The AICPA’s Governmental Audit Quality Center (GAQC) has submitted a comment letter on final proposed revisions to the Data Collection Form (the Form) and its instructions. The Form summarizes the results of each single audit engagement and is completed by both auditors and auditees and submitted to the Federal Audit Clearinghouse (FAC).
In its December 6 letter to the Department of Commerce, the GAQC expresses continued support of the FAC’s efforts to update the Form and to improve its usefulness to federal agency users. However, the letter also includes several overarching concerns and detailed comments.
Among the most significant comments, the letter suggests the FAC postpone a proposed change for the auditee to input the date the full, complete audit report was received until more research can be done and related guidance developed. This date is critical to determining low-risk auditee status in future years and without additional guidance there may be diversity in how auditees complete the field.
Additionally, the letter expresses concern about the proposed requirements for auditors and auditees to cut and paste text from audit findings, footnotes and the auditee’s Corrective Action Plan into the Form because of the manual nature of the process and the high potential for error. The GAQC states that, while this may be an acceptable approach in the short-term, the FAC and the Office of Management and Budget need to consider whether there are more efficient and effective ways to achieve the end goal, including through the use of newer technologies or automated techniques.