September 27, 2021

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July 29, 2021, letter commenting on AICPA’s February 2021 Exposure Draft, “Proposed Statements on Quality Management Standards – Quality Management”

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<div>This letter provides GAO's response to the American Institute of Certified Public Accountants (AICPA) Auditing Standards Board's (ASB) Proposed Statement on Quality Management Standards – Quality Management: A Firm's System of Quality Management (SQMS No. 1); Proposed Statement on Quality Management Standards – Engagement Quality Reviews (SQMS No. 2); and Proposed Statement on Auditing Standards, Quality Management for an Engagement Conducted in Accordance with Generally Accepted Auditing Standards (QM SAS). GAO provides standards for performing high-quality audits of government organizations, programs, activities, and functions and of government assistance to contractors, nonprofit organizations, and other nongovernment organizations with competence, integrity, objectivity, and independence. These standards, often referred to as generally accepted government auditing standards (GAGAS), are to be followed when required by law, regulation, agreement, contract, or policy. For financial audits, GAGAS incorporates by reference the AICPA's Statements on Auditing Standards (SAS). For attestation engagements, GAGAS incorporates by reference the AICPA's Statements on Standards for Attestation Engagements.</div>

This letter provides GAO’s response to the American Institute of Certified Public Accountants (AICPA) Auditing Standards Board’s (ASB)

  • Proposed Statement on Quality Management Standards – Quality Management: A Firm’s System of Quality Management (SQMS No. 1);
  • Proposed Statement on Quality Management Standards – Engagement Quality Reviews (SQMS No. 2); and
  • Proposed Statement on Auditing Standards, Quality Management for an Engagement Conducted in Accordance with Generally Accepted Auditing Standards (QM SAS).

GAO provides standards for performing high-quality audits of government organizations, programs, activities, and functions and of government assistance to contractors, nonprofit organizations, and other nongovernment organizations with competence, integrity, objectivity, and independence. These standards, often referred to as generally accepted government auditing standards (GAGAS), are to be followed when required by law, regulation, agreement, contract, or policy. For financial audits, GAGAS incorporates by reference the AICPA’s Statements on Auditing Standards (SAS). For attestation engagements, GAGAS incorporates by reference the AICPA’s Statements on Standards for Attestation Engagements.

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Based on GAO’s review, Education has updated the information and CDC has begun to do so. GAO recommends that CDC ensure that, as it makes updates to its guidance related to schools’ operating status, the guidance is cogent, clear, and internally consistent. HHS agreed with the recommendation. Tracking Contract Obligations Federal agencies are tracking contract actions and associated obligations in response to COVID-19 using a National Interest Action (NIA) code in the Federal Procurement Data System-Next Generation. The COVID-19 NIA code was established in March 2020 and was recently extended until March 31, 2021, while a draft of this report recommending that DHS and DOD extend the code beyond September 30, 2020, was with the agencies for comment. GAO has identified inconsistencies in establishing and closing these codes following previous emergencies, and has continued concerns with the criteria that DHS and DOD rely on to determine whether to extend or close a code and whether the code meets long-term needs. GAO recommends that DHS and DOD make updates to the 2019 NIA Code Memorandum of Agreement so as to enhance visibility for federal agencies, the public, and Congress on contract actions and associated obligations related to disaster events, and to ensure the criteria for extending or closing the NIA code reflect government-wide needs for tracking contract actions in longer-term emergencies, such as a pandemic. DHS and DOD did not agree, but GAO maintains implementation of its recommendation is essential. 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This third report examines key actions the federal government has taken to address the COVID-19 pandemic and evolving lessons learned relevant to the nation’s response to pandemics. GAO reviewed data, documents, and guidance from federal agencies about their activities and interviewed federal and state officials, as well as industry representatives. GAO is making 16 new recommendations for agencies that are detailed in this Highlights and in the report. For more information, contact A. Nicole Clowers at (202) 512-7114 or clowersa@gao.gov.
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