The American Institute of CPAs’ (AICPA) Governmental Audit Quality Center (GAQC) provided feedback to the Government Accountability Office (GAO) on the 2013 Exposure Draft (ED) of Standards for Internal Control in the Federal Government (Green Book) in a February 14, 2014 comment letter.
The Green Book establishes internal control standards for federal agencies and may be used by non-federal entities (e.g., states, local governments, and non‐profit organizations) that expend federal funds.
The purpose of the proposed changes to the Green Book is to reflect major changes in the accountability and financial management profession and to emphasize specific considerations applicable to the government environment, including the adaption of the Committee of Sponsoring Organizations of the Treadway Commission’s Internal Control—Integrated Framework (COSO).
The AICPA expressed overall support of GAO’s efforts to update the Green Book. However, the AICPA also urged the GAO to consider several concerns, observations and recommendations that are outlined in the AICPA letter.
The main AICPA recommendation was that GAO more closely align the Green Book language to COSO unless there is truly a specific difference in the government environment. This is particularly important since the recent grant reform regulation issued by the U.S. Office of Management and Budget (OMB) titled, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, may expand the use of the Green Book by some non‐federal entities.