Promising Practices in Evaluating Federally Funded Award Portfolios

The mission of the National Science Foundation (NSF) Office of Inspector General (OIG) is to provide independent oversight of NSF to improve the effectiveness, efficiency, and economy of its programs and operations, and to prevent and detect fraud, waste, and abuse. That mission extends to overseeing the 11,000 grants, cooperative agreements, and contracts that NSF awards annually to more than 2,000 colleges, universities, and other institutions. These awards fund basic and applied research; support science, technology, engineering, and mathematics (STEM) education; and help strengthen the U.S. research enterprise.

We conduct audits and reviews of NSF’s award recipient organizations to ensure they follow applicable federal regulations and NSF terms and conditions, and that costs claimed on NSF awards are allowable, reasonable, allocable, and necessary to complete award objectives. Through this work we’ve had the opportunity to identify areas of elevated risk that are common to managing federal awards, as well as trends and practices that can help enhance stewardship of federal funds.

A Resource for College and University Auditors

We regularly contract with independent public accounting firms to conduct audits of NSF award recipients on our behalf. In 2022, we published a capstone report, Promising Practices for NSF Award Management, which cataloged our contractor’s observations of award recipients’ control weaknesses and strengths over a 3-year period. The report includes the 5 most frequent finding categories we identified, 46 distinct examples of our most common findings, and promising practices we observed to strengthen controls within those areas. We believe this report will provide a strong foundation for any college or university auditor to develop a risk assessment or audit program related to their institution’s federally funded award portfolio.  

Common Finding Categories

The most common audit finding categories at the institutions we audited included:

  • Unallowable expenses ― We identified costs related to unallowable travel, participant support, salary, material/supply, fringe benefit, publication, consultant, and subaward costs charged to NSF awards.
  • Inappropriately applied indirect costs ― Recipients did not always apply indirect costs to the appropriate Modified Total Direct Cost base and did not apply indirect costs at the rates approved within the recipient’s Negotiated Indirect Cost Rate Agreements.
  • Inadequately supported expenses ― Recipients did not always maintain sufficient evidence to support costs claimed in NSF’s Award Cash Management Service, costs billed by internal service providers, and travel, salary, and consultant costs charged to NSF awards were allowable per federal and NSF regulations.
  • Inappropriately allocated expenses ― We identified instances where recipients inappropriately allocated travel, materials and supplies, publication, and student stipend or tuition costs to NSF awards.
  • Non-compliance with policies and procedures  Recipients did not always comply with, or did not document their compliance with, organization and NSF program-specific policies and procedures.

Promising Practices

The report identified the following promising practices that could help decrease the likelihood of recipient non-compliance with federal and NSF criteria, as well as improve the stewardship of federal funds:

  • Continually monitor and verify the allowability of high-risk expenses. Recipients were less likely to charge unallowable costs to NSF awards if they implemented processes for the continuous monitoring of high-risk expenses, rather than waiting until after the award expired to review the allowability of the expenses.
  • Strengthen controls over applying indirect cost rates. For example, recipients could implement controls to identify when indirect cost rates change between the proposal submission date and the award date and establish guidance identifying the appropriate indirect cost rate for sponsored projects awarded during provisional rate periods.
  • Ensure recipients create and maintain sufficient, appropriate documentation. Recipients with more robust requirements for documentation creation and retention were more likely to maintain sufficient, appropriate documentation to support that expenses charged to NSF awards were reasonable, allocable, and allowable.
  • Document and justify reasonable allocation methodologies. Recipients that require staff to document and justify reasonable allocation methodologies when purchasing goods and services were more likely to maintain sufficient documentation to support that they had allocated sampled expenses to NSF awards consistent with the relative benefits received by those awards.
  • Regularly review and update grant management policies and procedures. Recipients would have benefited from reviewing and updating their grant management practices on a regular basis. Many noted that their policies did not accurately reflect their current procedures, or they were already in the process of updating the cited policies and procedures.

We hope our Promising Practices for NSF Award Management report will serve as a valuable tool as you evaluate your institution’s federally funded award portfolio. If you have questions, please feel free to reach out to us at OIGPublicAffairs@nsf.gov. Our audit reports of NSF funded institutions can be found on our website.

To report research misconduct or other forms of fraud, waste, abuse, or whistleblower reprisal, please contact us by:

  • Web: oig.nsf.gov/contact/hotline
  • Anonymous Hotline: 1.800.428.2189
  • Mail: 2415 Eisenhower Avenue, Alexandria, VA 22314 ATTN: OIG HOTLINE

What’s on Your Audit Plan?

Every Spring, university audit shops must determine what to include on their audit plan for the next fiscal year. The Chief Audit Executive performs a risk assessment, seeks input from senior leadership, reviews strategic plans and industry trends, and analyzes resources to form an effective plan. While every college and university has unique individual risks and goals, common audit themes emerge and change from year to year.

Most Beneficial Audits of FY23

The ACUA Journal polled the membership and asked which engagements were the most impactful from Fiscal Year 2023. Out of the 58 surveys submitted, 33% of the responses said cybersecurity was most critical. Higher education institutions maintain a wide range of sensitive data, including academic records, student financial details and health care information, along with sensitive research and financial information. Colleges and universities continue to be victims of phishing and ransomware attacks. It is not surprising that cybersecurity audits top the list. Information Technology (IT) general controls and user access were other important IT audits.

Audits of human resources was the second highest, at 16% of responses. This is likely due to employment changes due to the pandemic, with some campuses auditing work from home practices. Payroll audits were beneficial at three universities.

Research security was third highest, at 9% of responses. This topic goes hand in hand with general cybersecurity, as research and study subject data is highly sensitive and desirable. Other topics included foreign influence and research administration, operations, and post-award reviews. Grant funding reviews were noted, including HEERF and CARES pandemic funding grants.

Athletics, admissions, and minors on campus were also noted as the most beneficial audits. See the complete list below:

Table showing FY23 most beneficial audits.

Hot Audit Topics for FY24

he ACUA Journal asked for the “hot” audit topics on the FY24 audit plan, and the responses were surprisingly diverse. Of the 62 topics offered, no single topic received more than six votes. This speaks to the wide risk universe present at colleges and universities. The hottest topics were contracted services with third parties and a repeat of cybersecurity, each with 10%. Research compliance, a perennial favorite, was third on the list with four votes.

Admissions is receiving more attention this year, with planned audits of course fees, enrollment, scholarships, student aid, and student fees. Name, image and likeness (NIL) appeared on the athletics topics. Diversity, equity and inclusion (DEI) and environmental, social and governance (ESG) are increasing in importance this year. Three universities are in various stages of auditing Workday software implementation.

Campus safety, including minors on campus and lab safety, are hot topics this year. There is also an interest in auditing student life, with planned audits of study abroad and student mental health. Familiar financial audits like purchasing cards, segregation of duties, and competitive bids round out the list. The complete list of hot audit topics for FY24 are below:

Table listing hot audit topics for FY24.

Common Audit Plan Favorites

In addition to the hot and emerging topics, there is value in considering recurring internal audit projects with sizable risk. Here are some of the most common college and university audit topics by category:

  • Admissions – admissions review
  • Athletics – NCAA compliance
  • Capital Projects – construction and contracts
  • Financial Management – travel and entertainment review, purchasing card review, payroll
  • Human Resources – hiring, retention, terminations and DEI
  • Information Technology – system implementation, IT general controls, access, disaster recovery, data privacy and cybersecurity
  • Operations – college general controls, centers and institutes
  • Research – sponsored award administrative review, foreign influence, conflict of interest, effort reporting
  • Student Life – housing, Greek life

Whether your work plan includes emerging trends, classic engagements, or a combination of both, it should be tailored to your college or university’s risks and strategic plans to ensure internal audit resources address your specific business processes and risk drivers. Even the best audit plan needs to be agile and budget for contingencies.

Share Your Expertise: ACUA Mentorship Program

The ACUA mentorship program is in its 7th year of pairing those new to internal audit, higher education, and/or seeking professional development with experienced ACUA mentors. The program promotes networking, sharing knowledge, and professional growth, and is a no-cost member benefit. There are currently eighteen pairings for this fiscal year. Once a mentee is matched with a mentor, the two usually meet at AuditCon or virtually to start their fiscal year commitment, which often includes monthly or bimonthly meetings.

Patrick McKinney, Director of Internal Audit at The University of Texas, is the new director of the program and is in charge of matching mentee applicants with mentors. Mentees complete a questionnaire that includes key interest areas, such as creating audit plans, audit program management, creating a new audit function, and working with senior management). Mentors also complete an application that lists their strengths, time availability, institution type and size, and information about past experience. The program is currently in need of additional mentors.

“Give it a Shot.”

New mentor Matt Walsh, Audit Director at Texas Tech, wasn’t sure what to expect from the program. He volunteered because he wanted to give back to his profession and get more involved with ACUA. He met his mentee, who was new to internal audit, on a Zoom call. Walsh asked what she wanted to get out of the program, which was to learn more about career progression and the path he had taken. With 10 years of audit experience, mentoring turned out to be second nature for Walsh.

They established monthly meetings to talk about career paths and her projects at a high level, staying away from specific advice and project details that could affect confidentiality. While a mentor can share ideas on projects, it is encouraged to guide mentees to their supervisors for specific implementation advice.

It is also important to steer a mentee away from complaining about their job and keep the conversation positive. A good mentor can turn the conversation around and ask what the mentee can do to improve the situation. Walsh never experienced complaining and said they had productive conversations with each meeting.

Walsh’s mentee left internal audit during the program, but he is eager to work with a new mentee in the next year. “Mentors don’t have to have experience mentoring,” Walsh said, “they just need job experience. Find out what the mentee needs and go from there.” For those considering becoming a mentor, Walsh says, “Give it a shot. It’s a great way to give back to the profession without a huge time commitment, and a good way to network.”

From Mentee to Mentor

Andre’ McMillan, Associate Director at the University of Delaware, first learned about the mentorship program through the ACUA president who paired him up with a former ACUA member from the University of Alaska. A staff member at the time, McMillan wanted input on career coaching and to better understand the industry. His mentor shared her higher education experiences with him and gave him a better understanding of what his boss was looking for in a rising leader.

The next year McMillan re-applied for the program with a different goal in mind. He had just been promoted to Associate Director and wanted to learn more about effective leadership. With his mentor’s guidance, he learned positive ways to coach his staff members, how to train and develop new staff, and learned tips on assigning work and handling promotions and disciplinary situations. Together they set goals which McMillan shared with his director.

For McMillan, the results were immediate. His mentors asked him about his goals and what he wanted to get out of the program, then established a regular meeting schedule to make mentoring a priority. He was also encouraged to reach out to his mentor on an ad hoc basis when needed. He felt comfortable with the one-on-one interaction, noting it was helpful to get an outside opinion on topics that could not easily be discussed with a direct supervisor.

This year McMillan decided to take the next step and become a mentor himself, paired with new internal auditor Brandi Fleck from the University of Oregon. He took his own mentor’s advice and listened to her needs and set up monthly Zoom meetings for their discussions.

Personalized Support

Fleck was encouraged to apply for an ACUA mentor. While Fleck had worked in research compliance for 4 years, she was new in the internal audit department shop of four employees. She was most interested in learning different methods of auditing, getting a variety of perspectives, discovering career paths, and learning ways to get involved with ACUA. Fleck met her mentor McMillan for the first time at the 2022 Audit Con in Las Vegas.

She first wanted to discuss her current audit work with her mentor. While maintaining confidentiality, she would ask McMillan questions about performing everyday work such as developing a work plan and documenting workpapers. McMillan would ask open ended questions like what is the objective, what is the control, and how can you test the control. She asked for McMillan’s opinion on how to sample non-salary payments between different departments, and McMillan shared some ideas with her. Having a mentor is not a substitute for your own supervisor, but Fleck said it helped to gain a different perspective and bring back ideas to her own department.

McMillan also shared his experiences with professional development. Fleck learned tips on how to work with difficult clients and how to not take things personally after a difficult encounter. McMillan has encouraged her to take the CIA exam and Fleck has started studying for part one.

For those unsure about starting a mentor/mentee relationship, Fleck says to, “Go for it! It’s a great way to connect and develop relationships outside of your university and to get personalized help.”

Expand ACUA Involvement

Another benefit of the program is learning how to become more involved with ACUA. McMillan has been on the Marketing Task Force and the Communications Committee, and even participated on an external quality assessment review (QAR) through ACUA. Fleck has joined the Diversity and Inclusion Committee at ACUA.

All of our mentors and mentees expressed comfort in their relationships and agree there are great people at ACUA who are committed to helping each other and share a responsibility to the profession. While there is a one-year commitment for the mentee/mentor relationship, most pairs continue to keep in touch well after that period, and the benefits can last a lifetime.

The mentorship committee will begin advertising and seeking next year’s mentors and mentees early this summer. Be on the lookout for additional information in your email, Connect ACUA, and the ACUA website. You can also reach out directly to Patrick McKinney at 512-471-0663 or Patrick.mckinney@austin.utexas.edu with any questions you may have.

Reactions to the Proposed IIA Standards Changes

For the past two years the Internal Audit Standards Board (IASB) has been creating the first major update to the Institute of Internal Audit Standards in over 20 years. A draft of the new Standards was released to the public on March 1, 2023. The 90-day public comment phase will commence May 30, 2023. Details about the new Standards changes and a link to the comment survey are on the IIA’s International Professional Practices Framework (IPPF) Evolution website at: https://www.theiia.org/en/Standards/ippf-evolution/

The Current Standards

The existing IPPF consists of multiple documents and resources, often repetitive and difficult to locate. There is a standalone mission of internal audit, “To enhance and protect organizational value by providing risk‐based and objective assurance, advice, and insight.” Mandatory guidance is divided between Core PrinciplesDefinition of Internal AuditCode of Ethics, and the Standards. The current Standards are further divided between attribute and performance standards. Additional recommended guidance is provided by Implementation Guidance and Supplemental Guidance.

Image mapping current IPPF to new standards.
The existing pieces of the International Professional Practices Framework.

Proposed Changes to the Standards

One of the biggest objectives of the IASB was to consolidate the former fragmented guidance into a single, user-friendly format. The proposed IPPF contains the new Global Internal AuditStandards (“new Standards”) that combines the guidance and is the section that has been released for public comment. The IASB plans to add two additional elements which have not been released yet: Topical Standards, which add more requirements on specific audit topics, and additional guidance on performing engagements.

Image showing proposed IPPF.
The proposed IPPF, with Global Internal Audit Standards released for public comment.



The new Global Internal Audit Standards is a 108-page guide organized into five domains that more clearly indicate key roles and responsibilities. Each domain is broken down into different principles, each with its own requirements, considerations for implementation, and evidence of conformance. At first glance it appears the former guidance has merely been rearranged into a logical format, but the changes are in the details. There is a new purpose, new standards, additional mandatory requirements throughout, changes to quality assurance review (QAR) requirements, additional board oversite requirements, and an increased focus on stakeholders and the public interest. The new domains are as follows:

  • Domain I: Purpose of Internal Auditing – Contains elements of the current Definition and Mission of Internal Audit.
  • Domain II: Ethics and Professionalism – Incorporates and builds upon the current Code of Ethics.
  • Domain III: Governing the Internal Audit Function – Focuses on the relationship between the board and the chief audit executive.
  • Domain IV: Managing the Internal Audit Function – Focuses on the requirements for the chief audit executive to manage the internal audit function effectively
  • Domain V: Performing Internal Audit Services – Focuses on performing assurance and advisory engagements.

ACUA Survey Results

The ACUA Auditing and Accounting Principles sub-committee ecently asked members to complete a brief survey about the proposed changes to the IIA Standards. Surveys were completed by 58 members and gathered overall opinions along with open-ended questions about members’ top pros and cons of the changes.

Overall, 74% of respondents generally supported the proposed new Standards. Members appreciated the improved organization and structure of the domains and having one consolidated source of guidance. They cited the improved clarification of roles and responsibilities, especially regarding the chief audit executive (CAE) and audit committees. There was support over the additional standards and specific guidance within each standard. Some members favored additional emphasis on objectivity and professional skepticism, support for the public sector, and stronger requirements for continuing professional education and external assessors. Members also noted the de-emphasis on having separate Standards for assurance versus consulting engagements.

When asked about their top two concerns over the proposed new Standards, 40% of respondents cited the overly prescriptive requirements throughout the document. The number of “musts” and “shoulds” has members wondering if the internal auditing profession is becoming a big administrative checklist rather than one of critical thinking and professional judgment.

The top concerns over specific sections of the new Standards are as follows:

  • 59% of respondents took issue of the excessive Board requirements throughout Domain III: Governing the Internal Audit Function. Most question whether the IIA has the authority to mandate specific Board requirements as board members are usually not IIA members and the CAE does not have authority over the board’s actions.
  • 41% disagreed with Standard 8.4 External Quality Assurance, which modifies the requirements by mandating an external review be performed every 10 years, instead of a self-assessment with validation, and requires having a Certified Internal Auditor (CIA) on the review team. This is cost-prohibitive and excludes seasoned reviewers who are not CIAs.
  • 21% were concerned with Standard 15.1 Final Engagement Communication because it requires findings to be ranked by significance, as rankings are subjective and cause conflict.
  • 10% disagreed with elements of the new Domain I: Purpose of Internal Auditing. The purpose statement focuses on “enhancing the organization’s success” and “serving the public interest.” The prior mission statement focused on providing a risk-based independent and objective service. Members believe the emphasis on success and serving the public interest presents a conflict of interest and shift in priorities.
  • 10% felt that acknowledgement of bias in Standard 2.1 Individual Objectivity and the statement “Internal auditors must be aware of and manage potential biases” negatively conveys auditors are inherently biased instead of being fair and impartial.

Additional concerns noted as particularly burdensome for the small shops were identified in the following areas:

  • Standard 2.2 Safeguarding Objectivity – Small shops felt the requirement that internal auditors must not provide assurance over an activity where they provided advisory services within the last year is too restrictive and limiting.
  • Standard 10.2 Human Resource Management – “The CAE must establish a program to recruit, develop, and retain qualified internal auditors” may be overly-burdensome.
  • Standard 12.1 Internal Quality Assessment – The suggested alternative for small shops “to consider requesting assistance from others within the organization to conduct periodic assessments, such as former internal auditors or others with suitable knowledge of internal auditing” may not be practical.
  • Standard 12.2 Performance Measurement– A new standard aiming to build upon accountability of internal audit to both the board and senior management requires the CAE to develop and report on a performance measurement methodology creates more administrative work.

Next Steps

While ACUA members are generally in favor of the modifications to the Standards, there are many details that members feel the IIA should reevaluate. The Auditing and Accounting Principles sub-committee have presented the survey results to the ACUA Board in preparation for the ACUA formal response to the IIA. The committee also encourages individual members to complete their own response to the IIA if desired at: https://www.theiia.org/en/Standards/Standards-Public-Comment/

After reviewing the public comments and making any modifications, the IIA anticipates releasing the new Standards in late 2023. The new Standards become effective 12 months from the release date in late 2024.

Letter from the Editor

Hello ACUA Members!

As the flowers bloom and the Class of 2023 graduates, one can’t help but feel the positive change that is occurring all around us, including changes within the Journal and our profession.

I want to thank former Journal editor Gavin Shubert on his work with the ACUA Journal and wish him the best as he leaves higher education to pursue a career in consulting. As the former Deputy Editor, I have graduated to the role as your new Editor, and I’m looking forward to finding a new Deputy Editor and more article contributors. Feel free to reach out to me with questions, comments, or ideas for future articles at editor@ACUA.org

The Journal is making a positive change to share more information about ACUA committees and members to keep you informed and encourage participation. This issue we highlight the ACUA mentorship program, whose FY23 mentees are about to graduate from the program. We also feature member poll results on hot audit topics, remote working, data analytics software, and more in the Tools and Resources section.

Last March in Denver many members graduated from the new auditor track at Audit Interactive, and seasoned auditors expanded their knowledge. Perhaps there are some new mentors and mentees in that group.

Even the IIA Standards are graduating to the new Global Internal Audit Standards. A big thanks to the Auditing and Accounting Principles sub-committee for gathering member concerns for a formal ACUA response. Learn more about the proposed changes in this issue and submit your concerns to the IIA before May 30th. I completed their quick online form already.

As this fiscal year comes to an end, I wish you a happy graduation and a positive start to FY24.

Sincerely,
Kara Hefner

ACUA Poll: Remote Work, Data Analytics and AuditCon

Last month the ACUA Journal launched a poll on ACUA Connect to get input from members on a variety of topics so that trends could be shared with the membership. This article summarizes remote work, data analytics, and AuditCon interest. Information on hot audit topics is shared in a separate article in this issue. There were 64 responses from small, medium, and large shops.

Chart of survey respondents' audit shop size

Remote Work

Since the pandemic, only 27% of respondents are working in the office every day. The number of hybrid workers make up the majority at 51%, while 22% primarily work from home full time.

Pie chart showing primary working arrangements of survey respondents.

For those on a hybrid schedule, 60% come to the office on a set pattern each week. The remainder can be flexible on which days they come in the office, with 22% stating they need to come in for a set number of days.

Pie chart showing hybrid schedules of survey respondents.

Data Analytics Software

Auditors are encouraged to incorporate data analytics into their engagements to identify patterns, detect outliers, test entire populations, identify duplicates, and understand the data better. There were 27 respondents who said they used data analytics software outside of Excel, some using multiple products. The most popular software was nearly evenly distributed between ACL, IDEA, PowerBI, Tableau, and IBM Cognos. Some schools were using TeamMate Analytics, and others used Alteryx and ActiveData plugins.

Pie chart showing data analytics software used by survey respondents.

AuditCon Attendance

This year’s AuditCon will be held in sunny Miami from September 24-28. The ACUA Journal asked the 64 respondents whether they plan to attend. While most were unsure at this time, 15 said yes to in person and 3 plan to attend virtually. We hope to see you there.

Chart showing responses about attending AuditCon in Fall 2023.

Letter from the President

Dear ACUA Colleagues,

I hope everyone is enjoying the beginning of Summer!

It was my pleasure to update the membership at the Annual Business Meeting that occurred on May 23, 2023.  If you were not able to join us, the presentation will be posted to ConnectACUA.  I especially want to take a moment thank our Treasurer, Chris Walker, for his and the Finance and Investment Committee’s work over the past year.

For 2024, the Board engaged a Task Force led by Toni Stephens, to assist in identifying the best path for delivering exceptionally relevant content to our members considering the increased costs of hotels, food and beverage, and hybrid streaming technology post COVID.  After thorough review and discussion of the task force recommendations as well as our financial projections, we are very excited to announce some changes to ACUA’s 2024 conference plans as follows: 

  • 2024 Audit Interactive will occur Virtually  
  • 2024 AuditCon will occur In-Person

After sending out requests for proposals to 9 different cities all over the United States, the Executive Committee reviewed the most economically feasible options for both the Members and the Organization.  I’m excited to share that we are working through final negotiations with a hotel in Atlanta, Georgia for AuditCon 2024.

I look forward to seeing you all in Miami, Florida for AuditCon 2023 September 24-28, 2023 at the Loews Miami Beach Hotel.     

Sincerely,
Melissa Hall, Georgia Institute of Technology
ACUA President

Letter from the Editor

Hello ACUA members,

Please give a warm round of applause for ACUAs new president, Melissa Hall, who made her first appearance in the Journal in the Letter from the President. Melissa took over as President from Brian Daniels, who did a great job leading ACUA through the pandemic and out the other side.

This season’s Journal issue features several fantastic pieces from a broad range of writers. Jaime Fernandez wrote a terrific article about continuous auditing and how your shop can beneficially implement this process. In addition, Han Yan, Ph.D., examines how internal auditing changed because of COVID and what the future of internal audit looks like beyond COVID. Then, David Clark gives an overview of diversity, equity, and inclusion in higher education and what to consider as your institutions formalize their plans to become more inclusive. Next up, Tharanee Ravindran highlights how a Control Self-Assessment can add value to future engagements by addressing risks at your institution. After that, Rose Kelly, Lisa Palazzo, Tina Griffiths, and Elizabeth Walton wrote about a three-pronged approach to risk, compliance, and controls at Case Western Reserve University, co-sourced with Deloitte. Finally, Jennifer Saak, Ph.D., Sheila Cranman, Ph.D., and Scot Allen, Ph.D., analyze how your institution can audit export controls, a hot topic at research-oriented universities.

In this issue of the College and University Auditor, you will find a wide variety of topics written by talented authors who strove to make their knowledge and expertise relatable and valuable for professionals in every institution. Please consider joining a growing field of professionals making their mark on the collective learning of our ACUA community by reaching out to me at editor@ACUA.org. Questions, ideas, and comments are always welcome.

Sincerely,

Gavin Shubert, Editor

Letter from the President

Dear ACUA Colleagues,

I hope everyone is enjoying the beginning of the Holiday season and is now on the countdown to Winter Break.

It was so great to see over 300 of you that were able to attend in person for AuditCon 2022 in Las Vegas. We also were glad to be able to provide content to the additional participants that were not able to attend in person.  We had such a robust schedule of timely and relevant information. This is directly attributable to our fabulous volunteers, staff, and strategic partners, who work diligently to ensure that our continuing education content is relevant and addresses the emerging risks affecting our industry and profession. THANK YOU ALL!  

As we look to the future of ACUA in 2023, I’m excited by all the possibilities as we embrace how the world has changed. Together we will all work to define the “new normal” for ACUA and our campuses. I hope that you will make plans to join us in Denver, Colorado, for Audit Interactive March 26-29, 2023, at the Grand Hyatt Denver.  

Lastly, a special thanks to our Immediate Past President, Brian Daniels of The University of Tennessee, for setting me up for success. He graciously led us out of the pandemic and back to in-person conferences. His leadership style will be hard to duplicate, but I look forward to stepping into his shoes and leading ACUA into the future.  

Sincerely,

Melissa Hall, Georgia Institute of Technology
ACUA President

Adding Value Through Control Self-Assessments

The ever-changing business environment requires institutions to embrace dynamic practices to manage risks appropriately and achieve organizational goals. Hence, audit departments worldwide strive to ensure their key activities align with the needs of the organizations. Control Self-Assessment (CSA) is an important tool that auditors can use to enhance the role of the internal audit function by adding value to the institution. By partnering with Internal Audit, institutions can take a structured approach to identify the risks associated with processes or activities, assess the related controls to ensure risks are managed effectively, and ensure organizational goals are achieved.

Management and Process Owners Buy-In

The success of the CSA program depends on buy-in at all levels of the organization: from management to department heads to process owners. This involves discussions on how the process works, the benefits of the program, and the resources required to execute the project successfully.

Project Selection Process

Similar to audit projects, the CSA engagements should add value to the institution by addressing the risks to the entity. By incorporating the CSA project selection process as part of the annual risk assessment, the internal audit department can ensure high risk areas are identified for potential projects. Based on residual risk, areas that are high-risk would be first considered for an audit. Any high-risk areas not selected for audits are viable candidates for a CSA project. Once identified, internal audit departments can recruit the departments to participate in the CSA program. During the infancy stage of the program, the audit departments may need to actively recruit volunteers to participate. As the program matures and the institution begins to reap the benefits of the program, internal audit departments will have departments actively volunteering to participate in the program.

CSA Process

The most important step in the process is selecting the CSA team that will oversee the project. It is vital that much consideration is given in selecting the team members. The CSA team mainly comprises of individuals who are involved in the process being assessed. These individuals will play a major role in ensuring the risks pertinent to the process/activity are identified and addressed appropriately.
The internal auditor facilitates the CSA process by performing the following steps.

    1. Conduct an Initial Meeting

    • Similar to the entrance meeting during an audit, the initial meeting is held to finalize the following details:
      • CSA team members,
      • Objectives and scope of the project
      • Timeline for completing the engagement

    2. Execute the Engagement Letter

    • The Institute of Internal Auditor’s International Standards for the Professional Practice of Internal Auditing (Standards) states “Internal auditors must establish an understanding with consulting engagement clients about objectives, scope, respective responsibilities, and other client expectations. For significant engagements, this understanding must be documented”. To comply with the letter and spirit of the Standards, a formal engagement letter should be prepared to document the objective, scope, process, and roles and responsibilities.

    3. Perform the CSA

    • Each step listed below is crucial for the program’s success.
    StepDetails of the process
    Identify risksThe CSA team identifies and documents the risks pertinent to the process. This is the most important step in the process since the rest of the procedures stems from this.
    Identify corresponding control(s) and evaluate the design effectiveness of the control(s)Identify and document the corresponding controls for the risks identified in the procedure above. The design effectiveness of the controls is evaluated during this phase to determine whether adequate controls exist to address the risks. If the CSA team concludes that either control does not exist or is inadequate, an opportunity for improvement will be developed.
    Evaluate the operating effectiveness of controlsFor the controls that are designed effectively, one or more of the following techniques can be utilized to evaluate the operating effectiveness of the controls: Team Meeting, Survey, and Facilitated Workshop.
    Validate ResultsThe assessments results must be validated by someone independent to ensure the results support the conclusion(s).
    Identify opportunities for improvementOpportunities for improvement are developed based on the conclusions from the Team Meeting, Survey, and Facilitated Workshop.
    Develop Management Action PlanManagement develops an action plan that enhances controls, guided by auditors.

    4. Share the results

      • The report is issued by the process owner and addressed to Management. It includes the following: Objective, Scope, Methodology, Analysis of Results, Conclusion, and Management Action Plan.

      5. Post Engagement Survey

      • Consider sending a Post Engagement Survey to the CSA client to solicit feedback on the engagement; it will help improve the process.

      6. Follow Up

      • Follow up on the planned action to ensure gaps in controls are remediated.

      Conclusion

      CSA promotes departments taking a structured approach in assessing risks and controls, through which it promotes accountability of controls. In addition, it helps the process owners and operational staff get a better understanding of the operations and helps them understand the importance of their respective roles and responsibilities in addressing the risks to the institution and achieving the organizational goals. By facilitating CSA projects, the audit department builds a trusting relationship with departments on campus. In addition, the audit team gets access to information, including risk management practices and control environment, that is vital in the annual risk assessment process. Internal audit departments can successfully facilitate CSA engagements using fewer resources than required for an audit while providing great benefits to the business units.