LEARNING OBJECTIVES
Understand the importance of proper positioning of the internal audit function within the
organization.
Identify the benefits of various organizational structures for an internal audit function.
Identify the roles and responsibilities of the key positions in an internal audit function.
Understand the policies and procedures of internal auditing and how they guide the internal
audit function.
Understand the attributes of a well-executed risk management model (process) and reflect
on what role the internal audit function should have in the organization's risk management
processes.
Understand quality assurance, how it operates, and why it is important to the internal audit
function.
Understand how technology is used in the management of the internal audit function.
By now, you should recognize the depth and complexity of an internal audit function and be aware
of the critical role it can play in the success of the entire organization through the assurance
services it performs in support of the organization's governance structure. In this chapter, we
discuss what is involved in managing the internal audit function. When applicable, the spectrum
of methods employed by different internal audit functions is presented and the benefits of each are
discussed. We begin with a discussion of the various options regarding organizational
structures for an internal audit function, including where it is positioned within an organization.
Then, we identify the key positions within the internal audit function, including the chief audit
executive (CAE), and outline the roles and responsibilities for each. From there, we move on to
the policies and procedures with an overview of how they provide necessary guidance and structure
to the internal audit function. Next, we examine various risk management models and look at what
role the internal audit function can and should play in the organization's risk management and
governance processes. After that, we explain quality assurance and its importance in the internal
audit function. Finally, we end the chapter by touching on various technological tools available to
an internal audit function and how they are used in managing the function.
In addition to establishing a charter, mission and/or vision, and internal audit plan, the CAE is
responsible for establishing and maintaining independence, objectivity, proficiency, and due
professional care within the internal audit function. As stated earlier, the positioning of the internal
audit function affects the degree to which it can remain objective. Being positioned on a level with
senior management with direct access to the audit committee gives the internal audit function
greater independence and, consequently, greater objectivity. Audit committee participation in the
selection, evaluation, and dismissal of the CAE further enhances the CAE's ability to maintain
organizational independence and minimizes the possibility of senior management exerting undue
influence that would impact his or her ability to act without bias (individual objectivity). Ideally,
the function will be positioned high enough within the organization with direct access to the audit
committee to allow conformity with The IIA's requirements and recommendations as detailed
below.
IIA Standard 1120: Individual Objectivity states, "Internal auditors must have an impartial,
unbiased attitude and avoid any conflict of interest." The Implementation Guide for this standard
further outlines these requirements: "Conflict of interest is a situation in which an internal auditor,
who is in a position of trust, has a competing professional or personal interest. Such competing
interests can make it difficult to fulfill his or her duties impartially. A conflict of interest exists
even if no unethical or improper act results. A conflict of interest can create an appearance of
impropriety that can undermine confidence in the internal auditor, the internal audit activity, and
the profession. A conflict of interest could impair an individual's ability to perform his or her duties
and responsibilities objectively."
As discussed in IIA Standard 1130: Impairment to Independence or Objectivity:
If independence or objectivity is impaired in fact or appearance, the details of the impairment must
be disclosed to appropriate parties. The nature of the disclosure will depend upon the impairment.
Interpretation:
Impairment to organizational independence and individual objectivity may include, but is not
limited to, personal conflict of interest, scope limitations, restrictions on access to records,
personnel, and properties, and resource limitations, such as funding.
The determination of appropriate parties to which the details of an impairment to independence or
objectivity must be disclosed is dependent upon the expectations of the internal audit activity's and
the chief audit executive's responsibilities to senior management and the board as described in the
internal audit charter, as well as the nature of the impairment.
Should an impairment to independence or objectivity be identified, the internal auditor must report
the impairment or perceived impairment to the CAE who must decide if the internal auditor needs
to be reassigned. When the impairment results from a scope limitation, the CAE must report such
limitation to the audit committee.
The CAE's communication to the audit committee should be in writing and include the potential
effect of the scope limitation. Additionally, to prevent the possibility of an impairment (actual or
perceived) internal auditors cannot accept fees, gifts, or entertainment from an employee, client,
customer, supplier, or business associate. Additional IIA requirements regarding impairments to
independence or objectivity can be found in exhibit 9-3.
EXHIBIT 9-3
IIA REQUIREMENTS REGARDING INPAIRNENTS
TO INDEPENDENCE AND OBJECTIVITY
Standard 1130.A1
Internal auditors must refrain from assessing specific operations for which they were previously
responsible. Objectivity is presumed to be impaired if an auditor provides assurance services for
an activity for which the auditor had responsibility within the previous year.
Standard 1130.A2
Assurance engagements for functions over which the chief audit executive has responsibility must
be overseen by a party outside the internal audit activity.
Standard 1130.A3
The internal audit activity may provide assurance services where they had previously performed
consulting services, provided the nature of the consulting did not impair objectivity and provided
individual objectivity is managed when assigning resources to
the engagement.
Standard 1130.C1
Internal auditors may provide consulting services relating to operations for which they
had previous responsibilities.
Standard 1130.C2
If internal auditors have potential impairments to independence or objectivity relating to proposed
consulting services, disclosure must be made to the engagement client prior to accepting the
engagement
Often, the internal audit function will coordinate efforts with other departments in the organization
that have similar risk mitigation objectives and responsibilities, such as compliance and risk
management. As long as the internal audit function is not asked to perform operating activities or
design processes and procedures they will later need to evaluate as part of their duties as an internal
audit function, there is no impairment to independence or objectivity. This type
of coordination can add significant value to the organization and promote efficient resource
utilization in the organization's risk mitigation efforts. Similarly, the internal audit function may
identify opportunities for coordinating assurance efforts between the different areas of the
organization without impairing independence or objectivity. Coordination of assurance efforts is
discussed in greater detail later in this chapter.
PLANNING
As previously mentioned, the CAE is responsible for creating an operating budget and allocating
resources in a manner designed to accomplish the annual internal audit plan. The annual plan is
developed by the internal audit function through a process that identifies and prioritizes possible
audit entities (business units or processes, referred to as the "audit universe") responsible for
mitigating key strategic, operations, reporting, and compliance risks to levels acceptable to the
organization's board of directors and senior management. Key risks are those confronting the
organization that must be controlled and monitored for an organization to successfully accomplish
its defined business objectives. These risks, as identified by senior management, should be
independently corroborated by the internal audit function. After the key risks have been identified
and agreed upon, the CAE determines which specific business units and processes are responsible
for mitigating these risks. The resulting information is then subject to a process
that prioritizes and ranks the risks and associated business units or processes. The CAE considers
all of this information and determines the human and financial resources necessary to provide
appropriate audit coverage of the prioritized audit universe. The result is a comprehensive internal
audit plan that includes both the assurance services and consulting services necessary to assess
how effectively the organization is managing the risks that threaten its business objectives and to
identify risk management improvement opportunities. The audit plan can then be implemented by
assigning specific personnel to individual engagements in the plan over the following fiscal year.
Internal audit functions will implement and assign resources to execute the internal audit plan
throughout the fiscal year, and many will update and recast the internal audit plan more frequently
than annually (for example, quarterly or monthly).
There are multiple theories for the structuring of an internal audit plan. Many internal audit
functions have moved toward a comprehensive process whereby senior management and the
internal audit function collaborate to complete a formal risk assessment on an organizationwide
basis to establish a prioritized list of key risk scenarios facing the organization that must be
appropriately managed by the organization to achieve key business objectives. It is much more
common, however, for the process to be informal and much less collaborative in nature. Whatever
process is used, maximum effectiveness is achieved when the risk assessment process is completed
at least annually at the beginning of, or prior to, an organization's fiscal year with quarterly updates.
This allows the CAE to align audit resources for the upcoming year and, if necessary, make
quarterly adjustment to stay in alignment with the conclusions drawn by management during their
risk assessment process. Providing the CAE with a definitive list of audit entities related to the
prioritized risks allows for the creation of an internal audit plan using a top-down, risk-based
approach.
However, many organizations and their internal audit functions still do not use this approach.
Instead, they continue to create internal audit plans that cyclically audit each and every area of the
organization with highly prioritized business units or processes cycled in for audit coverage more
frequently and lower prioritized business units or processes cycled in less frequently.
The IIA addresses the differences between assurance services and consulting services
relative to IIA Standard 2010: Planning with Standards 2010.Al and 2010.Cl:
Assurance Services. The internal audit activity's plan of engagements must be based on a
documented risk assessment, undertaken at least annually. The input of senior management and
the board must be considered in this process.(Standard 2010.Al)
Consulting Services. The chief audit executive should consider accepting proposed
consulting engagements based on the engagement's potential to improve management of risks, add
value, and improve the organization's operations.
Accepted engagements must be included in the plan. (Standard 2010.Cl)
The planning process should include the establishment of goals, engagement schedules, staffing
schedules, and financial budgets. Additionally, effective planning should reflect the internal audit
charter and be consistent with organizational objectives. The planning process should be a
collaborative process involving all levels of management to ensure the audit plan is understood
and supported by management.
In addition to the traditional positions described above, many internal audit functions are also
creating specialist positions designed to bring a unique or niche set of skills, experiences, and
knowledge to bear, such as engineers, actuaries, writers, data analysts, etc. These positions will
vary widely depending on the philosophy, structure, and mandate of the internal audit function, as
well as the organization's industry, regulatory environment, and governance structure. Depending
on the complexity of the subject matter expertise required, experience desired, and the particular
needs of the internal audit function, specialist positions can range from staff to director level.
The IIA's Global Internal Audit Competency Framework, originally published by The IIA in 2013
and updated in 2014, is a tool that defines the competencies needed to meet the requirements of
the International Professional Practices Framework (IPPF) for success within the internal audit
profession. As defined by the Framework, a competency is the ability of an individual to perform
a job or task properly, which includes a defined set of knowledge, skills, and behaviors. The
Framework provides a structured guide that assists in the identification, evaluation, and
development of those competencies in an individual internal auditor. The Framework outlines 10
core competencies to be demonstrated by each role included in the Framework, including: Internal
Audit Staff, Internal Audit Senior/Supervisor, Internal Audit Manager, Director, and Head of
Internal Audit/CAE. The Framework is introduced in chapter 1, discussed further in chapter 2,
"The International Professional Practices Framework: Authoritative Guidance for the Internal
Audit Profession," and can be found under "Professional Guidance" on The IIA's website.
Right Sizing
Right sizing is an important concept in the staffing and scheduling of an internal audit function. It
is important to achieve and maintain a balance of knowledgeable and skilled staff to complete the
internal audit plan, without putting undue stress on the staff by creating oppressive workloads,
while simultaneously maintaining a reasonable financial budget. This is true whether the internal
audit structure is flat or hierarchically organized and is often a factor when determining what type
of structure is appropriate for an organization. The CAE relies on various sources to help validate
right-sizing decisions, including networking, benchmarking, market studies, and other consultative
venues.
The CAE also must assign independent and objective human resources effectively, meaning that
internal auditors are assigned to engagements for which they are qualified and capable of
performing. In some instances, individuals with specialized knowledge and/or skills from
elsewhere in the organization (or from sources outside the organization) may assist with an internal
audit engagement when the necessary competencies are not present within the internal audit
function. From a broader perspective, the CAE takes succession planning into consideration and
ensures that there is a robust staff evaluation and development program in place. As with other
areas of managing the internal audit function, the CAE must maintain open communication with
senior management and the board regarding human resources. Typically, this communication takes
the form of regular updates during quarterly board meetings, such as audit committee meetings.
These updates can include a summary of status and adequacy of resources along with metrics,
goals, and objectives to monitor the overall adequacy of resources including comparisons of
resources to the internal audit plan, the impact of temporary shortages or vacancies, educational
and training activities, and changes to specific skill needs based on changes in the organization's
business, operations, programs, systems, and controls.
Hiring Practices
The CAE is responsible for hiring associates to fill the organizational structure of the internal audit
function in a way that maximizes efficiency, effectively provides the necessary skill base, and
makes good use of the financial budget. To do this, the CAE typically tries to hire individuals with
training and expertise in a variety of areas, including financial accounting and reporting, IT,
business operations, applicable laws and regulations, and the organization's industry.
Strategic Sourcing
Strategic sourcing, also referred to as co-sourcing or outsourcing, allows the CAE to optimize both
the skill base and the financial considerations related to staffing. The CAE, with the use of strategic
sourcing, is able to maintain a cost effective internal audit function by hiring permanent associates
who have a broad, more generalized base of skills while maintaining the flexibility of bringing in
technical experts that are necessary for specific projects or engagements but who would be
cost prohibitive to keep permanently on staff. Strategic sourcing also is used in scheduling when
the projected hours necessary to accomplish the internal audit plan exceed the number of hours
available from the permanent staff, but when hiring another staff member would be inefficient,
cost prohibitive, or impractical under existing market conditions.
Scheduling
Once the right mix of permanent associates and strategic sourcing is in place and appropriately
organized within the internal audit function, the CAE can begin assigning specific engagements
and projects to the personnel best suited to perform them. This is where the benefits of good hiring
practices and right sizing become apparent. The CAE maximizes the financial budget by creating
internal audit teams that, based on their skills and experience, will most effectively and efficiently
accomplish the objectives of a specific engagement. At the same time, the CAE takes into
consideration the development needs of the staff and works to balance the developmental
opportunities a specific engagement can provide to them and the need to complete engagements
within the scheduled time frame.
Financial Budget
As mentioned previously in this chapter, the financial budget is driven primarily by the internal
audit plan, organizational structure, and staffing strategy. The CAR must carefully evaluate the
financial resources necessary to accomplish the objectives set forth. It should be apparent at this
point that the financial budget both impacts and is impacted by each of the tasks undertaken by the
CAE as described above.
EXHIBIT 9-4
THREE LINES OF DEFENSE MODEL
COORDINATING ASSURANCE EFFORTS
According to IIA Standard 2050: Coordination and Reliance, "The chief audit executive should
share information and coordinate activities with other internal and external assurance and
consulting service providers to ensure proper coverage and minimize duplication of efforts."
Coordinating the efforts of the internal audit function with those of other internal and external
providers of assurance and consulting services is important because of the increase in effectiveness
and efficiencies that can be gained. Many organizations have multiple avenues for ensuring that
they operate within their risk appetite. Organizations operating in a highly regulated environment
in particular have a need to demonstrate that they have mitigated the many risks that threaten them
to a reasonable level. To do so, they implement a technique of assurance layering to get the risk
mitigation they need or desire. One common example of this strategy is the Three Lines of Defense
model, which was first discussed in chapter 3, "Governance."
In the Three Lines of Defense model, the organization layers the avenues through which they get
assurance that the risks facing them are mitigated to a level within their risk appetite. Although it
is referred to as three lines of defense, depending on the organization and how it is structured, there
may be more than three defined lines (layers) of assurance.
Exhibit 9-4 is a popular depiction of the Three Lines of Defense model that places the external,
independent assurance providers outside the model. As indicated, this model can be adapted by
organizations to depict their particular approach or philosophy.
The different lines of defense illustrated in the exhibit are outlined below:
First line of defense. Management owns and takes responsibility for assessing and mitigating risk
and for maintaining effective internal controls. This internal line of defense is non-independent of
management.
Second line of defense. Different areas within the organization work together
to assist in risk mitigation by facilitating and monitoring the risk management efforts of the
organization. These areas are also involved in the communication of applicable risk-related
information. This internal line of defense also is non-independent of management. The internal
audit function coordinates with these areas by partnering on risk assessments, soliciting and
providing feedback on changing areas of the organization, etc. These coordination efforts do not
compromise the independence or objectivity of the internal audit function
Third line of defense. The internal audit function is the third internal line of defense. The key
difference between this line of defense and the first two is that it is independent of management.
Coordination between these three lines of defense can vary greatly depending on the organization.
In smaller, less regulated organizations, coordination efforts can be less formal Lo gain the desired
efficiencies. In larger, more heavily regulated organizations, coordination can be quite formal and
involved. These organizations typically have to begin by creating an assurance map that identifies
where within the organization risk mitigation coverage exists, who is providing the coverage, what
professional standards the different assurance providers adhere to, and the frequency and Liming
of the assurance activities provided. This process, commonly referred to as combined assurance,
can be time intensive in the beginning, but it points out gaps in assurance and often results in
beneficial efficiencies by eliminating redundant and unnecessary assurance.
The interpretation Lo Standard 2050: Coordination and Reliance acknowledges the benefits of
such coordination and discusses the parameters necessary to keep the internal audit function
independent as it coordinates its efforts with other assurance functions in the organization:
In coordinating activities, the chief audit executive may rely on the work of other assurance and
consulting service providers. A consistent process for the basis of reliance should be established,
and the chief audit executive should consider the competency, objectivity, and due professional
care of the assurance and consulting service providers. The chief audit executive should also have
a clear understanding of the scope, objectives, and results of the work performed by other providers
of assurance and consulting services. Where reliance is placed on the work of others, the chief
audit executive is still accountable and responsible for ensuring adequate support for conclusions
and opinions reached by the internal audit activity.
Additional lines of defense. In addition to the internal lines of defense described above,
organizations also rely on external sources for assurance that their risks are adequately mitigated.
Most notably, these include the organization's independent outside auditors and applicable
regulators. Whether or not an organization formally includes them in its lines of defense model,
they do provide an additional layer of external, independent assurance for the organization.
While it is important to leverage the efforts of other internal and external assurance and consulting
activities, the most common form of such collaboration is with the independent outside auditors.
Implementation Guide 2050: Coordination and Reliance outlines the considerations the CAE can
make to determine if reliance on the independent outside auditors' work is appropriate.
Specifically, the guidance states that the CAE may:
"Evaluate objectivity by considering whether the provider has, or may appear to have, any
conflicts of interest and whether they have been disclosed.
Consider independence by examining the provider's reporting relationships and the impact
of this arrangement.
Confirm competency by verifying whether the provider's professional experience,
qualifications, certifications, and affiliations are appropriate and current.
Assess due professional care by examining elements of the practice the provider applies
to complete the work (that is, the provider's methodology and whether the work was
appropriately planned, supervised, documented, and reviewed."
To further capitalize on efficiencies between internal auditors and independent outside auditors,
the CAE should extend the same opportunities as. Described above to the independent outside
auditors so they, in turn, can rely on the work performed by the internal audit function. To
accomplish this two-way coordination, it is a good idea for the internal auditors and the
independent outside auditors to use similar techniques, methods, and terminology. This is attained
through regular meetings during which planned audit activities are discussed, including
completion timing and the impact, if any, of observations and recommendations on the scope of
planned work. Additionally, the internal audit function should make available to the independent
outside auditor all final communications, including management's responses to them, and all
applicable follow-up reviews.
This information allows the independent outside auditors to make any necessary adjustments to
the scope and timing of their scheduled work. Likewise, the internal audit function should have
access to the independent outside auditors' materials and communications so that the CAE can
ensure that appropriate follow-up and corrective actions have been taken.
Although the CAE is responsible for the coordination between the internal audit function and
independent outside auditors, the board is responsible for oversight of that coordination as well as
the work performed by independent outside auditors. This means that the CAE needs to gain the
board's support relative to coordinating the efforts of the internal audit function and the
independent outside auditors effectively. The CAE keeps the board apprised of the results of
ongoing assessments of these coordination efforts in general and the performance of the
independent outside auditors specifically, through regular communication.
In addition to this information, a report is typically submitted to the audit committee by either
senior management or the CAE outlining the results of management's self-assessment regarding
the design adequacy and operating effectiveness of the organization's internal controls. At
minimum, the internal audit function should independently assess the process that management
underwent to reach its conclusions. However, many CAEs take on the added role of independently
opining on the organization's system of internal controls over financial reporting.
This opinion is delivered to the audit committee concurrently with management's assertions
regarding the system of internal controls. In more limited cases, the CAEs' opinions extend to
internal controls over operations, compliance, and nonfinancial reporting objectives. They see this
as a natural extension of completing the annual internal audit plan in which the internal audit
function has already independently evaluated the organization's system of internal controls as
outlined in the internal audit plan. Other CAEs disagree with this approach and argue that it creates
a direct conflict with their responsibility to be independent and objective evaluators of
management's self-assessment of the systems of internal control. The approach taken by an
organization is largely a result of its culture.
However, because the CAE is responsible for maintaining relationships with organizations that
have potentially conflicting expectations, including the audit committee, senior management, line
management, and various interested outside third parties (regulators and the independent outside
auditors, in particular), this is not always as straightforward as it appears. If an audit report contains
no observations and the internal controls are found to be designed adequately and operating
effectively, there typically is no misalignment between parties. However, if the internal audit
function finds that the internal controls are designed inadequately and/or are operating
ineffectively, resulting in misalignment between management and one or more of the parties, the
situation becomes much more complicated. It is not enough for the CAE to simply report such a
misalignment to the board and senior management. The CAE must also coordinate a resolution to
the observation and report to the board and senior management how it is going to be rectified. Only
in very rare cases when the CAE and management fail to reach agreement regarding the
observation and/or its resolution would the CAE report an observation that was not accompanied
by its resolution. Communication obligations are covered in detail in chapter 14, "Communicating
Assurance Engagement Outcomes and Performing Follow-Up Procedures," and in chapter 15.
GOVERNANCE
Governance is defined in chapter 1 and then again in chapter 3 as "a process conducted by the
board of directors to authorize, direct, and oversee management toward the achievement of the
organization's objectives." Chapter 3 provides detailed information regarding the governance
process and the roles and responsibilities of all parties involved. For the purposes of this chapter,
however, governance will be discussed only in terms of the internal audit function's specific
responsibilities.
IIA Standard 2110: Governance requires the internal audit function to "assess and make
appropriate recommendations to improve the organization's governance processes for:
Making strategic and operational decisions;
Overseeing risk management and control;
Promoting appropriate ethics and values within the organization;
Ensuring effective organizational performance management and accountability;
Communicating risk and control information to appropriate areas of the organization; And
Coordinating the activities of, and communicating information among, the board,
[independent outside] and internal auditors, other assurance providers, and management."
These responsibilities are carried out largely through the assurance services provided by the
internal audit function. The internal audit charter defines what role the internal audit function plays
in providing assurance relative to the governance process and should reflect the expectations of
the board. Chapter 3 provides the following examples of the internal audit function's governance
responsibilities:
Evaluating whether the various risk management activities are designed adequately to
manage the risks associated with unacceptable outcomes.
Testing and evaluating whether the various risk management activities are operating as
designed.
Determining whether the assertions made by the risk owners to senior management
regarding the effectiveness of the risk management activities accurately reflect the current
state of risk management effectiveness.
Determining whether the assertions made by senior management to the board regarding the
effectiveness of the risk management activities provide the board with the information it
desires about the current state of risk management effectiveness.
Evaluating whether risk tolerance information is communicated timely and effectively
from the board to senior management and from senior management to the risk owners
Assessing whether there are any other risk areas that are currently not included in the
governance process but should be (for example, a risk for which risk tolerance and
reporting expectations have not been delegated to a specific risk owner).
To carry out these responsibilities, the internal audit function must have a clear understanding of
the board's governance direction and expectations, including risk tolerance levels and reporting
expectations. The internal audit plan should reflect that understanding by including appropriate
governance assurance activities and providing opportunities for regular communication to senior
management and the board regarding the effectiveness of risk management activities.
Governance is covered in greater detail in chapter 3.
RISK MANAGEMENT
Generally defined, risk management is a participatory process designed to identify, document,
evaluate, communicate, and monitor the most significant uncertainties facing an organization
requiring risk mitigation or exploitation of opportunities to successfully achieve business
objectives. In other words, risk management is a process conducted by management to understand
and deal with uncertainties (that is, risk and opportunities) that could affect the organization's
ability to achieve its business objectives. Risk response is an action or set of actions taken by
management to achieve a desired risk management strategy. Effective execution of risk
management strategies helps management achieve an organization's business objectives by
reducing the potential impact or likelihood (or both) of a potential risk event or, conversely, by
taking advantage of (exploiting) a perceived opportunity. Risk mitigation is the act of lessening
the severity or potential impact of risks through the use of risk responses. Risk responses are
discussed in detail in chapter 4, "Risk Management."
Risk mitigation is most effectively accomplished when it is decentralized to the areas most affected
by the specific risks. In contrast, risk management is typically more effective when it is a
centralized function. Risk management is most effective when senior management is actively
engaged in the process in a way in which contributors step back from their specific area/department
(silo) and consider the risks confronting the organization as a whole. Unfortunately, many
organizations make the mistake of letting risk management get dispersed throughout the
organization along with risk mitigation. Consequently, the various silos responsible for mitigating
risks also become responsible for the risk management activities described above. This results in
a situation where different areas of the organization are unaware of what is happening in each
other's areas to mitigate similar risk events, culminating in inconsistent risk responses and
inefficiencies due to the application of differing risk appetites and mitigation approaches by the
individual areas.
Historically, risk management has been designed to focus efforts on avoiding potential danger and
preventing harmful actions from negatively impacting an organization. Over time, organizations'
risk management models have evolved and are now focusing their risk management efforts on
identifying opportunities
that can be exploited in addition to risk events that have the potential to negatively affect the
organization. In these models, risk management efforts are designed to facilitate the management
of both risk and opportunity within a predefined risk appetite set by the board and senior
management. Properly executed risk management assists the board and senior management in
implementing appropriate risk responses (avoiding, reducing, sharing, and/or accepting risks or
exploiting opportunities) by increasing the likelihood of achieving the desired result (mitigating a
risk event or taking advantage of an opportunity). Effective risk management also provides
reasonable (not absolute) assurance that the business objectives of an organization will be achieved
As discussed earlier in the chapter, the results of a well-executed risk management process (model)
also can be an essential source for identifying an organization's risk drivers and provide invaluable
input for the development of the internal audit function's audit universe and audit plan.
Consequently, risk management is an area in which the internal audit function can and does have
a critical role to play. Just how much involvement the internal audit function should have in the
organization's risk management process, however, is the subject of much discussion. Although
many organizations now have formal risk management functions that.
are responsible for monitoring and facilitating risk mitigation efforts throughout an organization,
the role of the internal audit function varies widely and is predicated on the division of risk
management responsibilities and the culture of the organization. At minimum, the internal audit
function should evaluate the design adequacy and operating effectiveness of the organization's risk
management processes by providing input and feedback through a periodic review (audit). It is
also appropriate for the internal audit function to facilitate the identification and evaluation of risks
and opportunities, coach management on appropriate ways to respond to risk events and
opportunities, and help an organization coordinate enterprisewide risk management activities.
Increasingly, the internal audit function coordinates more actively with other risk management
groups, not only in its role as part of the third line of defense, but also in an effort to gain
efficiencies for the organization by taking advantage of scheduling synergies and leveraging
assurance efforts to the extent possible. As indicated earlier, however, the internal audit function
should not set the organization's risk appetite, make decisions on appropriate risk responses, or
assume ownership (be accountable for) the risk management processes; only management should
take on these roles.
According to IIA Standard 2120: Risk Management, "The internal audit activity must evaluate the
effectiveness and contribute to the improvement of risk management processes." The interpretation
for this standard states:
Determining whether risk management processes are effective is a judgment resulting from the
internal auditor's assessment that:
• Organizational objectives support and align with the organization's mission;
• Significant risks are identified and assessed;
• Appropriate risk responses are selected that align risks with the organization's risk appetite; and
• Relevant risk information is captured and communicated in a timely manner across the
organization, enabling staff, management, and the board to carry out their responsibilities.
Risk management processes are monitored through ongoing management activities, separate
evaluations, or both. In practical terms, the internal audit function should enhance risk
management and mitigation, providing another level of protection. Exhibit 9-5 shows a range of
activities that an internal audit function might be asked to perform, detailing which activities are
appropriate and which should be avoided. This exhibit was introduced as exhibit 4-4 in chapter 4,
"Risk Management," where it is discussed in greater depth.
CONTROL
IIA Standard 2130: Control states, "The internal audit activity must assist the organization in
maintaining effective controls by evaluating their effectiveness and efficiency and by promoting
continuous improvement."
In terms of providing assurance services, the information that comes out of the risk assessment
should drive the internal audit function's direction when evaluating "the adequacy and
effectiveness of controls in responding to risks within the organization's governance, operations,
and information systems regarding the:
• Achievement of the organization's strategic objectives;
• Reliability and integrity of financial and operational [nonfinancial] information;
• Effectiveness and efficiency of operations;
• Safeguarding of assets; and
• Compliance with laws, regulations, and contracts." (Standard 2130.Al)
Additionally, the internal audit function should identify the objectives of the audited area and
assess how well they align with the objectives of the organization. Assurance engagements should
assess whether controls in place effectively support achievement of those objectives.
Furthermore, Standard 2130.Cl states, "Internal auditors must incorporate knowledge of controls
gained from consulting engagements into evaluation of the organization's control processes."
Control is addressed in detail in chapter 6, "Internal Control."
Quality assurance is the process of assuring that an internal audit function adheres to a set of
standards defining the specific elements that must be present to ensure that the function operates
appropriately. Specifically, IIA Standard 1300: Quality Assurance and Improvement Program
states that "the chief audit executive must develop and maintain a quality assurance and
improvement program that covers all aspects of the internal audit activity." The interpretation for
this standard goes on to explain that "a quality assurance and improvement program is designed to
enable an evaluation of the internal audit activity's conformance with the Standards and an
evaluation of whether internal auditors apply the Code of Ethics. The program also assesses the
efficiency and effectiveness of the internal audit activity and identifies opportunities for
improvement."
IIA Standard 1310: Requirements of the Quality Assurance and Improvement Program, IIA
Standard 1311: Internal Assessments, and IIA Standard 1312: External Assessments detail the
specific requirements for IIA Standard 1300 by specifying that internal audit functions must
establish both internal assessment and external assessment procedures. In practical terms, internal
assessment procedures are the day-to-day quality assurance steps typically outlined in an internal
audit function's operating procedures (audit manual) that ensure that the Standards is followed,
and external assessment procedures are the quality assurance steps that a qualified, independent
party has performed or those that have been performed by the internal audit function and verified
by a qualified, independent party. This process is commonly referred to as an independent peer
review. Internal audit functions are required to successfully complete an external assessment
periodically at least once every five years) to confirm that the internal audit function is compliant
with the Standards. Both internal assessment and external assessment procedures must be
established and followed for an internal audit function to be able to state that it "conforms with the
International Standards for the Professional Practice of Internal Auditing" (IIA Standard 1321:
Use of "Conforms with the International Standards for the Professional Practice of Internal
Auditing"). Exhibit 9-6 presents internal audit function quality assurance procedures suggested
in Implementation Guide 1311: Internal Assessments.
While Standards 1300, 1310, 1311, and 1312 may seem unambiguous, particularly when clarified
by supplemental Implementation Guides, questions as to how these standards should be
implemented have sparked debate within the internal audit community. "Large" internal audit
functions typically have the resources to hire external sources to perform the required external
assessment necessary to comply with Standard 1312. However, care must be taken when selecting
the external assessment team to ensure independence is not compromised. Implementation Guide
1312 provides provide clarification regarding how private and public sector organizations,
respectively, can ensure independence of the external assessment team is maintained. Additionally,
Standard 1312 can be very onerous, especially for "small" internal audit functions. While the
Implementation Guide has attempted to address this concern by providing for a self-assessment
option with independent validation, and agreement can generally be reached on a philosophical
level, problems arise when practitioners try to define what constitutes a "small" internal audit
function and the term becomes relative depending on the size of the function defining it. Exhibit
9-7 presents the suggested alternative approach for "small" internal audit functions finding the
external assessment quality assurance procedures to be too onerous.
Because neither the Standards nor the Implementation Guides make any distinction between
functions that are primarily sourced internally to an organization and those that are primarily
sourced from outside the organization (strategic sourcing arrangements), much discussion
continues about the applicability of, and how best to comply with, the Standards when the function
is primarily outsourced.
Disclosure of Nonconformance
In the event that an internal audit function is found to be sufficiently deficient to impact "the overall
scope or operation of the internal audit activity," IIA Standard 1322: Disclosure of
Nonconformance states that "the chief audit executive must disclose the nonconformance and the
impact to senior management and the board." At that time, a determination will typically be made
regarding whether said noncompliance is intentional or inadvertent, as well as what, if any,
corrective action will be taken. Should senior management and the board make the decision not to
take corrective action and the internal audit function remains noncompliant, the internal audit
function will no longer be able to state that its internal assurance and consulting services conform
"with the International Standards for the Professional Practice of Internal Auditing" (Standard
1321).
The consequences of continuing to offer internal assurance and consulting services that are not
conducted in accordance with the Standards are far reaching and can significantly inhibit the
internal audit function's relationship with interested third parties such as regulators and other
interested outside parties (for example, the U.S. Securities and Exchange Commission [SEC] or
the organization's independent outside audit firm).
On an administrative level, automated risk assessment tools can provide the internal audit function
with a repository that allows for the identification, documentation, and prioritization of risks, what
areas of the organization own these risks, and key controls designed to manage or mitigate these
risks. These tools also document the audit universe, gather information about the different areas in
that universe, and are used to evaluate the risks specific to those areas. Additionally, these tools
help prioritize the amount of risk that a specific area brings to the organization, which drives how
often it is audited. Consequently, the resulting prioritization of the audit universe drives the budget,
scheduling, audit plan, and resource requirements as described earlier in the chapter.
Many organizations apply the same techniques described above to self-assess controls. In these
situations, control and process owners perform techniques that help them assess the design
adequacy and operating effectiveness of the controls within their areas of responsibility. Such
techniques may include the use of technology, as described above, and be facilitated by the internal
audit function or another assurance group within the organization.
Data Analysis
Often there are large amounts of data, commonly referred to as "big data," that must be reviewed
by the internal auditor. This can be very difficult, time consuming, and require specialized skills
without the assistance of technology. Many internal audit functions have created specialist
positions to support these efforts as discussed in greater detail previously in this chapter. Likewise,
sampling might not be effective, practical, or preferred. Sampling also can, at times, limit the
internal auditor's ability to draw definitive conclusions. In these cases, data analysis tools and
techniques can be invaluable because they allow for 100 percent testing, resulting in definitive
results and conclusions. In addition, these tools and techniques also can be used as a feeder source
for continuous auditing, continuous monitoring, and/or fraud detection and prevention efforts. For
a more extensive discussion of computer-assisted audit techniques and sampling, refer to chapter
10, ''Audit Evidence and Working Papers," and chapter 11, ''Audit Sampling."
Automated Monitoring
Automated monitoring tools, similar to data analysis tools, allow the internal audit function to
more efficiently perform continuous auditing by allowing internal auditors to monitor and evaluate
large amounts of data (information) that otherwise might not be possible or practical. Continuous
auditing, in contrast to periodic audit efforts, "is any method used by [the internal audit function]
to perform audit-related activities on a more continuous or continual basis." Continuous auditing
activities often support or supplement the internal audit function's periodic audit, control
assessment, and risk assessment processes. Automated monitoring tools also can enhance the
internal audit function's ongoing management communication efforts by providing "near" real-
time information about the effectiveness of management's continuous monitoring activities. The
availability of timely information about the design adequacy and operating effectiveness of
controls can be helpful to an internal audit function in reassessing priorities for planned assurance
and consulting services, thus maximizing coverage of the internal audit universe. Automated
monitoring tools can better equip an internal audit function to provide value-added services, while
managing its human and financial resources in the most efficient manner possible.
The Internet
In addition to the audit-specific tools mentioned above, the internet can be an effective tool if used
properly. It is an efficient way to do research, speeding up access to information that previously
had to be retrieved through hard-copy format. An increasing number of internal audit functions
use internet links to enhance the planning and delivery of services and gain access to work
programs, working papers, policies, procedures, and other audit tools and resources, which results
in increased efficiency and productivity.
SUMMARY
This chapter presented the different philosophies regarding placement of the internal audit function
within an organization and the drawbacks and benefits of each. The roles and responsibilities of
the key positions within the internal audit function were identified and discussed. The policies and
procedures of internal auditing were presented and how those policies and procedures guide the
internal audit function was examined. Various risk management models were explored along with
what role the internal audit function should take in the organization's risk management processes.
Likewise, the internal audit function's responsibility regarding governance was addressed and
examples of how those responsibilities can be carried out were provided. The quality assurance
requirements, as stated by The IIA, were discussed and the importance of those requirements to
the internal audit function was explained. The benefits of using technology, particularly as it relates
to the management of the internal audit function, were discussed in detail. It should be clear that
managing the internal audit function is a complex undertaking that requires a substantial amount
of good judgment from the CAE. For that reason, it is imperative that the CAE use all of the tools
available, including guidance from The IIA, and that the internal audit function be staffed with
skilled, knowledgeable individuals at every level to assist the CAE in providing the organization
with assurance and consulting services that add value and support senior management in the
achievement of the organization's objectives.