Topic B-4 outsourcing the internal audit department

A.Introduction

Both in the UK and elsewhere in the world, an increased trend is towards the outsourcing of internal audit, either wholly or in part. In local government, the pressures to provide ‘best value’ and to adopt competitive tendering have resulted in internal audit departments facing challenges to the provision of an in-house service. There are a number of advantages and disadvantages of outsourcing of internal audit.

B.Advantages of outsourcing internal audit

·There is greater focus on cost and efficiency of the internal audit function.

·Internal audit staff can be used from a broader source of expertise, e.g. professional firms that may specialise in the particular type of organisation.

·Reduces the risk of high turnover or loss of staff from the internal audit department.

·External sources are useful for providing specialist, expensive skills such as IT or treasury, that an in-house department may find difficult to recruit or retain.

·Skills required for only a short time each year can be provided without incurring excessive costs of maintaining an in-house expertise.

·Contracting out could increase independence, since staff from an external firm will need to comply with robust ethical guidelines and are more likely to be rotated to avoid close working relationships building up.

·Outsourcing could provide access to new market place techniques without the need for significant levels of investment or in-house development. For example, outsourcing may include the use of audit methodology software that an in-house team would have to buy or develop.

With a professional outsourced department, less management time is required on internal audit, e.g. in appraisals, training and development.

C.Disadvantages of outsourcing internal audit

·Conflict of interest may arise if the outsourced internal audit service is being provided by the external auditors.

·There may be pressure on independence arising from the cost associated with the provision of internal audit. The outsourced department may experience pressure from management, either through a threat not to renew the outsourcing contract, or by withholding payment.

·There is the risk of lack of knowledge or awareness of the organisational objectives, culture or business.

·There is the increased cost of an outsourced service, with less time spent on internal audit.

·An outsourced department may not be able to provide the same flexibility or ready staff availability, particularly where problems arise, since they do not have a permanent presence.

·Standards of service may fall once the contract has been secured and the previous team disbanded.

There is a risk of blurring roles between internal and external audit, resulting in lesser credibility in both.

D. Procedures for outsourcing

Where outsourcing is carried out, some general procedures to minimise the risks and disadvantages are appropriate including:

·Controls over acceptance of internal audit contracts to ensure no impact on independence or ethical issues ·Regular reviews of the quality of internal audit work performed

·Separate departments covering internal and external audit

·Clearly agreed scope, responsibilities and reporting lines

·Performance measures, management information and risk reporting

Procedure manuals for internal audit.

·Increasingly, there is a trend towards a partnership approach, where specialist skills are provided by consultants or are outsourced, whilst the core internal audit department remains in-house.

History Exam Question Analysis

（A-Q1/D2001）

1 There are similarities and differences between the responsibilities of internal and external auditors. Both internal and external auditors have responsibilities relating to the prevention, detection and reporting of fraud, for example, but their responsibilities are not the same. Both internal and external audit are part of an organisation.s overall corporate governance arrangements. Sometimes, the responsibilities of internal auditors are out-sourced to external organisations.

Required:

（a）Explain the difference between the responsibilities of internal auditors and external auditors for the prevention, detection and reporting of fraud and error.（5 marks）（b）Explain the role of internal audit in the context of:

（i）corporate governance;

（ii）risk management;

（iii）organisational control.（10 marks）

Your answer should include one example of how an internal audit department in a manufacturing company might fulfil its role under each of the headings above.

（c）Outline the issues that should be considered when an organisation decides to out-source the internal audit function.（5 marks）

（20 marks）

[答疑编号10204101：针对该题提问]

1.（a）Fraud and error

（i）The duties of internal auditors are generally determined by the organisation that has set up the internal audit department and employs the internal auditors. Internal auditors normally have a general responsibility to perform their work and their reviews of systems with the possibility of fraud and error in mind. This means that when they review the structure and operation of systems they have regard to strengths in the system that will prevent or detect fraud and error and weaknesses that will facilitate fraud and error.

（ii）When internal auditors discover structural or operational weaknesses that facilitate or fail to prevent or detect fraud and error, they generally have a duty to report such matters internally. The precise method of reporting varies from organization to organisation. If internal auditors discover actual instances of fraud or error, they also have a duty to report it.

（iii）It can be difficult in practice for internal auditors to deal with actual or suspected management fraud. The .Rules of Professional Conduct. do not permit auditors to remain silent on the subject. There is no general duty to report fraud or error outside the organisation and internal auditors, like other employees, have a duty of confidentiality to the organisation they work for. In extreme circumstances however, it may be necessary for internal auditors to report matters to persons outside the organisation （where money laundering is discovered, for example）.

（iv）External auditors plan and perform their work with an attitude of professional scepticism. ISA 240 .Fraud and Error. States that the audit is designed to detect material errors, which may be due to fraud or error, but this does not mean that the audit can be guaranteed to detect material fraud or error. Fraud or error should only be

reported in the financial statements to shareholders if they are material. Like internal auditors, external auditors are bound by a duty of confidentiality to their clients. In most countries, external auditors do have a number of legal rights and duties to report certain types of suspected fraud, such as money laundering, to certain bodies. Confidential advice is available to external auditors from their professional bodies.

（b）Internal audit.s role

（i）Corporate governance

（1）The objectives of good corporate governance include: the proper constitution of the board, proper arrangements for the remuneration of directors, proper mechanisms for shareholder relations, and proper accountability and audit.

（2）Accountability and audit includes the maintenance of a proper system of internal control. A proper system of internal control includes appropriate risk management systems and overall organisational control.

（3）Internal audit.s role in the context of these objectives includes assisting management by suggesting ways in which these objectives can be achieved, and by monitoring progress.

Example for manufacturing company

The internal auditors can recommend to the board those areas in which structural changes need to be made in order to comply with codes of corporate governance, such as those issued by the OECD and the World Bank. They can recommend processes for setting objectives and targets, and for measuring their achievement.

（ii）Risk management

Internal audit has a particular interest in investigating and evaluating the company.s risk management structures. Internal audit can manage the provision of the basic data which management can use in order to identify, prioritise and manage the risks facing the company. Internal audit can also help by developing models and techniques for identifying, prioritising and managing risk.

Example for manufacturing company

（1）In a manufacturing company, risk management issues to be addressed include operational, financial, health and

safety and other regulatory issues. Internal audit can help in identifying the issues, evaluating their importance and

suggesting mechanisms for managing or transferring the risk.

（2）The management of risk depends on the business objectives, short and long term, strategic and operational, and

conflicts between objectives. These objectives include, for example, the need to provide a return to investors, the

need for long-term investment, and the need to produce a quality product. Internal audit can help classify those risks.

（iii）Organisational control

The simple existence of an internal audit function is an example of organisational control. Internal audit can investigate and document existing control systems, and recommend improvements.

Example for manufacturing company

Areas of control to be addressed include the overall control environment, operational control and other areas designed to manage the risks as identified above. Internal audit can help in providing cost-benefit analyses in respect of the implementation of control procedures, as well as making recommendations on structural control.

（c）Out-sourced internal audit issues

The issues to be considered include:

（i）The costs of out-sourcing the function, including the internal administrative costs and the costs of

managing the function. These may be more or less than internal costs, and a cost-benefit analysis will help establish the likely financial implications.

（ii）An out-sourced internal audit function will be more independent than an internal function, but this has to be set off against the （probably）superior knowledge of the business of the existing function.

（iii）Out-sourcing the internal audit function probably means a loss of control, whilst the responsibility for the function will remain with the company.

（iv）Change management issues have to be addressed which can be time consuming and expensive. Existing staff have to be re-deployed （perhaps to the company to which the function is out-sourced）and there may be resentment of the new internal auditors and deliberate attempts to frustrate them.

（v）The choice of the out-sourcing company is important. it must have sufficient resources and experience and there is always a risk associated with this; the contract with the out-sourcing company will have to be carefully worded and the initial contract should only be for a limited period of time.

（A-Q2/D2005）

2.You are the senior manager in the internal audit department of Octball Ltd. You report to the chief internal auditor and have a staff of six junior auditors to supervise, although the budget allows for up to ten junior staff.

In a recent meeting with the chief internal auditor, the difficulty of staff recruitment and retention was discussed. Over the past year, five junior internal audit staff have left the company, but only two have been recruited. Recruitment problems identified include location of Octball’s head office in a small town over 150 kilometres from the nearest major city and extensive foreign travel, often to cold climates.

Together with the chief internal auditor you believe that outsourcing the internal audit department may be a way of alleviating the staffing problems. You would monitor the new outsourced department in a part-time role taking on additional responsibilities in other departments, and the chief internal auditor would accept the post of Finance Director （FD）on the board, replacing the retiring FD.

Two firms have been identified as being able to provide the internal audit service:

– The NFA Partnership, a local firm specialising in provision of accountancy and internal audit services. NFA does not audit financial statements or report to members, and

–T&M, Octball’s external auditors, who have offices in 75 countries and employ in excess of 65,000 staff.

Required:

（a）Discuss the advantages and disadvantages of appointing NFA as internal auditors for Octball Ltd.（8 marks）

（b）Discuss the issues T&M need to consider before they could accept appointment as internal auditors for Octball.（7 marks）

（c）Assume that an outsourcing company has been chosen to provide internal audit services.

Describe the control activities that Octball should apply to ensure that the internal audit service is being maintained to a high standard.

（5 marks）

（20 marks）

[答疑编号10204102：针对该题提问]

2.（a）Benefits of outsourcing to NFA

Expertise available

The NFA partnership will be able to provide the necessary expertise for internal audit work. They may be able to provide a broader range of expertise as they serve many different clients therefore staff may be available for

specialist work that Octball could not afford to employ.

Buy-in skills as necessary

If internal audit is only required for specific functions or particular jobs each year then the expertise can be purchased as required. Taking this approach will minimise in-house costs.

Independence/Qualifications

No information is provided on the qualification of staff in NFA, although as an independent firm it is likely that care will be taken that staff do remain independent and have the appropriate qualifications in order that they can provide an appropriate high level of service.

Audit techniques-training

Outsourcing will remove the need for training internal staff. Effectively training will be provided for ‘free’ as the outsourcing firm will be responsible for keeping staff up-to-date with new auditing techniques and processes.

Problems with outsourcing to NFA

Fee pressure

NFA may experience some fee pressure, but only in respect of maintaining cost effectiveness of the internal audit department. The relationship needs to be managed carefully to ensure that NFA do not decrease the quality of their work due to insufficient fees.

Knowledge

The NFA partnership will not have any prior knowledge of Octball. This will be a disadvantage as this will mean the partnership will need time to ascertain the accounting systems and controls etc in Octball before commencing work. However, provision of an independent view may identify control weaknesses etc that the current internal audit department have missed.

Location

The NFA partnership may not be able to provide this service to Octball as they are a local firm and therefore the issue of travel and working away from home would remain.

Continuity of Service – staffing

As provision of audit services is the NFA partnership’s main activity, they should also be able to budget for client requirements although this cannot be guaranteed as staff may still leave. However, as a larger internal auditing firm, they will be able to offer staff better career progression which should assist staff retention.

（b）Items to be considered by T&M

Independence

T&M need to ensure that independence can be maintained in a number of areas:

– Independence regarding recommending systems or preparing working papers and subsequent checking of those systems or working papers. While the internal audit department may need to carry out these functions, T&M must ensure that separate staff are used to provide the internal and external audit functions.

– Staff from T&M will be expected to follow the ethical guidance of ACCA which means that steps will be taken to avoid conflicts of interest or other independence issues such as close personal relationships building up with staff in Octball. Any real or perceived threats to independence will lower the overall trust that can be placed on internal audit reports produced by T&M.

Training

As a firm of auditors, T&M will automatically provide training for its staff as part of the in-house compliance with association regulations （e.g. compulsory CPD was introduced from January 2005）. T&M will need to ensure that staff providing the internal audit function to Octball are aware of relevant guidance for internal auditors.

Skills

T&M must ensure that they have staff with the necessary skills and sufficient time to undertake the internal

audit work in Octball. Skills may not be an issue because staff in T&M will already understand audit procedures.

Fee pressure

There may be fee pressure on T&M, either to maintain the cost effectiveness of the internal audit department, or to maintain the competitiveness of the audit fee itself in order to keep the internal audit work.

Knowledge

As external auditors, T&M will already have knowledge of Octball. This will assist in establishing the internal audit department as systems documentation will already be available and the audit firm will already be aware of potential weaknesses in the control systems.

（c）Controls to maintain the standard of the internal audit department.

– If T&M are appointed, ensure that the internal and external audit is managed by different departments in the firm.

– Setting and review of performance measures such as cost, areas reviewed etc with explanations obtained for any significant variances.

– Use of appropriate audit methodology, including clear documentation of audit work carried out, adequate review, and appropriate conclusions drawn.

– Review of working papers by myself, ensuring adherence to International Standards on Auditing （UK and Ireland）where appropriate and any in-house standards on auditing.

– The work plan for internal audit is agreed prior to work commencing and this is followed by the outsourcing company.

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