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P00611 1 (2012-05-18)

handle is hein.gao/gaobadoup0001 and id is 1 raw text is: AGAO Accontabi|ty Integrity I ReiOwibity United States Government Accountability Office Washington, DC 20548 May 18, 2012 Director, Standards and Guidance The Institute of Internal Auditors 247 Maitland Avenue Altamonte Springs, FL 32701 Subject: Exposure Draft of Proposed Changes to the International Standards for the Professional Practice of Internal Auditing (Standards) This letter provides the U.S. Government Accountability Office's (GAO) comments on the Institute of Internal Auditors' (11A) Exposure Draft of Proposed Changes to the International Standards for the Professional Practice of Internal Auditing (Standards). We appreciate the opportunity to comment on this proposal. We commend the IIA for taking on this project to periodically review and update the Standards. While we agree with most of the changes of the exposure draft, we have suggestions for wording changes that we believe would add clarity to the proposed changes in the following areas: * external assessments, * planning interpretation, and * control. Change to Standard 1312 - External Assessments - page 2 of 6 We agree with the wording changes from reviewer and review to assessor and assessment in the standard and accompanying interpretation. However, the addition of External assessments can be in the form of a full external assessment, or a self-assessment with independent validation to the interpretation may have unintended consequences. The use of can in this sentence and the phrase ... or a self assessment with independent validation may inadvertently dilute the rigor of standard 1312 which states that the assessment must be conducted by an assessment team from outside the organization. We believe that external assessments may be the preferable approach. However, adding more detail on the attributes of an independent validation may mitigate our concerns about the adequacy of independent validations of internal assessments. While we realize that the concept of independent validation is currently included in Practice Advisories 1312-1 and 1312-2, we have a concern with it being elevated to the standards without an adequate description of what is meant by independent validation.

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