Where Less Can Be Better
We first addressed SAS 145, Understanding the Entity and Its Environment and Assessing the Risks of Material Misstatement in our November 2021 blog. Two years later, the requirements are bearing down on us. SAS 145 is effective for audits of financial statements for periods ending on or after December 15, 2023. In other words, (for most of us) starting with our calendar year 2023 audits.
Audit risk assessment has long been a bane to the small practitioner, especially those whose practice consists primarily of perhaps smaller, less complicated audits. Some practitioners expressed concern that the standard contained concepts challenging to grasp and apply. Some felt that the cost of complying with the standard far outweighed the benefits. Others saw a formal risk assessment as beneficial to more complicated audits but only busywork for the less complex audits where risks were apparent going in. These negative views toward a standard-based risk assessment led to bastardizations of the process, such as:
- The assigning of the risk assessment to newly minted staff accountants who had limited (or no) knowledge of the industry, the client, and risk assessment in general,
- Doing the audit in reverse by diving head-first into substantive testing. Only at the tail-end of the audit would attention be given to a form-driven risk assessment limited by the diminishing remaining time allocated to fieldwork,
- Performing the risk assessment without modifying the standardized audit program to address the significant risk identified. In other words, just going through the motions,
- Rolling forward the prior year’s risk assessment with limited client inquiries, insufficient professional skepticism, and substandard documentation.
What Has SAS 145 Done For Us?
No Exemptions for Less Complex Audits. The standard does not exempt less complex audits from the risk assessment standard. To do so would be degrading to professional audits under generally accepted auditing standards. Risk must always be identified and addressed for an audit to be efficient and meaningful. However, it does incorporate scalability options into the standard.
Scalability – One Size Does Not Fit All. The standard provides guidance on the concept of scalability. It clarifies that the application of the standard can be designed to fit less complicated companies. In other words, auditor judgment should be used to match the standard’s requirements to the company’s complexity. The work can be scaled down and simplified to fit less complex entities. One size does not fit all. Accordingly, scalability, when understood in large part, addresses concerns expressed by auditors of less complicated entities.
Additionally, scalability is described in great detail in the AICPA’s Audit and Accounting Guide Risk Assessment in a Financial Statement Audit, updated to January 2023, to conform to SAS 145. It has numerous examples (“Scalability Scenario”) that explore the risk assessment requirements of SAS 145 to fit a less complex audit. It compares this to what would be done on a more complex audit. It is suggested that observation and inspection may often be used to obtain audit evidence to conform to the standard’s requirements for less complicated audits.
So, there is hope. The audit risk assessment is critical, but it is not intended to eat our lunch.
It is important to remember that size alone does not equal complexity. A company can be huge, yet due to the nature of its industry and limited use of advanced technology, not be considered complex. Therefore, audit risk assessment procedures can be scaled down. On the other hand, a small company in specific industries can be very complex. It may have several revenue streams and rely heavily on complex information technology. Accordingly, the risk assessment approach would be more demanding.
Getting Things in the Right Order
Understanding the reasons and necessity for a robust audit risk assessment (scalable when appropriate) places the audit procedures in the proper order. And here they are:
- Plan the audit. Planning includes several procedures, including preliminary analytics, brainstorming, establishing planning materiality, and risk assessment procedures.
- Tailor the audit program to address the identified risks.
- Perform substantive procedures to obtain audit evidence that reduces those risks to an acceptable level.
- Issue an appropriate report consistent with the audit evidence obtained.
Some Other New Requirements
SAS 145, in addition to new guidance on scalability, also provides the following new requirements:
- Separately assess inherent risk and control risk for each relevant assertion
- A requirement to assess control risk at maximum if controls are not to be tested for operating effectiveness
- A requirement that if the control risk (CR)is set at the maximum level (high), then the risk assessment for risk of a material misstatement (RMM) must be the same as the risk assessment for inherent risk (IR).
For example, if control risk is assessed as “high” and inherent risk is assessed as “low,” then the RMM must also be assessed as “low” – the same as inherent risk.
- A “stand-back” requirement
- A revised definition of significant risk and how to identify and assess such risks.
- A requirement to evaluate the design and implementation of general IT controls.
Peer Review Focus
Undoubtedly, risk assessment will continue to be a peer review focus in 2024 and beyond. Risk assessment has been a challenging audit area and a continuing focus of the AICPA initiative to improve audit quality.