Updated July 31, 2015
There continues to be many requests by federal agencies to require grantees to have their auditor sign a certification statement. Sometimes, the statements are associated with pre-award activities, and the auditor is asked to sign a statement saying that the entity has appropriate controls or financial systems to administer federal programs. Others relate to existing grantees that are asked to have their auditor sign similar statements. There have also been requests made of auditors to provide feedback about the status of significant deficiencies and material weaknesses noted in an audit. In most circumstances, statements such as these are not appropriate for the auditor to sign unless the auditor has been engaged to perform an engagement under professional standards.
If you, as an auditor, are asked to sign such a statement or certification, you should not do so unless you have performed an appropriate engagement. If you are the ongoing auditor to a federal recipient and have not been engaged to perform an engagement under professional standards, one option would be to suggest that your client submit its financial statement and related audit report and, if applicable, its schedule of expenditures of federal awards and related single audit reports in lieu of signing the statement or certification. Another option would be to reach out to the federal agency single audit coordinator to make them aware of the problematic request. Finally, you might also make the AICPA's Governmental Audit Quality Center know about the request by sending an e-mail to firstname.lastname@example.org so that they can follow-up with the federal agency, as well. The AICPA has issued guidance specifically applying to pre-award survey requests in Interpretation No. 7, “Reporting on the Design of Internal Control,” of AT section 101 (AICPA, Professional Standards), which provides useful guidance for such situations.