Consistent with messaging over the past year, the PCAOB confirmed its plans to focus more on firms’ systems of quality control, including potentially updating the current quality controls standards. This was the message that I heard loud and clear at the PCAOB Small Business and Broker-Dealer Auditor Forum this past October where the PCAOB gave various updates on new auditing and other regulatory standards, current inspection trends, and anticipated future developments.
As any firm that has been through an inspection knows, the PCAOB currently reviews several quality control areas including tone at the top, client acceptance and continuance, independence policies and procedures, partner matters, firm policies, methodologies and guidance, training, and monitoring programs, such as internal inspections programs. Clearly, the PCOAB is going to be increasing its focus on these areas whether through new QC standards or increased scrutiny in firm inspections.
Board Member Duane DesParte called this out in his September 12, 2019 1 speech by saying, “I believe both the firms and the PCAOB should increase their focus on the firms’ quality control systems as an important driver in achieving sustainable, higher quality auditing.” Board Member DesParte went on to speak to various aspects of quality control including monitoring, for which he said, “Monitoring is another important element of an effective QC system. Our standards should continue to reinforce the importance of firms monitoring the quality of their overall audit practices as well as of individual audit engagements.”
While firms can design policies and procedures to be compliant with PCAOB standards, found mostly in QC Section 20 - System of Quality Control for a CPA Firm's Accounting and Auditing Practice, the fact remains that the effective implementation and execution of such policies and procedures is critical to ensuring audit quality. And how do firms ensure effective implementation of QC policies? Monitoring programs! In fact, monitoring is so important it has its own standard: QC Section 30 - Monitoring a CPA Firm's Accounting and Auditing Practice.
Taking all this into account, during the October forum session, the PCAOB asked firms, “Which element of quality control do you view as the strongest at your firm?”
The majority (53%) responded that independence, integrity, and objectivity was the strongest element. Only 8% felt that monitoring was the strongest element. That’s an alarmingly low statistic considering how critical monitoring programs are to ensure compliance with firm policies. I imagine the PCAOB will be focusing more and more on monitoring, evaluating the results of firms’ internal inspection programs and challenging the effectiveness of such programs, when compared to the PCAOB’s own inspection results. The PCAOB wants firms to continue to improve audit quality, not just in response to PCAOB inspections, but on a perpetual basis.
In August of 2019, the PCAOB moved its quality control initiative from a research project to a standard-setting project. The PCAOB intends to develop a concept release before the end of 2019 which will be available for public comment. Time will certainly help shed more clarity on the planned changes to the quality control standards, but monitoring will likely remain an important element with increased focus.
At Johnson Global Accountancy, we work with audit firms of all sizes to assist in implementing, improving and executing monitoring programs. Through our experience in the industry, we have helped firms develop methodology for monitoring programs over independence, partner rotation, and internal inspections. We have also worked with firms to help provide monitoring services including pre- and post-issuance reviews of audits. In this capacity, using a risk-based approach targeting common PCAOB inspection areas and significant risks, we work with engagement teams directly to review audits and identify potential deficiencies, prior to being identified by the PCAOB during an inspection. Effectively, we partner with firms and help improve their systems of quality control and assist in the implementation and execution of such controls.
1 PCAOB Board Member Duane M. DesParte. Improving Audit Quality through a Renewed Focus on Quality Control. September 12, 2019.
Dane Dowell is a Director at Johnson Global Accountancy who works with PCAOB-registered accounting firms to help them identify, develop, and implement opportunities to improve audit quality. With over 12 years of public accounting experience, he spent nearly half of his career at the PCAOB where he conducted inspections of audits and quality control. Dowell has extensive experience in audits of ICFR and has worked closely with attorneys in the PCAOB’s Division of Enforcement and Investigations. Prior to the PCAOB, he worked with asset management clients at PwC in Denver, Singapore, and Washington, DC.
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