JGA Team Perspectives: System of Quality Management – Using Technology in Your Practice and Audits

Mark Whittenber, JGA Director and Shanett Edwards-Morton, JGA Director • May 22, 2024

Editor’s note: This article is part of a series to highlight the unique experience that JGA professionals possess and deliver to our clients.


The implementation of systems of quality management is a recent focus area of standard-setters and has become a high priority for firms of all sizes. International Standard on Quality Management (ISQM) 1 requires all firms that perform engagements under the IAASB’s international standards to have systems of quality management designed and implemented by December 15, 2022. The AICPA’s Statement on Quality Management Standards (SQMS) No. 1 requires systems of quality management to be designed and implemented by December 15, 2025, with required evaluation of the system within one year following that date. On May 13, the PCAOB approved QC 1000, A Firm’s System of Quality Control and Other Amendments to PCAOB Standards, Rules and Forms, which would replace current PCAOB quality control standards in their entirety. The standard is undergoing review by the SEC. It will apply to all PCAOB-registered firms and will be effective December 15, 2025. It will require firms to identify their specific risks and design a quality control system that includes policies and procedures to guard against those risks, with mandatory annual reporting by the firms.


To manage the implementation journey, every firm should develop a roadmap that incorporates existing policies, processes and procedures as well as the need for additional or newly designed policies, processes and procedures. Throughout the remainder of this article, Mark Whittenberg and Shanett Edwards-Morton share their thoughts and recommendations on how technology should be incorporated within the firm’s system of quality management, in order to drive, monitor and maintain audit quality. This includes technology that is used to support engagement teams as well as technology used in the firm’s operations.


Technology for Audits and Quality Management

While compliance is often the driver when implementing quality control standards, there is strategic value for firms to look at their internal processes for getting audits done and the technology tools and software they use and make improvements that can benefit overall quality management. There is already a rapid change in use of technology in audits, and clients are expecting firms to use technology to enhance efficiency and provide more meaningful insights. Firms should have a plan to incorporate technology into both their engagements and their system of quality management.


“Outside the Big 4, firms used to have a handful of software tools they used for audits, but now there is increased investment and rapid development of new applications and more advanced technology,” Whittenberg said. “Firms that don’t use technology for their audits will be at a competitive disadvantage, and it takes time and resources to implement technological changes.” 


Technology and the System of Quality Management

In evaluating technologies and automated tools (i.e., technology resources) related to a firm’s system of quality management (SQM), it is important to consider the overall SQM framework, including the risk assessment process component, the monitoring and remediation process component, and the other components (governance and leadership, relevant ethical requirements, acceptance and continuance, engagement performance, resources, information and communication). Categories of technology resources include those:


  • Related to the design, implementation, and operation of the firm’s SQM – for example to: monitor personnel independence and ethics violations, track personnel time and assess workload, retain and maintain engagement related documentation, and record the firm’s considerations around client acceptance and continuance;
  • Used by engagement teams in performing the engagement – for example: audit software and automated tools used on an engagement to prepare and compile documentation, and tools and software for firm methodology and policies; and
  • Used to ensure effective operation of IT applications – for example: operating systems and databases, hardware, and logical access.


When seeking technology solutions for quality management, it is important to first identify the pain points and needs. “Vendor demonstrations at conferences are catchy, but firms frequently buy the software and then say, ‘Now what?’ if they do not have a use case, have not thought about how to apply it to their clients and firm’s specific needs, or do not have the necessary data available,” Whittenberg said. 


“Firms may have technology that supports their SQM, but they also must have technology tools to help them manage their workflows and components in order to evaluate their overall SQM,” Edwards-Morton said. “It is critical that firms ensure technology is addressed during each step of the SQM implementation process, and that the right technology is deployed for the risks identified.” Firms may attempt to use existing audit software tools that were not designed for this evaluation and for ongoing monitoring and remediation. 


Firm Operational Monitoring Tools

Technologies can drive consistency in firm operations, which impacts quality management. “Firms often use a lot of manual monitoring of their operations, but as they see other firms adopting technology in this area, they are looking into applications, so they do not get left behind,” Edwards-Morton said. 


Common examples are firms using Excel spreadsheets or Word checklists for engagement acceptance and continuance procedures, independence compliance, and training and tracking CPE. “Technology can look at firm data in more depth and in less time, identify conflicts and risks, and generate evidence that responsive actions were performed, and effectiveness was tested, which is required by the standards,” Whittenberg said. 


A number of vendors provide operational monitoring tools in areas of risk assessment, ethics and independence, and human resource management and scheduling. Solutions are available to address specific problems and are easier to integrate today. “Cloud-based software permits firms to ramp up quickly without a lot of configuration and to interface with firm software and connect different systems to obtain better insights and monitoring,” Whittenberg said. 


The new standards require an analysis of the root cause of QC deficiencies t which can be difficult to perform when the data is contained in multiple databases. Cloud-based software can manage data and provide connections to issues that are spread across the firm but contribute to quality risks.


Engagement Team Specific Monitoring Tools

These are the tools used to perform certain audit procedures, including project management, data analytics, audit documentation, and other solution-specific tools. “These tools are where firms get the biggest bang for their buck, and they are important for client-facing activities,” Whittenberg said. Use of technology in this area can impact team engagement performance and quality. Examples include DataSnipper, that can read financial statements or SOC reports, identify key information auditors need, and auditors can review the information then copy and paste it into audit workpapers.


Best Practices in Implementing Technology Tools and Software

There are different stages in a software audit tool maturity model, ranging from basic audit documentation software to advanced tools for data analytics and visualization.


It is important for firms to assess where they are and have a plan in place. Not all firms need the most advanced solutions, but it is important to anticipate both current and future needs. Firms should start with a use case that identifies the problems to be solved and the software or other solutions that may address their needs. In developing software tools, we recommend a multistep approach that begins with taking a software inventory of tools in use and assessing the engagement team process and the completeness and accuracy of data inputs and outputs. Future tool planning identifies desired future capabilities, the people and processes, training, and the rollout plan.


There are a number of risks to consider, including data completeness and accuracy, change management during development and in production, access, and IT general control weaknesses that can impact operating effectiveness. The biggest challenges in integrating technology are lack of buy-in and support from firm leadership, commitment to a long-term investment in technology, resistance to change from auditors, and managing skill gaps. 


Artificial Intelligence

There is a lot of optimism about the potential use of AI for audits, in areas like risk identification and predictive analytics, automating manual tasks, analyzing and testing complete volumes of data, identifying anomalies, and documentation. Also, there are potential applications for firm monitoring and quality management, including, among others, acceptance and continuance, independence and conflicts of interest, and scheduling and resource optimization. 


“There is a lot of promising software out there, but most firms are not fully using it yet,” Whittenberg said. “Machine learning will get smarter as it continues to ingest data, but it’s not there yet at a large scale, and Chat GPT is producing information that is not yet usable.” As AI evolves, firms should look at their competencies, risks, and proposed solutions and consider whether their required investment will help them improve their audit quality and engagement monitoring.


“As firms think about the new quality management standards’ requirements, many may be overwhelmed, especially the smaller firms," Whittenberg said. “They must have a plan to incorporate technology into both their engagements and their SQMs, because their competitors are doing it.“


Firms moving into compliance with the new quality standards (ISQM 1, SQMS 1, and QC 1000) is a significant change. To manage these considerations, every audit firm should have an implementation plan to look at their internal processes for getting audits done. If you have any questions regarding these standards and preparation for compliance, please feel free to contact us.



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On May 3, 2024, the SEC charged audit firm BF Borgers CPA PC and Benjamin F. Borgers (collectively, “Borgers”) with fraud affecting more than 1,500 SEC filings. According to the SEC’s Order , of the 369 BF Borgers clients whose public filings from January 2021 through June 2023 incorporated BF Borgers’ audits and reviews, at least 75% of the filings incorporated BF Borgers’s audits and reviews did not comply with PCAOB standards. Because a significant number of issuers have been impacted by the Order, the SEC’s Division of Corporation Finance released a statement on the topic (the “CF Release”). According to the CF Release, issuers that have engaged Borgers to audit or review financial information to be included in any Exchange Act filings to be made on or after the date of the Order will need to engage a new qualified, independent, PCAOB-registered public accountant. Further, the CF Release provides that: Form 10-K and Form 20-F filings on or after the date of the Order may not include audit reports from Borgers; and Form 10-Q filings on or after the date of the Order may not present financial information reviewed by BF Borgers. Accordingly, affected entities will be required to engage a new qualified, independent, PCAOB-registered public accountant to perform the current annual audit and quarterly reviews, as well as perform re-audits and rereviews of all relevant impacted periods. The CF Release also stated that “Exchange Act reports that were filed before the date of the Order do not necessarily need to be amended solely because of the Commission’s entry of the Order. However, issuers should consider whether their filings may need to be amended to address any reporting deficiencies arising from the BF Borgers engagement.” This document provides some helpful information for auditors who are considering or have recently accepted an audit engagement with an affected entity. Specifically, it discusses topics such as interim reviews, client acceptance and communications with the predecessor auditor. Interim Reviews The successor auditor may conduct the review of the current year interim financial information and the rereview of the prior year corresponding interim period, provided the firm also simultaneously proceeds with the annual audit and reaudits of the latest year (or years, depending on the client’s filing situation, i.e. based on the number of comparative periods presented). Auditors can find the requirements relating to reviews of quarterly financial statements in AS 4105 , Reviews of Interim Financial Information . According to that standard, an auditor may conduct a review of the interim financial information of an SEC registrant if the entity's latest annual financial statements have been or are being audited . (AS 4105.05) Because successor auditors will begin the reaudit of the prior year financial statements immediately following their engagement, auditors are permitted to proceed with the review of the clients’ quarterly financial statements for inclusion in the company’s Form 10-Q filing with the SEC. There are certain specific requirements auditors should be aware of when conducting initial reviews of interim financial statements relating to obtaining knowledge about internal controls and communicating with the predecessor auditor. Those requirements can be found at AS 4105.12 and .13. We encourage auditors to read and understand the requirements of AS 4105 before committing to engaging new clients. Client Acceptance As indicated in the CF Release, any prior period financial statements that had previously been audited by Borgers will need to be reaudited by the newly engaged auditor for inclusion in the issuers next Form 10-K or Form 20-F. Prior to starting an initial audit, the successor auditor will also be required to perform procedures regarding acceptance of the client relationship and the specific audit engagement; and communicate with the predecessor auditor as described in AS 2101.18. It is advisable that any firm should follow their client acceptance procedures with rigor. Prior to acceptance, firms should read the SEC Order carefully and consider the variety of risks involved with each prospective client, especially the heightened risk that a material misstatement may exist on prior year financial statements. Firms will also need to extend their acceptance procedures to cover all periods subject to reaudit. A few special considerations to highlight: Determine the auditing procedures necessary (and the ability) to obtain sufficient appropriate audit evidence regarding opening balances and consider the obstacles that may be involved. Perform background checks of management and the board of directors and understand the reasons for departures and changes from the date of the opening balances (and possibly beyond) to the present. Review all SEC comment letters and responses for all periods under audit and reaudit. For perspective clients with inventory, special consideration will need to be given as to how to obtain appropriate audit evidence because of the inability to perform physical inventory observation procedures in the prior periods. Inquire about the prospective clients’ books, records, internal controls and IT systems to understand the ability to obtain reliable information timely for all periods under audit. Assess whether the firm has the skills, knowledge and experience to take on a new client, and if the firm is considering taking on multiple issuers, whether they have the internal resources to perform the audits with the appropriate level of audit quality. Communications with the Predecessor Auditor PCAOB standards at AS 2610 require the successor auditor to communicate with and make a variety of inquiries with the predecessor auditor prior to accepting the engagement and that acceptance cannot be final until the communications received from the predecessor have been evaluated. Inquiry of the predecessor auditor is a necessary procedure because the predecessor auditor may be able to provide information that will assist the successor auditor in determining whether to accept the engagement. In addition, the successor auditor should request and review the working papers of the predecessor auditor for all periods that will be subject to reaudit. When possible misstatements are discovered during the audits or reaudits, the successor auditor will also be required to communicate with the predecessor auditor. According to PCAOB standards, in an initial review of interim financial information the auditor should perform procedures that will enable him or her to obtain sufficient knowledge of the entity’s business and its internal control. The standard goes on to describe steps the auditor should take, which includes making certain inquiries of the predecessor auditor and reviewing the predecessor auditors’ workpapers (including both the audit and quarterly review workpapers). The standard also states that, “if the predecessor accountant does not respond to the successor accountant's inquiries or does not allow the successor accountant to review the predecessor accountant's documentation, the successor accountant should use alternative procedures to obtain knowledge of the matters discussed in [that] paragraph.” Given the number of affected entities described in the Order, it is unclear whether Borgers will reply to successor auditor inquiries and how timely the responses will be. Thus, auditors considering accepting these engagements will need to be prepared to perform alternate procedures to address the possible gaps during the acceptance process. In summary, even though the facts and circumstances described in this SEC Order are unique, successor auditors are still required to perform the PCAOB standards’ requirements as described above.
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