By Geoffrey Dingle, Managing Director, Shareholder
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02 May, 2024
PCAOB Publishes Spotlight Related to Root Cause Analysis In April 2024, the PCAOB released a Spotlight Root Cause Analysis – An Effective Practice to Drive Audit Quality which continues the Board’s goal of sharing its observations from its inspection and remediation activities, but this time related to Root Cause Analysis (RCA). RCA should not be a new concept to audit firms. In 2020, we published RCA: Seems like EVERYBODY is talking about Root Cause Analysis , where we shared the importance of performing an effective RCA to be able to understand what are the underlying causes of deficiencies which occur at your firm. We wanted to highlight a few important aspects coming through in this April 2024 Spotlight. The Spotlight rightly stated that RCA should be a multifaceted approach . There are a number of different tools, techniques, processes, and philosophies that firms can undertake to perform a RCA. In addition, there may not always only be one factor that is causing a deficiency – it could be a variety of factors such as lack of technical competence, failure of resource allocation at firm level, etc. The Spotlight also identified characteristics of a well-designed RCA process , which are important to highlight as follows: Have a dedicated team with RCA experience perform the RCA as they are more objective and have the requisite background. In helping our clients with RCA, we find by bringing in our objectivity, our PCAOB standards experience coupled with our RCA experience, engagement teams are more willing to be open and honest with their opinions of where they see potential root causes that resulted in deficiencies. Firms use a variety of methods and techniques to gather data which include review of workpapers, interviews with engagement teams immediately after the deficiencies are identified, and review of engagement metrics. All this information combined paints an informative picture of what caused the deficiencies. Firms should not only focus on looking at engagements that had negative quality outcomes, but also focus on looking at engagements which had positive outcomes arising from inspections or the firm’s internal monitoring. By identifying what worked well with some engagement teams, firms can then use that information to drive change with other engagement teams. Lastly, firms should be aware that the task of identifying root causes and implementing a new action to remediate this deficiency does not mean that the job is done. Firms should monitor these remedial actions to determine whether the actions that they undertook are in fact solving the problem. In conclusion, there is no time like the present to strengthen your RCA process . Remediating deficiencies (by providing training, developing new tools and templates, changing processes, etc.) is a time consuming and costly undertaking…you want to make sure that the action you are investing in, is actually going to remedy the problem. In addition, the PCAOB’s standard setting agenda includes a proposal for the new quality control standard that, if adopted, would require firms to perform RCA of its control deficiencies. Our recommendation is to start implementing your RCA process now so that you can refine and modify your RCA process.