PowerPoint Presentation · 2020. 10. 14. · GAGAS: The New Yellow Book Alexander K. Buchholz is a Partner at PKF O'Connor Davies with over 15 years experience in public accounting,

Generally Accepted GovernmentAuditing Standards ("GAGAS"):

The New Yellow Book

March 10, 2020

Alexander K. Buchholz, CPA, MBA, CGMA

Partner

Not-for-Profit Services

646.965.7783

[email protected]

March 10, 2020

myCPE

GAGAS: The New Yellow Book

Alexander K. Buchholz is a Partner at PKF O'Connor Davies

with over 15 years experience in public accounting, including with a "Big Four"

accounting firm. His expertise is in Single Audits, internal control/compliance

audits and specialized cost reporting. His industry experience is in healthcare

and not-for-profit entities, including skilled nursing facilities, social service

agencies, charter schools, diagnostic and treatment centers, home care service

entities, adult homes and other long-term care facilities, special needs entities,

and cemeteries.

Alex is also an adjunct professor at Brooklyn College of the City University of New York in the Department of

Accounting where he teaches undergraduate and graduate courses in accounting and auditing. He also

teaches at Lehman College.

He conducts internal training seminars for the Firm and frequently speaks at outside organizations and

associations. He is also a former member of the Firm's continuing professional education (CPE) committee,

with special emphasis on Single Audit training. Alex has written many articles on accounting and auditing

topics for a variety of professional publications.

Biography

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Professional Affiliations & Civic Involvement

• American Institute of Certified Public Accountants (AICPA)

• New York State Society of Certified Public Accountants (NYSSCPA)

− Former Chair — Academic Advancement of Higher Education

− Former Chair — Healthcare Committee

− Former Member — Not-for-Profit Committee

− Former Foundation for Accounting Education

• National Conference of CPA Practitioners

• New York State Association of Cemeteries

• Metropolitan Cemetery Association

• Board member, New York State Board of Public Accountancy

• Board Member, St. Mary's Healthcare System for Children

Biography (continued)

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Presentation Disclaimer

Presentations are intended for educational purposes only

and do not replace independent professional judgment.

Statements of fact and opinions expressed are those of

the participant individually and, unless expressly stated to

the contrary, are not the opinion or position of the New

York State Board of Public Accountancy and / or PKF

O'Connor Davies, LLP.

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Important Instructions for the Live Webinar Program To earn full credit

• You are required to remain connected during the entire program

• You must answer all the polling questions

• You must complete the evaluation form after the webinar has ended

Polling Questions: In case you are unable to submit your response to a poll question

due to any technical issue, kindly reach out to the moderator via the questions/chat

panel or email at [email protected] with your poll question response during the

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About the Q&A Session

Please note that the Q&A Session will be at the end of the webinar, if time permits.

You can submit your questions through the questions panel, and it'll be put forward to

the speaker by the moderator.

In case you want to ask the question to the presenter directly through your computer or

cell phone, please make sure that the microphone of your device is working properly

and there's no background noise.

If you want to speak through your cell phone, the phone number and access code are

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Kindly refer to the screenshot below to access audio panel

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Learning Objectives

After attending this session, participants will be able to:

1. Discuss implementation of the New Yellow Book.

2. Discuss important points to convey in management

and audit committee meetings.

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Polling Question #1

How many yellow book audits does your firm perform in

a year?

a) Less than 10

b) Between 10-50

c) More than 50

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Quick Refresher: What is the Yellow Book?

Published by the United States Government Accountability

Office ("GAO")

Outlines requirements for audit reports, professional

qualifications for auditors, and the quality control process

for audit organizations

Also known as Generally Accepted Government Auditing

Standards, or GAGAS

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Quick Refresher: What is the Yellow Book? (continued)

Used by auditors of government entities, entities that

receive government awards, and other audit organizations

performing Yellow Book audits

Auditors of federal, state, and local government programs

must follow these standards to perform their audits and

produce their reports

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2018 Yellow Book – Effective Dates

Financial audits, attestation engagements, and reviews of

financial statements

For periods ending on or after June 30, 2020

Performance audits

For audits beginning on or after July 1, 2019

Early implementation is not permitted

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Polling Question #2

What is the effective date of for the New Yellow Book for

financial audits, attestation engagements, and reviews of

financial statements?

a) For periods beginning on or after June 30, 2017

b) For periods beginning on or after June 30, 2018

c) For periods ending on or after June 30, 2020

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2018 Yellow Book – Key Changes

New format

• Differentiates GAGAS requirements from application

guidance

Performance audits

• Updated internal control guidance

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2018 Yellow Book – Key Changes (continued)

Reporting cause in findings

• Auditor now must consider internal control deficiencies

• Applies to all engagement types

Independence changes

• Threats to an auditor's independence when preparing

financial statements from a client's records or providing

nonaudit services

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2018 Yellow Book – Key Changes (continued)

Peer review changes

• Revised requirements for audit organizations

Waste

• Added a requirement for waste, which is now defined by

the Yellow Book

CPE requirements

• Now included, but the required hours stay the same

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New Format

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New Format

Chapters reorganized and expanded

• Expanded from 7 chapters to 9 chapters

• Appendices removed

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21

New Format (continued)

Chapters now include Requirements and Application

Guidance

Requirements text is now in boxed text

Application Guidance text follows

Changes allow the auditor to clearly distinguish between

the GAGAS requirements versus GAGAS guidance

i.e. what is Must/Should versus what is May

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22


Supplemental Guidance from the appendix of the 2011

Yellow Book was either removed or incorporated into the

individual chapters

Auditors now need only consult one source—the 2018

Yellow Book—for both Requirements and Application

Guidance

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23


Requirements

Guidance

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Performance Audits

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25

Performance Audit Changes

GAGAS requirements for performance audits are in

Chapters 8 and 9 of the 2018 Yellow Book

Key change: Auditors must now consider whether internal

control is significant to the audit objectives

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Performance Audit Changes (continued)

Requirements: Determining Significance and Obtaining an

Understanding of Internal Control

8.39 – Auditors should determine and document whether

internal control is significant to the audit objectives.

8.40 – If it is determined that internal control is significant to

the audit objectives, auditors should obtain an understanding

of such internal control.

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Source: GAO Yellow Book, page 165

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Consideration of Internal Control

The Yellow Book considers, and defines, 4 key categories

of performance audit objectives:

Program effectiveness and results

Internal control

Compliance

Prospective analysis

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Source: Yellow Book 1.22, page 11-12


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28

Consideration of Internal Control

Auditors can look at Section 1.24 of the Yellow Book for

examples of audit objectives that focus on internal control

Example: determining whether "organizational missions,

goals, and objectives are achieved efficiently and effectively"

Source: Yellow Book page 13


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Example—Internal Control is Significant

Audit objective: Review and assess how a not-for-profit

allocates, spends, and monitors the receipt of State grants of

mental health funds.

Is Internal Control significant to this audit objective?

• Yes, based on Yellow Book 1.24 b. and d. As an example,

the auditor would test:

− Controls over allocations of grants

− Controls over grant fund expenditures

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Example—Internal Control is Not Significant

Audit objective: Review the adequacy of a college's

investigation of sexual harassment complaints

Is Internal Control significant to this audit objective?

• No, based on Yellow Book 1.23 a. and b. Internal control

is not a specific consideration

− Focus would be on adherence to requirements and

reasonableness of the investigation process

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31

Helpful Tip

Performance auditors can often rely on certain work done during

the auditee's financial audit

Financial audits must test and provide assurance on internal

control

Performance audits can rely on that assurance to the extent it

is relevant to the audit objectives


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Polling Question #3

Does your firm perform any performance audits?

a) Yes

b) No

c) Unsure

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Reporting Cause In Findings – Changes

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Reporting Cause in Findings

Findings—Assessing Cause and Internal Control

Deficiencies

Cause—a finding element that explains why the reported

condition exists

• Cause is the reason why condition and criteria do not

align

• Cause is often the basis for the auditor's

recommendations

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Reporting Cause in Findings (continued)

Findings—Assessing Cause and Internal Control

Deficiencies

Auditors now must consider internal control deficiencies

when developing cause

• Applicable to:

−Financial statement audits (6.18)

−Reviews of financial statements (7.20)

−Performance audits (8.117)

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Independence Changes

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37

Independence Changes

Most significant changes relate to performance of nonaudit

services that include preparing accounting records and


2018 Yellow Book retains much of its other independence

requirements and guidance

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38

Independence Goal

A threat to independence is not acceptable if:

• An auditor's professional judgment is comprised, or

• A reasonable and informed third party would conclude that

the integrity, objectivity, or professional skepticism of the

audit organization, or a member of the audit team, is

comprised

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Be Alert to the Independence Period

Per Yellow Book paragraph 3.20, auditors and audit

organizations should be independent from an audited entity

during:

• Any period of time that falls within the period covered by the

financial statements or subject matter of the engagement

and

• The period of the professional engagement (i.e.: Assisting

client in preparing the footnotes related to new accounting

standards for June 30, 2019 financial statements)

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40

Independence – Government Organizations

Recognizes that audit organizations in government entities

frequently provide services that differ from the traditional

professional services a firm provides

Types of services are often provided in response to a statutory

requirement; at the discretion of the authority of the audit

organization or to an engaging party

Generally do not create a threat to independence

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Overview of Key Independence Changes

41

Structure

Nonaudit services (most significant changes in preparation of accounting

records and financial statements and SKE clarifications)

• All nonaudit services that do not impair independence create a threat to

independence

Clarification of entity(ies) requiring independence – "responsible party"

Requirement to re-evaluate threats

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Applying the Conceptual Framework

42

1 Meet the general requirements

2 Determine nonaudit services are not otherwise prohibited

3 Identify threats to auditor's independence

4 Evaluate the significance of threats

5 Identify and apply safeguards

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New Skills, Knowledge and Expertise ("SKE") Application Guidance – Yellow Book Paragraph 3.79

Management not required to possess expertise needed to perform or re-

perform the services.

Indicators of management's ability to effectively oversee the nonaudit service

include management's ability to:

• Determine the reasonableness of the results of the nonaudit service

provided

• Recognize a material error, omission, or misstatement in the results of the

nonaudit services provided.

• If the audited entity is unable or unwilling to assume these responsibilities,

the auditor should conclude that this is an impairment to independence

43

YELLOW BOOK REQUIREMENT (Yellow Book 3.73): Auditors should determine that the audited entity has designated an

individual who possesses suitable SKE and that understands the services to be provided sufficiently to oversee them.

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Polling Question #4

Under the New Yellow Book, which of the below are no

longer requirements of management's ability to effectively

oversee the nonaudit service:

a) Determine the reasonableness of the results of the

nonaudit service provided

b) Recognize a material error, omission, or misstatement in

the results of the nonaudit services provided.

c) Reperform the services being performed by the

independent auditor

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45

Self-interest

Self-review

Bias

Familiarity

Undue influence

Management participation

Structural

3 Identify Threats to Auditor's Independence

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46

Evaluate threat for significance

Is the threat significant?

Document evaluation

and proceed

Is the nonaudit service

preparing the financial

statements (in their entirety)

from a client provided trial

balance or underlying

accounting records?

Identify and apply safeguards

Assess effectiveness of

safeguards(s)

Is threat eliminated or reduced

to an acceptable level?

Document nature of threat and

any safeguards applied

Proceed

Independence impairment –

Do not proceed

Yes

Yes

No No

No

NEW

2018 Yellow Book – Revised evaluation of nonaudit

services related to preparing accounting records and


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47

2018 Yellow Book-Independence Considerations for Preparing Accounting Records and Financial Statements

Determining or changing

accounting records

Authorizing or approving

the entity's transactions;

and

Preparing or making

changes to source

documents without

management approval

Independence

impaired!

Significant threats Create threats -

evaluate and

document

Preparing financial

statements in their

entirety (Yellow Book

3.88)

Other nonaudit

services described in

Yellow Book 3.89

related to preparing

accounting records

and financial

statements (see next

slide)

1 2 3

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Required Documentation – Preparing Accounting Records and Financial Statements

Any other nonaudit services related to preparing accounting

records and financial statements create a threat whose

evaluation for significance should be documented

Recording transactions for which management has determined

or approved the appropriate account classification, or posting

coded transactions to an audited entity's general ledger;

Preparing certain line items or sections of the financial

statements based on information in the trial balance

Posting entries that an audited entity's management has

approved to the entity's trial balance; and

Preparing account reconciliations that identify reconciling items

for the audited entity management's evaluation

48

See 2018

Yellow Book

paragraph

3.89

Bucket #3

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49

4 Evaluate the Significance of Threats

Extent

outcome could

have material

effect on

financial

statements

Factors in evaluating significance of preparing accounting records and


Degree of

subjectivity in

determining

amounts or

treatment

Extent of

entity's

involvement in

determining

significant

matters of

judgment

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50

4

Evaluation of Independence Threats Related to Preparing Financial Statements

If the auditor is preparing financial statements in their entirety, the

auditor must identify and apply safeguards

If the safeguards eliminate the threat or reduce it to an acceptable

level, the auditor should document the nature of the threat and any

safeguards applied and proceed

If the safeguards do not eliminate the threat or reduce it to an

acceptable level, independence is impaired and the auditor should

not proceed

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51

If the auditor is not preparing the financial statements in their

entirety, but performing other services related to the financial

statements, the auditor must evaluate those threats for significance

• If the threat is significant, the auditor must identify and apply

safeguards (see previous slide)

• If the threat is not significant, the auditor should document the

evaluation and proceed

Evaluation of Independence Threats Related to Preparing Financial Statements (continued)4

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What is a safeguard?

• Safeguards are actions or other measures, individually or

in combination, that auditors take that effectively eliminate

threats to independence or reduce them to an acceptable

level.

52

5 Identify and Apply Safeguards

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Example safeguards related to nonaudit services

• Not including individuals who provided the

nonaudit service on the audit engagement

team

• Someone not associated with the engagement

perform a concurring review of the audit

engagement

• Re-performance of the nonaudit service by

another audit organization

53

5 Identify and Apply Safeguards (continued)

Impact:

Firms that do not

have the ability to

apply safeguards

when required will

either need to

scale back

nonaudit services

or independence

will be impaired.

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Examples: Financial Statement Preparation

You audit NFP. You also have been engaged to prepare the financial

statements in their entirety (financial statements and footnotes) based on the

trial balance

The finance director has sufficient SKE to oversee this nonaudit service and

takes responsibility for the service

You previously evaluated threats in providing this nonaudit service as "not

significant" and therefore did not apply safeguards

The evaluation has not previously been documented because, in your view,

the 2011 Yellow Book, did not require documentation of the evaluation of

threats unless threats were significant and required safeguards

Question: What impact will the 2018 Yellow Book have on this

nonaudit service?

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Examples: Preparing Conversion Entries

You audit NFP Agency. You also have been engaged to assist with the

determination of conversion entries for the full accrual FS

The finance director has sufficient SKE to oversee this nonaudit service and

takes responsibility for the service

You previously evaluated threats in providing this nonaudit service as "not

significant" and therefore did not apply safeguards

The evaluation has not previously been documented because, in your view,

the 2011 Yellow Book, did not require documentation of the evaluation of

threats unless threats were significant and required safeguards

Question: What impact will the 2018 Yellow Book have on this

nonaudit service?

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New Application Guidance on Clerical Assistance

Providing clerical assistance, such as typing,

formatting, printing, and binding FS, is unlikely to be a

significant threat. (See Yellow Book paragraph 3.95)

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57

2018 Yellow Book Tips and Resources

Ensure all governmental audit staff receive 2018 Yellow

Book specific training

Review your nonaudit services and identify potential

issues with upcoming engagements

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Polling Question #5

As a result of this enhanced independence concerning

the preparation of financial statements and conversion

from cash to accrual basis, does this impact your

clients?

a) Yes

b) No

c) Unsure

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Peer Review Changes

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60

Peer Review ("PR") Requirements

2018 Yellow Book differentiates requirements for those audit

organizations affiliated with a recognized organization

(AICPA and the National State Auditors Association are

included on recognized organization list)

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Peer Review ("PR") Requirements (continued)

61

Comply with the respective

organization's PR requirements

Additional GAGAS peer review

requirements in areas such as:

• Selection of GAGAS engagements,

• Peer review report ratings, and

• Availability of peer review report to

the public

Audit organizations affiliated with a

recognized PR organization

Comply with GAGAS PR requirements

in such areas as:

• Selection of GAGAS engagements

• Peer review report ratings

• Availability of the peer review

report to the public

• Written agreement for peer review

• Peer review team

• Report content

• Audit organization's response to

the peer review report

Audit organizations NOT affiliated

with a recognized PR organization

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Waste

The 2018 Yellow Book provides a discussion of abuse in the

application guidance rather than the requirements

(paragraph 6.23-24).

Paragraph 6.21 defines waste as "the act of using or expending

resources carelessly, extravagantly, or to no purpose. Importantly,

waste can include activities that do not include abuse and does not

necessarily involve a violation of law. Rather, waste relates

primarily to mismanagement, inappropriate actions, and inadequate

oversight".

Paragraphs 6.22 and 6.24 list examples of waste and abuse,

respectively.

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Auditors Role in Waste

Auditors are not required to detect abuse or waste

• Since the auditee are using public resources and government authority, "auditors

may consider whether and how to communicate such matters if they become

aware of them.

• Auditors may also discover that waste or abuse are indicative of fraud or

noncompliance with provisions of laws, regulations, contracts, and grant

agreements" (Paragraph 6.20).

• Findings of abuse and waste may lead to further testing and search for internal

control deficiencies. The auditor's findings of abuse and waste may be included

in the audit report which is read by the auditee's stakeholders. These types of

findings can reduce the stakeholder's confidence in the entity's ability to be a

good steward of public resources.

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CPE Requirements

The continuing professional education topic is now included

as chapter 4 of the Yellow Book. The 2018 revision does not

change the amount of required CPE hours. The application

guidance now further highlights that to maintain competency,

CPE hours specific to GAGAS should be obtained

"particularly during years in which there are revisions to the

standards" (Paragraph 4.19).

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CPE Requirements (Summary)

Paragraph 4.16 Auditors who plan, direct, perform engagement procedures

for, or report on an engagement conducted in accordance with GAGAS

should develop and maintain their professional competence by completing

at least 80 hours of CPE in every 2-year period as follows:

• 24 Hours in subject matter directly related to the government

environment, government auditing, or the specific or unique environment

in which the audited entity operates.

• 56 Hours in subject matter that directly enhances auditors' professional

expertise to conduct audits

Exemptions to 56 hour requirement if less than 20 percent of time spent on

GAGAS audits and only involved in performing engagement procedures

(not planning, directing or reporting on engagement)

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CPE Requirements (continued)

Exemptions for all CPE requirements for nonsupervisory auditors

who charge less than 40 hours annually to GAGAS

Certain exemptions also allowed for students and interns for

limited time.

Exemptions also for support services only.

Exemption for specialist not involved in the planning, directing

performing engagement procedures, or reporting on a GAGAS

engagement as they are not auditors.

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Polling Question #6

How does your firm ensure your audit staff are in

compliance with CPE as it relates to yellow book

credits?

a) Attend webinars such as this one

b) Conduct in-firm training using subject matter experts

c) All of the above

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Summary

New Yellow Book requirements may effect audit and

nonaudit services for local governments, especially smaller

ones.

Local governments should be familiar with the Yellow Book

as it relates to procurement of audit and non-audit services.

Be prepared for possible increase in costs.

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Polling Question #7

Would you like to be contacted about having the speaker

present at one of your firm trainings in the near future on

this topic?

a) Yes

b) No

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should be considered as situation-specific tax or legal opinions and no options

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contained on our website or presentation is not intended to be used for the purpose

of avoiding penalties under U.S. federal tax law.

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Contact Information

www.pkfod.com

Alexander K. Buchholz

CPA, MBA, CGMA

Partner

Not-for-Profit Services

646.965.7783

[email protected]

73

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T: 203.929.3535
mailto:[email protected]

Documents

PowerPoint Presentation · 2020. 10. 14. · GAGAS: The New Yellow Book Alexander K. Buchholz is a Partner at PKF O'Connor Davies with over 15 years experience in public accounting,