FEDERAL ELECTION COMMISSION 

OFFICE OF INSPECTOR GENERAL 

FINAL REPORT 

Quality Assessment Audit of the Federal Election 

Commission’s Audit Division 

September 2012 

ASSIGNMENT No. OIG-12-01
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

TABLE OF CONTENTS 

DESCRIPTION	 PAGE 

Executive Summary 1 
 

Background 4 

Objectives, Scope and Methodology 6 

Audit Findings and Recommendations 

A.	 No formal adoption of professional auditing standards 8
 

B. Lack of a formal quality control program 10 

C. Proper evidence to support supervisory review not consistently 13 

documented in workpapers 

D. Roles of RAD campaign finance analysts that participate on audits 15 

is not adequately defined or properly documented 

E. Controls to ensure adherence with continuing professional 16 

education (CPE) best practices needs to be improved 

Conclusion 20 
 

Attachment 1: Summary of Audit Findings and Recommendations and 

 Management’s Response 21 
 

 

 

EXECUTIVE SUMMARY 

The Federal Election Commission (FEC) was established to oversee campaign financing and is 

responsible for administering and enforcing the Federal Election Campaign Act of 1971, as 

amended (“FECA”). The FEC is also responsible for enforcing all applicable federal election 

statutes and regulations. At the FEC, the Audit Division (AD) has been authorized by the 

Commission and delegated the responsibility for conducting audits of federal political committees 

(“Committees”) that raise and expend funds to aid in the federal election of public officials. In 

addition, the AD is responsible for evaluating the Presidential primary candidates’ applications 

for matching funds and determining the amount of contributions that may be matched with federal 

funds. 

As required by Title 26 of the Internal Revenue Code, including relevant sections of the 

Presidential Election Campaign Fund Act, (26 U.S.C. §§9007(a) and 9008(g)) and the 

Presidential Primary Matching Payment Account Act (26 U.S.C.§ 9038(a)), all Presidential 

campaigns and political party Presidential nominating convention committees, that accept public 

funds must be audited, as well as, host city convention committees. Pursuant to the FECA 

chapter of Title 2, United States Code (specifically 2 U.S.C. §438(b)), all political campaign 

committees for the U.S. House of Representatives and U.S. Senate seats, all Presidential 

committees (that do not receive public funds), and all other committees including political action 

committees (PACs) and national state party committees are subject to an audit and/or field 

investigations. 

The purpose of this audit was to ensure the FEC Audit Division is performing quality audits, and 

to recommend improvements when warranted. Specifically, the primary objective was to 

determine if the FEC AD’s quality control system is suitably designed and consistently complied 

with to the extent necessary to reasonably ensure compliance with professional audit standards 

and internal policies. A system of quality control encompasses an audit department’s 

organizational structure and the policies adopted and procedures established to provide it with 

reasonable assurance of conforming to applicable professional auditing standards (best practices). 

This audit was intended to model a peer review, which is a type of quality assessment that is 

commonly conducted on Federal audit offices. As such, we utilized guidelines for peer reviews 

established by The Council of the Inspectors General on Integrity and Efficiency (CIGIE). CIGIE 

is an independent entity within the executive branch. CIGIE’s mandated mission is to address 

integrity, economy, and effectiveness issues that transcend individual Government agencies and 

to increase the professionalism and effectiveness of personnel in the offices of Inspectors General. 

When assessing AD’s system of quality control, the Office of Inspector General (OIG) considered 

auditing best practices based on applicable standards included in Generally Accepted Government 

Auditing Standards (GAGAS) as well as Generally Accepted Auditing Standards (GAAS) 

established by the AICPA (American Institute of Certified Public Accountants)1

. 

OIG was informed by AD Management that “they have not formally adopted GAGAS, but that 

they generally follow aspects of GAGAS where applicable.” OIG notes that we are not aware of 

1

 For financial audits, GAGAS incorporate the AICPA’s field work and reporting standards and the related statements 

on auditing standards (SAS) unless specifically excluded or modified by GAGAS. 
 

any requirements that FEC Audit Division’s audits must adhere to GAGAS, GAAS, or any other 

professional auditing standards. However, in order to determine if the AD is producing quality 

government audits, the OIG used GAGAS as the standard in which to evaluate the AD against. 

Based on these best practices, audit organizations should design a system of quality control that 

provides reasonable assurance of performing and reporting in conformity with applicable 

professional standards in all material respects. 

In performing our audit, OIG interviewed Audit Division personnel and obtained an 

understanding of the nature of AD’s organization, and the design of AD’s system of quality 

control to assess the risks implicit in AD’s audit function. In addition, the OIG selected a sample 

of seven Committee audits and tested compliance with the AD’s internal quality control policies 

and procedures, and auditing best practices, to the extent we considered appropriate. 

Based on our assessment of the Audit Division’s quality control policies and procedures, AD’s 

system of quality control needs to be enhanced to provide reasonable assurance of performing and 

reporting in conformity with applicable government auditing best practices. Although AD’s 

quality control system needs to be improved and formally documented, the OIG found no 

indications that the audit testing actually performed by the AD was insufficient to support the 

findings and conclusions included in the audit reports sampled. In fact, the AD has a very 

vigorous audit planning (pre-audit) process that enables testing to concentrate on the most 

significant (material) and high-risk audit areas. Also, AD develops standard detailed audit 

programs that list every audit test step to be completed by the audit team for each type of audit 

(Title 26 or Title 2). However, the Audit Division needs to enhance and formalize its existing 

quality control process to ensure adequate evidence is consistently maintained to support audit 

work performed, and that workpaper review procedures by someone other than the person who 

performed the work is properly documented. This documentation ensures that audits consistently 

comply with professional audit standards and internal policies and procedures. 

OIG concludes that the weaknesses related to the design of AD’s quality control system are 

partially attributed to the fact that the FEC Audit Division is not legally required to adhere to the 

professional standards for government auditors. Although AD’s management states that AD 

generally follows GAGAS, AD has not formally adopted applicable professional auditing best 

practices nor established a formal written quality control framework. Nevertheless, the OIG 

concludes the quality of the AD’s audits is acceptable and generally consistent with professional 

auditing standards. OIG notes that the Audit Division is currently working on enhancing and 

formalizing a quality control framework which will be applied to all phases of the audit process. 

In addition to this report, we will issue a management letter that sets forth issues that were not 

considered significant to be reported as findings in this report, but could enhance the effectiveness 

of AD’s system of quality control. 

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The OIG has identified five findings related to Audit Division quality control deficiencies which 

are summarized below: 

•	 No formal adoption of professional auditing standards; 

•	 Lack of a formal quality control program; 

•	 Proper evidence to support supervisory review not consistently documented in work papers; 

•	 The role of the Reports Analysis Division Campaign Finance Analysts (RAD analysts) that 

participate on audits is not adequately defined or properly documented; and 

•	 Controls to ensure compliance with continuing professional education (CPE) audit best 

practices needs to be improved. 

OIG believes that by formally adopting applicable professional auditing standards and 

implementing a formalized quality control program, reduces the risk that the Audit Division may 

conduct audits that may be deficient, or lacking in competence, integrity, objectivity, and 

independence. 

The OIG has proposed 11 recommendations to AD to assist in addressing the identified findings 

and issues listed above. Management has agreed to implement 5 of the 11 recommendations, 

partially agrees with 3 recommendations, and disagrees with 3 recommendations. 

The Office of Inspector General conducted this performance audit in accordance with 

Government Auditing Standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide reasonable basis for our findings and 

conclusions based on our audit objectives. We believe that the evidence obtained provides a 

reasonable basis for our findings and conclusions based on our audit objectives. 

3 
 

 

 BACKGROUND 

The Federal Election Commission (FEC) was established to oversee campaign financing and is 

responsible for administering and enforcing the Federal Election Campaign Act of 1971, as 

amended (“FECA”). The FEC is also responsible for enforcing all applicable federal election 

statutes and regulations. At the FEC, the Audit Division (AD) has been authorized by the 

Commission and delegated the responsibility for conducting audits of federal political committees 

(“Committees”). In addition, the AD is responsible for evaluating the Presidential primary 

candidates’ applications for matching funds and determining the amount of contributions that may 

be matched with federal funds. 

As required by the Presidential Election Campaign Fund Act, “Title 26” (26 U.S.C. §§9007(a); 

9038(a)), all Presidential campaigns and political party Presidential nominating convention 

committees that accept public funds must be audited, as well as, host city convention committees. 

Pursuant to the FECA chapter of Title 2, United States Code (specifically 2 U.S.C. § 438(b)), all 

political campaign committees for the U.S. House of Representatives and U.S. Senate seats, all 

Presidential committees (that do not receive public funds), and all other committees including 

political action committees (PACs) and national and state party committees are subject to an 

audit and/or field investigation. 

The objective of all AD committee audits is to determine whether the committee complied with 

the limitations, prohibitions, disclosures, and other requirements in accordance with applicable 

federal election statutes and regulations (Title 26 and Title 2 audits). In addition, for Title 26 

audits only, the objective is to also determine whether the candidate and/or committee used the 

public funds in accordance with the applicable statutes and federal election regulations. 

The FEC Audit Division performs three types of audits: 

Title 26 Audits – audits of publicly financed committees and convention host committees. 

Title 2-Authorized Committee Audits – audits of committees authorized by either Presidential 

candidates who are not financed with public funds, or by U. S. Congressional candidates. These 

committees are subject to Title 2 regulations. 

Title 2-Unauthorized Committee Audits – audits of committees not authorized by a candidate 

including party committees, political action committees (PACs), and separate segregated funds 

(PACs connected to labor organizations, corporations, trade/membership associations, or 

cooperatives). 

The above audits cover a committee’s campaign finance activity for the respective election cycle. 

For each election audit cycle, the AD updates its existing audit programs which are subsequently 

approved by the Commission. The audit programs detail the audit review process and procedures 

that will be completed by the audit team. For Title 2 audits, compliance threshold requirements 

are established and approved by the Commission at the beginning of every election audit cycle. 

These thresholds are utilized by the AD to evaluate whether committees have substantially 

complied with FECA. Committees are required to file reports as per the FECA. 

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Report Analysis Division (RAD) campaign finance analysts review all reports to track 

compliance with election laws and to ensure that the public record provides a full and accurate 

representation of campaign finance activity. If the FEC’s review identifies an apparent violation 

or raises questions about the information disclosed on a report, there are several tools available 

to address report issues including referring the committee to AD for an audit. Any Title 2 

committee to be audited must be approved by the Commission. 

As of November 22, 2011 (the official start date of this OIG audit), the AD completed and the 

Commission approved 34 audit reports for the 2008 election cycle (the audit cycle under review 

by OIG). All audit projects and most audit workpapers are maintained in TeamMate (TM), which 

is an electronic audit workpaper and project management system. 

At the beginning of the 2008 election audit cycle, there were five (5) audit teams which were each 

headed by an audit manager. The audit managers report to the Assistant Staff Director for the 

Audit Division. During the period under review, the Assistant Staff Director for Audit retired in 

July 2011 and a new Assistant Staff Director for Audit was named in October 2011. As a result 

of this and other employee turnover, the AD was in transition during the audit period under 

review and was restructured from five (5) audit teams to four (4). Additionally, AD was 

implementing newly adopted Commission procedures for the audit report process which included 

increased opportunities for audited committees to respond to potential findings. 

5 
 

OBJECTIVES, SCOPE AND METHODOLOGY 

Objectives 

The Office of Inspector General’s (OIG) objectives for conducting this quality assessment audit 

of the Federal Election Commission’s (FEC) Audit Division (AD) were to: 

1.	 Determine if the AD has a quality control system that is suitably designed to reasonably 

ensure compliance with professional audit standards (best practices) and internal policies; 

2.	 Verify that quality controls and internal policies and procedures are consistently followed and 

operating effectively; and 

3.	 Identify areas for improvements and provide guidance and recommendations based on best 

practices. 

Scope 

During the OIG’s audit planning phase, we interviewed AD management to obtain an 

understanding of the nature of the AD organization and the audit process used to assign, plan and 

conduct committee audits. Based on this initial assessment, OIG decided to select a sample of 

each audit category (Title 26, authorized, unauthorized committees) from the most recent election 

cycle. Therefore, the period under review for this OIG audit included the 2008 election cycle (the 

most recent election cycle with issued reports at the time this OIG audit commenced). The total 

population for the period under review was 34 audit reports. The OIG excluded seven audits from 

the population as they were related to reports issued prior to the implementation of a new audit 

reporting process (Directive 70) which occurred in the middle of the 2008 election audit cycle. 

This exclusion resulted in an audit population of 27 audit reports. We selected a non-statistical 

sample of seven audits (three Title 26 audits, two authorized audits, and two unauthorized audits) 

which represents 26% of the population. The OIG utilized a computerized random sample 

generator to make the selections for five of the seven audits. The other two audits were selected 

using judgmental sampling. This was necessary to ensure the sample represented a reasonable 

cross-section of the different types of audits conducted and of the different audit teams. 

The majority of the audits selected for testing were performed by the AD between March 2008 

and October 2011. We tested compliance with the AD’s system of quality control to the extent 

we considered appropriate. 

OIG Audit Methodology 

To accomplish the audit objectives, OIG performed the following: 

•	 Reviewed the Audit Division’s audit programs and other supplemental guidance for 

conducting audits. 

•	 Gained an understanding of the AD organization’s internal quality assurance program through 

interviews and conducting a walkthrough of the AD audit process. 

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•	 Assessed the design of the AD’s overall internal quality control system and benchmarked 

against best practices to determine if improvements should be recommended. 

•	 Interviewed various levels of the professional AD staff to assess their understanding of, and 

compliance with, relevant quality control policies and procedures. 

•	 Examined the audit workpapers and audit reports of committee audits selected for testing to 

ensure that auditors consistently comply with internal policies and procedures; adhere to 

applicable auditing best practices; audit conclusions are properly supported with sufficient and 

competent evidence; and supervisory review of audits is timely throughout the conduct of 

audits. These reviews were documented utilizing a checklist based on GAGAS to determine 

if the AD has implemented best practices (where applicable). 

•	 Verified if audit staff is adhering to auditing best practices related to continuing professional 

education (CPE) by obtaining adequate training to ensure audits are conducted in an effective 

and efficient manner and in accordance with professional auditing standards and best 

practices. 

7 
 

AUDIT FINDINGS AND RECOMMENDATIONS 

A. The Audit Division has not formally adopted professional auditing standards 

The Audit Division (AD) has not formally adopted Government Auditing Standards (GAS) or any 

other professional auditing standards framework which would allow the AD to formally assess 

whether their audits are conducted in accordance with best practices for government audits. 

Professional auditing standards are intended to ensure that audits have gone through a rigorous 

process to ensure efficiency and quality. 

Based on OIG’s assessment of the Audit Division’s audit process, we determined the following: 

•	 AD’s audits are based on the requirements outlined in the federal election statutes and 

regulations. 

•	 AD has not formally adopted a professional auditing standards framework to ensure audit 

standards are followed. 

•	 The AD does not perform an internal annual assessment of audit operations or an external 

review process (peer review) to periodically assess if the AD is conducting audits in 

accordance with auditing best practices to perform quality government audits. 

According to the Government Accountability Office, the Government Auditing Standards (GAS), 

commonly referred to as generally accepted government auditing standards, provides a framework 

for performing high-quality audit work with competence, integrity, objectivity, and independence. 

GAS 1.04 (Purpose and Applicability of GAGAS) states, - “Many auditors and audit 

organizations also voluntarily choose to perform their work in accordance with GAGAS....” 

Based on our research of GAS (the “Yellow Book”) and Federal election statutes and regulations, 

it does not appear that the FEC Audit Division is legally required to follow GAS or any other 

professional auditing standard. OIG notes that although the AD has not volunteered to formally 

adopt GAS, AD stated that they “generally” follow GAS. However, the aspects of GAS that are 

followed are not formally documented. OIG also acknowledges that the level of audit evidence 

required by GAS to provide assurance of compliance is not consistent in all respects with the 

compliance requirements contained in the Federal election statutes and regulations. 

Not establishing and documenting a set of auditing standards and implementing monitoring 

controls to evaluate compliance with those standards may lead to a perception that FEC audits do 

not provide the same assurance of audits performed by other government audits that follow GAS. 

Recommendation #1 

The Audit Division should formally adopt a set of professional auditing standards which should 

incorporate professional auditing best practices (where feasible). The auditing standards adopted 

should be reflected in AD’s documented policies and procedures to govern their process for 

conducting audits. 

8 
Management Response: 

Audit Division Management (Management) agrees with this recommendation. While AD is not 

legally required to follow GAGAS or any other professional auditing standard, the Division does 

generally follow GAGAS standards to ensure efficient and quality audits. Management will 

document enhancements to the quality control process in the FEC Audit Division Quality 

Standards (to be completed September 2012). This document will provide a framework to further 

ensure the appropriate quality control measures are executed in the Division. 

OIG Comment: 

The OIG believes management’s response will address this recommendation once fully 

implemented. The OIG looks forward to reviewing the quality control framework to ensure that it 

fully addresses auditing best practices included in this recommendation. 

Recommendation #2 

The Audit Division should consider establishing a policy to have an independent external review 

(peer review) every three years in accordance with best practices. If adopted, this requirement 

should be incorporated with their written professional auditing standards framework. 

Management Response: 

Management disagrees with this recommendation. The Commission is legislatively mandated to 

audit politically sensitive materials for which there is no comparable external peer. Management 

is committed to monitoring the current quality control procedures (referencing and management 

review) and will institute an internal sampling and review of audits periodically to ensure 

compliance with the FEC Audit Division Quality Standards. The review will be conducted by 

Division staff (Auditors or Audit Managers) with no previous direct involvement with the audit. 

OIG Comment: 

OIG notes that external peer reviews are a best practice. In the absence of an external peer review 

process by the AD, the FEC OIG will consider periodically reviewing the AD. 

Recommendation #3 

Require audit staff to obtain training on applicable professional auditing standards to adequately 

apply the standards during audit engagements. 

Management Response: 

Management agrees with this recommendation and as such, all audit staff have been and will 

continue to be appropriately and adequately trained on applicable professional auditing standards 

to ensure efficient and quality audits. Training of the audit staff on professional auditing 

standards will continue. 

OIG Comment: 

During our interviews of AD staff members, several employees felt that they have not received 

sufficient training on auditing standards that they are required to follow. OIG notes that while 

most AD staff members are seasoned auditors, the AD has hired less experienced auditors outside 

the FEC over the past few years. OIG believes that management’s commitment to continuous 

training will fully address this recommendation. 

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B. Lack of a formal quality control program 

The Audit Division does not have a sufficient and documented system of quality control 

consistent with professional auditing standards (best practices). The OIG notes that while the AD 

does utilize standard audit programs, which include some quality control elements, there is no 

official documented quality control framework in place that ensures all audits have been 

conducted in accordance with internal requirements and/or best practices. For example, the AD 

can enhance its quality control program by initiating the following: 

•	 a formal documented policy document to govern their overall audit process; 

•	 an official quality control review process for each audit to ensure all required audit steps were 

properly completed; 

•	 “close out” procedures in TeamMate (electronic audit workpaper and project management 

system) to evidence the audit has been properly completed; 

•	 an annual internal assessment to monitor if quality controls are adequately designed and 

operating effectively; 

•	 a policy that requires audit staff and/or specialists (RAD campaign finance analysts) to certify 

that they are independent and free from external impairments prior to conducting an audit; and 

•	 a formal policy that states all staff involved in the audit process must adhere to audit CPE best 

practices. 

A system of quality control is necessary to provide an audit department with reasonable assurance 

that the department and its personnel comply with professional auditing standards (best practices). 

According to Government Auditing Standards (GAS 3.53), “An audit organization’s system of 

quality control encompasses the audit organization’s leadership, emphasis on performing high 

quality work, and the organization’s policies and procedures designed to provide reasonable 

assurance of complying with professional standards and applicable legal and regulatory 

requirements.” 

A system of quality control should address: 

(a) Leadership responsibilities; 

(b) Independence, legal, and ethical requirements; 

(c) Initiation, acceptance, and continuance of audit engagement; 

(d) Human Resources; 

(e) Audit engagement performance, documentation, and reporting; and 

(f) Monitoring of quality. 

By enhancing its quality controls, the AD reduces the risk that audits are not performed in 

compliance with internal policies and procedures and/or do not meet professional auditing 

standards. A formal monitoring process would also enhance control procedures and maintain the 

overall quality of the audits. 

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Recommendation #4 

The Audit Division should document and implement a quality control framework. The quality 

control framework should address best practices of professional auditing standards (where 

applicable) including the following elements: 

•	 independence requirements [for both audit staff and specialists (RAD campaign finance 

analysts)]; 

•	 documented policies and procedures; 

•	 proper communication of policies and procedures to staff involved in the audits; and 

•	 adequate workpaper standards. 

Management Response: 

Management partially agrees with this recommendation. Currently, several longstanding 

procedures provide sufficient quality control. The Audit Programs, approved by the Commission, 

contain directed procedures and quality control elements to govern the audit process. Peer 

auditors not associated with the subject audit are required to review and reference each audit 

report to ensure accuracy and compliance with the laws, regulations, and the Audit Program. This 

has been the practice in the Division for at least 20 years. In addition, Management also reviews 

all workpapers and audit reports for accuracy and compliance with laws, regulations and the 

Audit Program. As directed by Commission procedures, the General Counsel’s office also 

analyzes reports for correct and consistent application of the law. Management will enhance the 

documentation of quality control policies and procedures in the FEC Audit Division Quality 

Standards (to be completed September 2012). 

Management does not agree with the recommendation related to independence of auditors and 

RAD campaign finance analysts. Independence is required for all FEC employees and the 

Commissioners. Formal policies are thus already in place to ensure proper independence, 

including for all FEC audit staff (including RAD campaign finance analysts). Like all other 

Federal executive branch employees, FEC audit staff (including RAD campaign finance analysts 

assisting with audits) is subject to the conflict of interest provisions of Title 18, United States 

Code and the regulations of the Office of Government Ethics. Thus, like all employees, auditors 

may not participate personally or substantially in an audit that will have a direct and predictable 

effect on their own financial interests or those of a person whose financial interests are imputed to 

them. 18 U.S.C. § 208. FEC auditors audit only political committees, not commercial (or any 

other) types of entities. Also, like all employees, auditors must not participate personally or 

substantially in audits in which they have a “covered relationship” (as defined in OGE 

regulations) with the audited committee, or in which they have a “covered relationship” with a 

person who represents the committee. 5 C.F.R. § 2635.501(a). They may also consult with the 

Ethics Office if they are concerned that circumstances not specifically covered by statute or 

regulation would cause a reasonable person with knowledge of the pertinent facts to question their 

impartiality. 5 C.F.R. § 2635.502(a)(2). 

OIG Comment: 

OIG notes that while the AD does currently have some standard quality control practices, we 

found that audits conducted during the period under this OIG review these practices were not 

consistently operating effectively. 

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The OIG is encouraged by management’s plans to enhance the documentation of AD’s quality 

control policies and procedures and we look forward to reviewing the enhancements once 

implemented. 

Although management has generally agreed with the OIG’s recommendation to implement a 

quality control framework, AD does not agree that it is necessary to incorporate independence 

requirements. The OIG believes that while there are policies and regulations related to 

independence for all FEC staff, auditors are held to a higher standard and it is an audit best 

practice to specifically and explicitly address external impairments related to audits and those 

conducting audits. Therefore, the OIG still believes that FEC and AD’s policies and practices 

related to independence, conflict of interest/external impairments should be reflected in the 

quality control framework. Only if all requirements are revised according to the new standard 

procedures will this recommendation be fully implemented. 

Recommendation #5 

The Audit Division should document and implement standard quality control processes and 

procedures. To ensure quality controls are properly implemented and operating effectively, AD 

Management should incorporate the following controls: 

•	 create a quality control checklist to be completed at the end of each audit to ensure audit 

workpapers properly reflect that the audit was performed in accordance to the quality 

control framework adopted; 

•	 require audit staff and applicable specialists (RAD campaign finance analysts) to certify 

they are free from external impairments related to the committees they are auditing; and 

•	 implement a process to ensure all Teammate audit projects are finalized to ensure all 

workpapers have been properly prepared and reviewed. 

Management Response: 

Management partially agrees with this recommendation. Currently, several longstanding 

procedures provide sufficient quality control consistent with professional auditing standards. 

Management will enhance the documentation of quality control policies and procedures in 

the FEC Audit Division Quality Standards (to be completed September 2012). 

See response in Recommendation #4. 

OIG Comment: 

The OIG believes management’s planned actions will address this recommendation. However, 

OIG notes that it is imperative that sufficient monitoring controls (e.g. quality control checklist, 

finalizing projects in TeamMate) are implemented to ensure the process is consistently operating 

effectively. The OIG looks forward to reviewing the quality control policies and procedures to 

ensure it fully addresses this recommendation. 

Recommendation #6 

The Audit Division should conduct a formalized annual internal quality control assessment of the 

AD’s overall audit process to include the attributes identified in GAS 3.53 (a-f) (see page 10) or 

another audit best practice to monitor the effectiveness and efficiency of the audit process. If 

improvements are noted during the assessment, management should develop and document the 

recommendation(s) and corrective action(s) to address the issues noted. 

12 
 

Management Response: 

Management agrees with this recommendation. Management is committed to monitoring the 

current quality control procedures (referencing and management review) and, in accordance with 

FEC Audit Division Quality Standards, which will be completed in September 2012, a periodic 

internal quality control assessment will be conducted. 

OIG Comment: 

The OIG believes management’s planned actions will address this recommendation once fully 

implemented. 

C. Proper evidence to support supervisory review not consistently documented in 

workpapers 

The Audit Division does not consistently follow internal procedures or standard professional 

auditing best practices to evidence proper review and supervision of audits conducted. Based on 

the 7 audits reviewed, OIG found the following: 

•	 In 5 of 7 audits, all audit workpapers were not always signed off in the TeamMate (TM) 

electronic audit software system by the audit manager to evidence that the applicable audit 

steps had been completed. In one of these audits, the WP data was included in the audit 

report. 

•	 In 2 of 7 audits, the reason for not performing audit steps was not documented and signed off 

by the audit manager. 

•	 In 3 of 7 audits, TM project files contain workpapers that were only signed by the team lead 

and thus there is no evidence to support whether the team lead was the preparer or the 

reviewer. As a result, OIG cannot determine if these workpapers were properly reviewed. 

•	 In 4 of 7 audits, coaching notes (reviewer comments) were not subsequently signed-off 

(cleared) by the audit manager/reviewer to evidence that the coaching note was properly 

addressed by the audit staff. 

There are several factors that the OIG believes contributed to these findings. First, the AD does 

not have a formal internal policy (see recommendation # 1) that clearly documents the roles of the 

audit manager; lead auditor; and audit staff. Also, AD lacks standard workpaper review 

procedures to include how to sufficiently address and document reviewer comments. In addition, 

there is no standard control procedure to ensure that all workpapers that are cross referenced to 

the audit report have been reviewed and signed-off by the audit manager or a designated reviewer. 

As a result, audit teams are not consistent in their application of audit workpaper documentation 

and review procedures. 

Secondly, OIG recognizes that AD team members normally perform audit testing offsite at the 

respective committees’ offices and may not have the ability to access TM, and therefore must 

prepare workpapers outside of the TM project file. In these instances, the lead auditor is 

responsible for uploading all workpaper files in TM (which records the workpaper as “prepared” 

by the lead auditor). 

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The AD does not have a standard policy or process in place that requires the workpaper 

“preparer” (the auditor who actually performed the audit testing) to subsequently go into TM to 

sign-off on the workpaper as “preparer,” or requires the “preparer” to sign-off directly on the 

actual workpaper prior to uploading the file into TM. 

According to GAGAS Section 4.20, “...auditors also should document before the audit report is 

issued, evidence of supervisory review of the work performed that supports findings, conclusions, 

and recommendations contained in the audit report.”Also, the AICPA AU Section 339.18 states, 

“...In documenting the nature, timing, and extent of audit procedures performed, the auditor 

should record: a. Who performed the audit work and the date such work was completed; and b. 

Who reviewed specific audit documentation and the date of such review...” 

Not consistently maintaining adequate documentation to evidence proper review and supervision 

of audits increases the risk that audit program steps may not properly be completed, audits may 

not be properly supervised, and/or audit work may not be reviewed in accordance with 

professional standards and/or internal policies and procedures. In addition, the lack of adequate 

evidence of review increases the risk that an independent reviewer outside the AD may question 

the quality of the audits conducted. 

Recommendation #7 

Audit Division Management should implement standard control procedures for documenting 

proper review and supervision of each audit and incorporate into the overall quality control 

framework. The review and supervision process should include the following: 

•	 the audit managers should be required to sign-off on all program audit steps included in TM; 

•	 workpapers (WPs) should be properly signed-off by the person who prepared the WPs; 

•	 once workpapers are uploaded in TM, they should be properly signed-off as “reviewed” by a 

higher level AD staff member (i.e. lead auditor/audit manager); 

•	 coaching notes (reviewer comments) should be required to be sufficiently addressed and 

cleared with the proper sign-offs in TM; and 

•	 AD management (or designee) should ensure that workpapers that support data included in the 

audit report and subsequently cross referenced to the report have been properly signed-off by 

the reviewer before the audit report indexing procedure is completed. 

Management Response: 

Management agrees with this recommendation. Management is in the process of formalizing 

written review and supervision procedures that will follow the FEC Audit Division Quality 

Standards. Although at the time of the OIG audit, standards were not formally documented, 

procedures were and remain in place for the proper review and supervision of all audits. 

Additionally, all workpapers, findings and reports are, and continue to be, thoroughly reviewed by 

Management. The Division provided training to all staff on workpaper sign-off procedures and 

report referencing guidelines in November 2011 and in March 2012. In addition, written 

procedures on how to document the applicable audit steps in TeamMate were sent to the staff in 

March of 2012 to reinforce consistency of review across the Division. 

14 
 

 

OIG Comment: 

The OIG believes management’s planned actions will address this recommendation once fully 

implemented. The OIG looks forward to reviewing the review and supervision procedures to 

ensure they fully address this recommendation. 

D. The role of the RAD campaign finance analysts that participate on audits is not 

adequately defined or properly documented 

The Audit Division has a policy related to assigning RAD campaign finance analysts to audits 

(RAD Audit Fieldwork Guide); however, this document does not adequately explain the role of 

the RAD campaign finance analyst in an audit, and does not document what audit procedures 

during fieldwork the RAD campaign finance analyst is responsible for completing and/or what 

specific task(s) they are not allowed to perform. In addition, the work performed by RAD 

campaign finance analysts was not consistently documented in the audit workpapers for the audits 

sampled by the OIG. As a result, the OIG was unable to determine with reasonable assurance 

whether certain audit testing was or was not completed by RAD campaign finance analysts, and 

whether the RAD campaign finance analysts possessed the proper auditing experience and/or 

qualifications to perform such testing. 

According to professional auditing best practices, there are restrictions related to how specialists 

can be used on audit engagements. If specialists are being utilized for their expertise only, they 

are not required to comply with professional auditing standards. However, according to GAGAS 

section 4.19a, “... Internal specialists who are part of the audit organization and perform as a 

member of the audit team should comply with GAGAS, including the CPE requirements.” 

If the roles of the RAD campaign finance analysts are not defined, and the work performed by the 

RAD campaign finance analyst is not reflected in the workpapers, the risk that the RAD campaign 

finance analysts’ work could expand beyond their area of expertise and negatively impact the 

quality of the audit is increased. 

Recommendation #8 

a.	 The Audit Division should revise the RAD Audit Fieldwork Guide to include clearly defined 

roles of the RAD campaign finance analyst during an audit, a list of the types of audit 

procedures the analyst can be assigned, and what specific audit steps are prohibited from 

being performed by RAD campaign finance analysts. 

b.	 The Audit Division should document the work performed by RAD campaign finance analysts 

for each audit and RAD campaign finance analysts should be required to sign-off on any audit 

workpapers prepared before they are uploaded in TM (as RAD campaign finance analysts are 

not provided access to TM). 

Management Response: 

Management does not agree with these recommendations. Management already has a written 

policy that outlines the role for the campaign finance analyst that is suitable to their expertise. 

According to that policy, fieldwork assignments for a RAD campaign finance analyst are made by 

the Chief Compliance Officer after discussion with the Assistant Staff Directors of both RAD and 

Audit. 

15 
Management will incorporate the RAD audit fieldwork guide into the FEC Audit Division Quality 

Standards. Prior to fieldwork, an Audit Testing Plan is developed and discussed with 

Management. Assignment of audit reviews to be performed by Auditors and RAD campaign 

finance analyst is part of that planning discussion and is included in the Audit Program. All work 

performed by a RAD campaign finance analyst is reviewed by the Lead Auditor and Audit 

Manager to ensure proper utilization of this specialist’s work throughout the process. 

AD will require the campaign finance analyst to sign-off on their completed work. 

OIG Comment: 

OIG does not agree that the current written policy (RAD Audit Fieldwork Guide) adequately 

explains the role of the RAD campaign finance analyst. The OIG would suggest that 

management consider revising the RAD Audit Fieldwork Guide before incorporating controls 

related to the work of RAD campaign finance analysts into the applicable quality control 

documents. The OIG looks forward to reviewing the quality control standards to ensure that it 

fully addresses this recommendation. 

In addition, based on audits reviewed by OIG, there was not consistent evidence to support that 

the work of RAD campaign finance analysts was always properly documented and reviewed. The 

OIG believes management’s decision to require campaign finance analysts to sign-off on work 

completed will improve controls to ensure work of a RAD campaign finance analyst is properly 

documented. 

E. Continuing professional education (CPE) best practices needs to be improved 

Continuing professional education (CPE) requirements are designed to ensure audit staff members 

continue to maintain and enhance their knowledge, skills, and abilities in conducting, leading, and 

performing audits. It is important that audit organizations promote professional competency 

through continuous training to ensure quality audits are performed. The AD currently requires all 

staff members involved in the audit process to obtain 80 hours of CPEs during each two year 

reporting cycle; this is consistent with audit best practices. The AD has a very detailed CPE 

tracking and reporting system which is designed to adequately consolidate and monitor CPEs 

earned for each staff member. 

To determine if AD’s process for tracking and monitoring CPEs obtained to meet the government 

auditing standard (best practice) is operating effectively, OIG selected a sample of 23 audit staff 

from the CPE tracking report. For each employee, we compared all CPE credits included on the 

tracking report to supporting documentation and assessed whether the training received is eligible 

for CPE under the GAO guidance. 

Based on our audit testing, we found that sufficient documentation to evidence CPE’s earned is 

not always maintained and that controls could be improved to make the process more efficient 

and effective. The results of our detailed testing are as follows: 

•	 There were 22 instances where CPEs listed on the AD CPE tracking report did not contain 

proper support to substantiate that the auditor actually attended the training, or adequate 

evidence was missing from the applicable employee training file (only the email request to 

attend training from the Audit staff was included in the file; or the training approval package 

does not include evidence that substantiates the staff member actually attended the training). 

16 
 

•	 3 staff members (two audit managers and one audit staff) did not obtain the 80 hour CPE 

requirement during the 2 year audit period under review. 

•	 AD staff was given CPE credits for WebTa (FEC’s Time and Attendance system) training 

which OIG believes does not meet the CPE eligibility requirements per GAGAS. 

According to GAO Guidance on GAGAS Requirements for Continuing Professional Education 

(GAO-05-568G), section 33, “... GAGAS require that audit organizations ensure that auditors 

meet the CPE requirements...Individual auditors, in conjunction with the audit organization, are 

responsible for monitoring their own progress towards meeting the CPE requirements and 

maintaining evidence of their attendance at or completion of CPE programs...” 

The AD does not have a formal documented policy that communicates to its staff the internal 

requirements to ensure compliance with GAGAS CPE guidance. In addition, management 

informed the OIG after the completion of our CPE testing that the former Deputy Staff Director 

of Audit2 did not require audit managers to obtain the full 80 hours of CPE training. Therefore, 

during the audit period under review, only the audit staff members who actually performed audit 

testing were required to comply with the 80 hour CPE requirement. OIG notes that this does not 

adhere with professional auditing best practices, which also require anyone who leads audits, or 

reviews/signs-off on audit workpapers and reports to obtain 80 hours of CPE training. 

The lack of having a formal CPE policy that is documented and communicated to all employees 

increases the risk that auditors may not be obtaining adequate CPEs in compliance with auditing 

best practices. 

Recommendation #9 

The AD should formally document their policies and procedures relating to current CPE 

requirements. The policy should include the following: 

•	 the AD has adopted the 80 hour CPE requirements in accordance with GAO’s Guidance on 

GAGAS Requirements for Continuing Professional Education; 

•	 each AD staff member is responsible for providing adequate documentation to support CPEs 

earned; and 

•	 guidelines that explain and give examples of what type of training is eligible and ineligible to 

meet GAGAS CPE requirements. 

Management Response: 

Management agrees with this recommendation. Management will formalize CPE policies in the 

FEC Audit Division Quality Standards, which will include the existing 80 hour CPE requirement, 

guidelines that explain what type of training is eligible and instructions on maintaining 

documentation on the server. 

OIG Comment: 

The OIG believes management’s planned actions will address this recommendation once fully 

implemented. The OIG looks forward to reviewing the CPE policy to ensure it fully addresses 

this recommendation. 

2

 The audits reviewed by the OIG during the 2008 election cycle were under the purview of the Audit Division’s 

former Assistant Staff Director for the Audit Division. 

17 
Recommendation #10 

The AD should strengthen control procedures to ensure AD CPE requirements are met by 

implementing the following: 

•	 the audit manager responsible for tracking and monitoring CPEs should be required to verify 

that all training included in the CPE tracking report is supported by proper evidence in 

accordance with GAO’s Guidance on GAGAS Requirements for Continuing Professional 

Education, Section 36: Maintaining Documentation; and 

•	 when training request forms are the only source of evidence, AD staff should be required to 

sign the training form in the appropriate section to certify that they actually attended and/or 

completed the training. 

Management Response: 

Management disagrees with this recommendation. All CPE classes were properly documented 

through spreadsheets, emails, attendance sheets, certificates, etc. GAGAS Requirements for 

Continuing Professional Education, Supplemental Guidance section 35, (Maintaining 

Documentation) states that the audit organization records, should include the name, title, dates 

attended, and the number of CPE hours earned. Management tracks all the aforementioned 

information. Additionally, Management provided OIG copies of all certificates for all but four 

instances. 

OIG Comment: 

Based on the results of our audit testing, we conclude that for the period reviewed, the AD’s CPE 

monitoring procedures were not operating effectively to ensure compliance with GAGAS CPE 

best practices, nor do they support management’s response. Prior to performing CPE testing, AD 

stated that one audit manager was responsible for tracking and reporting CPE credits for the entire 

AD staff. 

OIG was provided individual folders for each audit staff member and one folder for group 

training that contained supporting documentation for CPE credits earned. Audit testing revealed 

the following: 

•	 The files were not complete with all the supporting documentation related to CPE credits 

included in the tracking report. Additional training documentation that was not located in 

the CPE files during our initial testing was provided to the OIG on three separate 

occasions in an attempt to clear the noted exceptions. 

•	 The OIG noted instances where the supporting documentation was not sufficient to 

evidence that auditors actually attended the training (e.g. travel request, registration 

confirmation only). 

Contrary to management’s response above, OIG’s subsequent reviews still resulted in 22 

instances of missing or inadequate CPE documentation for 11 of the AD’s staff members. 

Failure to implement this recommendation or apply alternate monitoring procedures will continue 

to increase the risk of not having adequate controls related to ensuring audit staff complies with 

CPE best practices. 

18 
Recommendation #11 

The Audit Division should establish training guidelines to ensure employees are obtaining proper 

training (e.g. training on applicable auditing standards, audit related topics). Individual training 

needs and types of training planned to meet GAGAS CPE requirements should be incorporated 

into each auditor’s annual performance plan. 

Management Response: 

Management partially agrees with this recommendation. Management will formalize CPE 

policies in the FEC Audit Division Quality Standards. Although Management has been tracking 

this information, it will enhance this procedure by making it available to the staff in real time. 

Additionally, Management will develop a core curriculum for the staff and will meet annually to 

discuss. 

OIG Comment: 

The OIG believes management’s planned actions will address this recommendation once fully 

implemented. We still believe that incorporating training to satisfy CPE best practices into 

individual auditors’ annual performance plans is a best practice that should be considered by 

management. The OIG looks forward to reviewing the CPE policy to ensure it fully addresses 

this recommendation. 

19 
CONCLUSION 

Based on this quality assessment audit by the OIG, except for the audit findings contained in this 

report, we conclude the Audit Division’s system of quality control in effect during the 2008 

election audit cycle has been suitably designed to provide reasonable assurance of performing and 

reporting in conformity with applicable professional auditing best practices. However, some 

enhancements are needed to ensure that the system of quality control is properly documented, 

communicated, and applied. This OIG opinion is primarily due to the fact that the AD has not 

formally documented a suitable professional auditing standards framework to provide 

stakeholders and the public with assurance that the Audit Division has consistently performed due 

professional care as government auditors to produce quality audits. By formally adopting 

professional auditing standards, the AD decreases the perception and risk that the Audit Division 

could potentially conduct audits that may be deficient, and may be lacking in competence, 

integrity, objectivity, and independence. OIG notes that the AD is currently working on 

documenting and implementing a quality control framework to be applied to all phases of the 

audit process. Even though FEC audits (Title 2 & Title 26) are not legally required to comply 

with generally accepted government auditing standards (GAGAS), OIG strongly encourages 

Management to formally incorporate the best practices of GAGAS where feasible and applicable, 

to ensure and measure the quality of audits performed are aligned with audits performed 

government-wide. 

The OIG notes that based on our review of the Audit Divison’s workpapers sampled, audit 

evidence and testing actually performed was sufficient to support the conclusions and findings 

included in the sampled audit reports. However, the OIG concludes that AD’s workpaper 

documentation needs to be improved to ensure proper review and supervision is consistently 

documented to support audits conducted by the AD, are in compliance with internal policies and 

procedures, and that they also meet, to the extent possible, professional auditing best practices. 

The OIG believes implementation of the recommendations provided in this audit report will assist 

the Audit Division in establishing and strengthening adequate controls, effective monitoring 

processes, and maintain the quality of audits conducted. 

20 
 

 

 

Summary of Audit Findings and Recommendations and Management’s Response 

Finding Recommendation Management Response OIG Comment 

A. The Audit 

Division has not 

formally 

adopted 

professional 

auditing 

standards 

1. Formally adopt a set of 

professional auditing standards 

which should incorporate 

professional auditing best 

practices (where feasible). The 

auditing standards adopted should 

be reflected in AD’s documented 

policies and procedures to govern 

their process for conducting 

audits. 

“Agree with recommendation: While AD 

is not legally required to follow GAGAS 

or any other professional auditing 

standard, the Division does generally 

follow GAGAS standards to ensure 

efficient and quality audits. Management 

will document enhancements to the quality 

control process in the FEC Audit Division 

Quality Standards (to be completed 

September 2012). This document will 

provide a framework to further ensure the 

appropriate quality control measures are 

executed in the Division.” 

The OIG believes management’s 

response will address this 

recommendation once fully 

implemented. The OIG looks 

forward to reviewing the quality 

control framework to ensure that 

it fully addresses auditing best 

practices included in this 

recommendation. 

2. Consider establishing a policy 

to have an independent external 

review (peer review) every three 

years in accordance with best 

practices. If adopted, this 

requirement should be 

incorporated with their written 

professional auditing standards 

framework. 

“Disagree with recommendation: The 

Commission is legislatively mandated to 

audit politically sensitive materials for 

which there is no comparable external 

peer. Management is committed to 

monitoring the current quality control 

procedures (referencing and management 

review) and will institute an internal 

sampling and review of audits 

periodically to ensure compliance with the 

FEC Audit Division Quality Standards. 

The review will be conducted by Division 

staff (Auditors or Audit Managers) with 

no previous direct involvement with the 

audit.” 

OIG notes that external peer 

reviews are a best practice. In the 

absence of an external peer 

review process by the AD, the 

FEC OIG will consider 

periodically reviewing the AD. 

3. Require audit staff to obtain 

training on applicable professional 

auditing standards to adequately 

apply the standards during audit 

engagements. 

“Agree with recommendation: As such, all 

audit staff have been and will continue to 

be appropriately and adequately trained 

on applicable professional auditing 

standards to ensure efficient and quality 

audits. Training of the audit staff on 

professional auditing standards will 

continue.” 

During our interviews of AD 

staff members, several employees 

felt that they have not received 

sufficient training on auditing 

standards that they are required to 

follow. OIG believes that 

management’s commitment to 

continuous training will fully 

address this recommendation. 

21 
 

Summary of Audit Findings and Recommendations and Management’s Response 

Finding Recommendation Management Response OIG Comment 

B. Lack of a 4. Document and implement a “Partially agree with recommendation: Although management has 

formal quality quality control framework. The Currently, several longstanding generally agreed with the OIG’s 

control program quality control framework should 

address best practices of 

professional auditing standards 

(where applicable) including the 

following elements: 

• independence requirements 

[for both audit staff and 

specialists (RAD campaign 

finance analysts)]; 

• documented policies and 

procedures; 

• proper communication of 

policies and procedures to 

staff involved in the audits; 

and 

• adequate workpaper 

standards. 

procedures provide sufficient quality 

control. For example, Peer auditors not 

associated with the subject audit are 

required to review and reference each 

audit report to ensure accuracy and 

compliance with the laws, regulations, 

and the Audit Program. This has been the 

practice in the Division for at least 20 

years. Management will enhance the 

documentation of quality control policies 

and procedures in the FEC Audit Division 

Quality Standards (to be completed 

September 2012). 

Management does not agree with the 

recommendation related to independence 

of auditors and RAD campaign finance 

analysts. Independence is required for all 

FEC employees and the Commissioners. 

Formal policies are thus already in place 

to ensure proper independence Also, like 

all employees, auditors must not 

participate personally or substantially in 

audits in which they have a “covered 

relationship” (as defined in OGE 

regulations) with the audited committee, 

or in which they have a “covered 

relationship” with a person who 

represents the committee. 5 C.F.R. § 

2635.501(a.). ” 

For management's full response, see 

page 11 

recommendation to implement a 

quality control framework, AD 

does not agree that it is necessary 

to incorporate independence 

requirements. The OIG notes that 

it is an audit best practice to 

specifically and explicitly address 

external impairments related to 

audits and those conducting 

audits. Therefore, the OIG still 

believes that AD’s policies and 

practices related to 

independence/external 

impairments should be reflected 

in the quality control framework. 

Only if all requirements are 

revised according to the new 

standard procedures will this 

recommendation be fully 

implemented. 

22 
 

 

 

 

 

 

Summary of Audit Findings and Recommendations and Management’s Response 

Finding Recommendation Management Response OIG Comment 

5. Document and implement 

standard quality control processes 

and procedures. To ensure quality 

controls are properly implemented 

and operating effectively, AD 

Management should incorporate 

the following controls: 

• create a quality control 

checklist to be completed at 

the end of each audit to 

ensure audit workpapers 

properly reflect that the audit 

was performed in accordance 

to the quality control 

framework adopted; 

• require audit staff and 

applicable specialists (RAD 

campaign finance analysts) to 

certify they are free from 

external impairments related 

to the committees they are 

auditing; and 

• implement a process to 

ensure all Teammate audit 

projects are finalized to 

ensure all workpapers have 

been properly prepared and 

reviewed. 

“Partially agree with recommendation: 

Currently, several longstanding 

procedures provide sufficient quality 

control consistent with professional 

auditing standards. Management will 

enhance the documentation of quality 

control policies and procedures in the 

FEC Audit Division Quality Standards (to 

be completed September 2012). See 

response in Recommendation #4 above.” 

The OIG believes management’s 

planned actions will address this 

recommendation. However, 

OIG notes that it is imperative 

that sufficient monitoring 

controls (e.g. quality control 

checklist, finalizing projects in 

TeamMate) are implemented to 

ensure the process is consistently 

operating effectively. The OIG 

looks forward to reviewing the 

quality control policies and 

procedures to ensure it fully 

addresses this recommendation. 

6. Conduct a formalized annual 

internal quality control assessment 

of the AD’s overall audit process 

to include the attributes identified 

in GAS 3.53 (a-f) (see above) or 

another audit best practice to 

monitor the effectiveness and 

efficiency of the audit process. If 

improvements are noted during the 

assessment, management should 

develop and document the 

recommendation(s) and corrective 

action(s) to address the issues 

noted. 

“Agree with recommendation: 

Management is committed to monitoring 

the current quality control procedures 

(referencing and management review) 

and, in accordance with FEC Audit 

Division Quality Standards, which will be 

completed in September 2012, a periodic 

internal quality control assessment will be 

conducted.” 

The OIG believes management’s 

response will address this 

recommendation once fully 

implemented. The OIG looks 

forward to reviewing the quality 

control framework to ensure that 

it fully addresses auditing best 

practices included in this 

recommendation. 

23 
 

 

 

 

Summary of Audit Findings and Recommendations and Management’s Response 

Finding Recommendation Management Response OIG Comment 

C. Proper 7. Implement standard control “Agree with recommendation: The OIG believes management’s 

evidence to procedures for documenting Management is in the process of planned actions will address this 

support proper review and supervision of formalizing written review and recommendation once fully 

supervisory each audit and incorporate into the supervision procedures that will follow implemented. The OIG looks 

review not overall quality control framework. the FEC Audit Division Quality forward to reviewing the review 

consistently The review and supervision Standards. Although at the time of the and supervision procedures to 

documented in process should include the OIG audit, standards were not formally ensure they fully address this 

workpapers following: 

• the audit managers should be 

required to sign-off on all 

program audit steps included 

in TM; 

• workpapers (WPs) should be 

properly signed-off by the 

person who prepared the 

WPs; 

• once workpapers are 

uploaded in TM, they should 

be properly signed-off as 

“reviewed” by a higher level 

AD staff member (i.e. lead 

auditor/audit manager); 

• coaching notes (reviewer 

comments) should be 

required to be sufficiently 

addressed and cleared with 

the proper sign-offs in TM; 

and 

• AD management (or 

designee) should ensure that 

workpapers that support data 

included in the audit report 

and subsequently cross 

referenced to the report have 

been properly signed-off by 

the reviewer before the audit 

report indexing procedure is 

completed. 

documented, procedures were and remain 

in place for the proper review and 

supervision of all audits. Additionally, all 

workpapers, findings and reports are, and 

continue to be, thoroughly reviewed by 

Management. The Division provided 

training to all staff on workpaper sign-off 

procedures and report referencing 

guidelines in November 2011 and in 

March 2012. In addition, written 

procedures on how to document the 

applicable audit steps in TeamMate were 

sent to the staff in March of 2012 to 

reinforce consistency of review across the 

Division.” 

recommendation. 

24 
 

 

 

 

 

 

Summary of Audit Findings and Recommendations and Management’s Response 

Finding Recommendation Management Response OIG Comment 

D. The role of 8. The AD should: “Disagree with recommendations: OIG does not agree that the 

the RAD • revise the RAD Audit Management already has a written policy current written policy (RAD 

campaign Fieldwork Guide to include that outlines the role for the campaign Audit Fieldwork Guide) 

finance analysts clearly defined roles of the finance analyst that is suitable to their adequately explains the role of 

that participate RAD campaign finance expertise. Management will incorporate the RAD campaign finance 

on audits is not analyst during an audit, a list the RAD audit fieldwork guide into the analyst. The OIG would suggest 

adequately of the types of audit FEC Audit Division Quality Standards. that management consider 

defined or procedures the analyst can be All work performed by a RAD campaign revising the RAD Audit 

properly assigned, and what specific finance analyst is reviewed by the Lead Fieldwork Guide and then 

documented audit steps are prohibited 

from being performed by 

RAD campaign finance 

analysts. 

• each AD staff member is 

responsible for providing 

adequate documentation to 

support CPEs earned; and 

document the work 

performed by RAD campaign 

finance analysts for each 

audit and RAD campaign 

finance analysts should be 

required to sign-off on any 

audit workpapers prepared 

before they are uploaded in 

TM (as RAD campaign 

finance analysts are not 

provided access to TM). 

Auditor and Audit Manager to ensure 

proper utilization of this specialist’s work 

throughout the process. 

AD will require the campaign finance 

analyst to sign-off on their completed 

work. For management's full response, 

see page 16. 

incorporate standard 

practice/controls related to the 

work of RAD campaign finance 

analysts into the applicable 

quality control documents. 

In addition, based on audits 

reviewed by OIG, there was not 

consistent evidence to support 

that the work of RAD campaign 

finance analysts was always 

properly documented and 

reviewed. The OIG believes 

management’s decision to require 

campaign finance analysts to 

sign-off on work completed will 

improve controls to ensure work 

of RAD campaign finance 

analyst is properly documented. 

E. Continuing 

professional 

education (CPE) 

best practices 

needs to be 

improved 

9. The AD should formally 

document their policies and 

procedures relating to current CPE 

requirements. The policy should 

include the following: 

• the AD has adopted the 80 

hour CPE requirements in 

accordance with GAO’s 

Guidance on GAGAS 

Requirements for Continuing 

Professional Education; 

• each AD staff member is 

responsible for providing 

adequate documentation to 

support CPEs earned; and 

• guidelines that explain and 

give examples of what type 

of training is eligible and 

ineligible to meet GAGAS 

CPE requirements. 

“Agree with recommendation: 

Management will formalize CPE policies 

in the FEC Audit Division Quality 

Standards, which will include the existing 

80 hour CPE requirement, guidelines that 

explain what type of training is eligible 

and instructions on maintaining 

documentation on the server.” 

The OIG believes management’s 

planned actions will address this 

recommendation once fully 

implemented. The OIG looks 

forward to reviewing the CPE 

policy to ensure it fully addresses 

this recommendation. 

25 
 

 

 

 

Summary of Audit Findings and Recommendations and Management’s Response 

Finding Recommendation Management Response OIG Comment 

10. Strengthen control procedures 

to ensure AD CPE 

requirements are met by 

implementing the following: 

• The audit manager 

responsible for tracking and 

monitoring CPEs should be 

required to verify that all 

training included in the CPE 

tracking report is supported 

by proper evidence in 

accordance with GAO’s 

Guidance on GAGAS 

Requirements for Continuing 

Professional Educations, 

Section 36: Maintaining 

Documentations; and 

• When training request forms 

are the only source of 

evidence. AD staff should be 

required to sign the training 

form in the appropriate 

section to certify that they 

actually attended and/or 

completed the training. 

“Disagree with recommendation: All CPE 

classes were properly documented 

through spreadsheets, emails, attendance 

sheets, certificates, etc. Management 

tracks all the aforementioned information. 

Additionally, Management provided OIG 

copies of all certificates for all but four 

instances.” 

Based on the results of our audit 

testing, we conclude that for the 

period reviewed, the AD’s CPE 

monitoring procedures were not 

operating effectively, nor do they 

support management’s response. 

OIG’s subsequent reviews still 

resulted in 22 instances of 

missing or inadequate CPE 

documentation. 

Failure to implement this 

recommendation or apply 

alternate monitoring procedures 

will continue to increase the risk 

of not having adequate controls 

related to ensuring audit staff 

complies with CPE best 

practices. 

11. The Audit Division should 

establish training guidelines to 

ensure employees are 

obtaining proper training (e.g. 

training on applicable auditing 

standards, audit related 

topics). Individual training 

needs and types of training 

planned to meet GAGAS CPE 

requirements should be 

incorporated into each 

auditor’s annual performance 

plan. 

“Partially agree with recommendation: 

Management will formalize CPE policies 

in the FEC Audit Division Quality 

Standards. Although Management has 

been tracking this information, it will 

enhance this procedure by making it 

available to the staff in real time. 

Additionally, Management will develop a 

core curriculum for the staff and will meet 

annually to discuss.” 

The OIG believes management’s 

planned actions will address this 

recommendation once fully 

implemented. We still believe 

that incorporating training to 

satisfy CPE best practices into 

individual auditors’ annual 

performance plans is a best 

practice that should be 

considered by management. The 

OIG looks forward to reviewing 

the CPE policy to ensure it fully 

addresses this recommendation. 

26 
 

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