provides the foundation for all our audit work.
The approach
Our integration of COSO into the audit process is similar to one described in The IIA Research Foundation report, The Internal Auditor’s Role in Management Reporting on Internal Control. The report suggests that audit results be cataloged in terms of the COSO framework and that this information be utilized in top-level reports to management and the board of directors. Our approach builds on some of these concepts by incorporating COSO criteria into each stage of the audit process.
According to COSO, the three primary objectives of an internal control system are to ensure (1) efficient and effective operations, (2) accurate financial reporting, and (3) compliance with laws and regulations. The report also outlines five essential components of an effective internal control system:
° THE CONTROL ENVIRONMENT, which establishes the foundation for the internal control system by providing fundamental discipline and structure.
° RISK ASSESSMENT, which involves the identification and analysis by management—not the internal auditor—of relevant risks to achieving predetermined objectives.
° CONTROL ACTIVITIES, or the policies, procedures, and practices that ensure management objectives are achieved and risk mitigation strategies are carried out.
° INFORMATION AND COMMUNICATION, which support all other control components by communicating control responsibilities to employees and by providing information in a form and time frame that allows people to carry out their duties.
° MONITORING, which covers the external oversight of internal controls by management or other parties outside the process; or the application of independent methodologies, like customized procedures or standard checklists, by employees within a process.
We use these elements to define the control objective to be audited, assess the components of Boeing’s control system, and report the results to management. Integrating COSO in this manner adds structure to our audit process, ensures that appropriate criteria are considered in key phases of each audit, and provides a trail to support the conclusions reached.
Defining Objectives
A key aspect of our reengineered process is that we focus each audit on a single COSO objective, rather than on many audit objectives. Each auditor, in conjunction with management, determines the appropriate COSO objective—operations, financial reporting, or compliance. This determination is made during audit planning and formally documented in the working papers. Concentrating on one audit objective allows us to improve audit focus and efficiency. If another objective needs to be addressed, a separate audit can be initiated.
If, after conducting audit research or fieldwork, a deviation from the predefined objective becomes necessary, the proposed change must be reviewed and approved by audit management. The working papers also must be amended to describe the rationale for changing the objective. As a practical matter, audit projects are normally completed without varying from the initial COSO objective.
Most audit projects will have a readily apparent objective based on the function or process to be reviewed. For example, a "program shop scheduling" audit clearly falls into the operations category. The objective of other audits, however, may not be so obvious. A "receiving inspection" audit may have either an operations focus or a compliance focus, depending on the type of management controls to be examined. Similarly, an audit such as "cost collection on the shop floor" may focus on operations or financial reporting, again depending on the controls to be assessed. For those few projects where the COSO objective is not clearly ascertainable, it is the auditor’s responsibility to identify the controls on which the majority of the audit work will concentrate and to select the appropriate audit objective based on the following guidance.
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BENEFITS OF COSO-BASED AUDITS
Effectiveness
Testing all five COSO control components provides a solid foundation for determining the degree of assurance provided by controls.
Efficiency
Focusing on one COSO objective category guards against costly "scope creep."
Comparability
Using a common audit framework and rating system enables the controls in different business segments to be contrasted.
Communication
Integrating COSO criteria in discussions with clients enhances their understanding of control concepts.
Audit Committee
Reporting in terms of the COSO framework helps to portray strengths and weaknesses of the internal control system.
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Operations An operations objective focuses on controls governing efficiency and effectiveness. Effectiveness concerns the quality of controls over the achievement of specific management objectives, while efficiency addresses the quality of controls yielding an optimum measure of resource inputs to productive outputs. An operations audit should determine whether the organization can be reasonably assured that no material inefficiencies or lack of effectiveness exist in the audited organization or process.
Because Boeing is in a highly regulated industry, it is tempting to regard every operations audit as a compliance audit. However, an overall evaluation cannot be provided unless the audit evaluates the entire system of controls for ensuring compliance with laws and regulations. Such a system includes the relationship with the regulatory agency, Boeing internal policies and procedures, the people specifically assigned to promote compliance, and the methods for monitoring compliance effectiveness. Only audits that address each aspect of the compliance program can render an overall opinion on how well the system of internal controls assures compliance with the laws and regulations in question.
At the same time, operations audits that incidentally identify noncompliance with internal procedures provide useful information that must be communicated to management. Auditors are expected to note such potentially illegal violations as incidental findings on the control evaluation form.
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RATING CRITERIA FOR COSO-BASED AUDITS
Control Component CRITERIA FOR UNSATISFACTORY RATING
Control Environment "Hard controls" are missing or inadequate.
There are verified instances of breakdowns of "soft controls."
Risk Assessment Management has not predefined relevant objectives.
Such objectives are incompatible with broader objectives.
Management has not identified relevant risks to achieving its objectives.
Management does not have a basis for determining which risks are most critical.
Management has not ensured mitigation of critical operating risks.
Audit tests detect key risks not previously contemplated by management.
Control Activities Key control activities are not functioning as intended.
Management’s risk mitigation strategy is not adequately reflected within control activities.
Information & Communication Key metrics are not identified, collected, and communicated.
Employees do not understand their control responsibilities, and this is pervasive.
Customer or supplier complaints and disputes are not resolved, or remedial action is not undertaken in a timely manner.
Monitoring Management has not established a means of determining the quality of the internal control system over time, either through independent evaluations or ongoing, structured, and independent process checks.
Overall The ratings of all components should be considered to determine whether controls provide reasonable assurance that management objectives will be achieved. A strength in the internal controls of one component may compensate for a control weakness in another.
Financial Reporting In audits where the objective is financial reporting, emphasis is placed on the adequacy and effectiveness of management controls governing the reliability of financial data used for external reporting purposes. An audit based on such controls should provide reasonable assurance that no material misstatements exist in the examined data. Tracing audit controls and financial data back to the financial statements is indicative of an audit with a financial reporting objective.
An audit that reviews the assumptions and methods used to estimate contract costs-at-completion typically has a financial reporting objective. Similarly, audits of accounting controls that govern the preparation of financial statements generally will have financial reporting as their audit objective. Th