INTOSAI Capacity Building Committee | INTOSAICBC
The enabling mechanisms required to facilitate and structure professional development at SAI level (position paper)TRACKING OF COMMENTS FROM TASK GROUP MEMBERSTask group memberReferenceCommentResponse1Jan van SchalkwykGeneralAlign with other documentsDone2Jan van SchalkwykGeneralRework on document for INCOSAI submission – one cover sheet, with this document as an annexure to thatFlagged for September 2016.3Jan van SchalkwykGeneralDelete references to other documents in annexuresDone4EUROSAIGeneralWe would appreciate a more logical flow in the development of the paper. In our view the rationale is not easy to follow. For example – items of the paper are not developed following the content of the executive summary.The table on page 5 of the document proposed a logical structure to accommodate developments regarding professionalism at the level of INTOSAI, followed by a discussion of each of the major developments under a few group headings. The executive summary draws from this table and in the bulleted list outlines the critical enablers that still require attention in INTOSAI.Some streamlining has been done on the flow of the document, including refining and aligning the recommended actions, which should improve the flow of the argument.In the final rework – after the full consultation process has played out – there are plans to make a SINGLE SHORT proposal to INCOSAI, with the different documents (this document, the Framework for Regional Professionalism and the INTOSAI core competency framework) as annexures, which should also assist.5EUROSAIWe would also welcome (it) if you could do an exercise of summarising and avoiding details, such as describing how the competency framework was discussed in Oslo, or too detailed references to what others do, such as IFAC (it could be placed in an annex, for those that want more information). We propose organising the information in such a way that the reader can more easily capture the message of the paper (“less is more”)Noted. As to idea of less detail, please refer to responses under 4 above.Also note that, since the work on the INTOSAI core competency framework has now been completed, this section has been scaled down considerably.6EUROSAIGeneralAs commented in the video-conference, we suggest drafting the paper in a non-prescriptive way for SAIs and regional organisations, thus respecting SAI independence and regional autonomy. That will make the paper more embraceable for SAIs and Regions. In concrete, the priorities of the executive summary could be redrafted as follows:Support the approval of the SAI PMF and encourage its wider implementation in both developing and developed SAISThe development of a core set of professional pronouncements… (no changes proposed)Support the approval of the framework for regional professionalism and encourage its implementation by the Regions, as well as the development of supporting mechanisms as needed by the different INTOSAI regionsCompletion of the development of the IDI regional strategic management framework for all regionsThe document is clearly based on a principle of a “global profession, local solution” which respects the fact that differing audit models, mandates, legal requirements, needs, etc will require a fair amount of tailoring of any proposed action to fit that uniqueness. In that sense, the document is indeed non-prescriptive.The proposed changes to the executive summary have been accepted, pending further inputs and comments on the document.The principle of “global solution, local solution” will be tested throughout the document as part of a final review process. 7EUROSAIPage 5As for the table where frameworks and tools are identified to measure SAIs and Regions performance, we feel that they should be figured out in a non-compulsory and flexible way, leaving room for other guidelines / frameworks and tools to be used.As indicated in the introduction to the table, the only purpose of the framework is to summarise and structure recent development regarding professionalization at INTOSAI level. No mention has been made of it either being mandatory or that it excludes regional development (regardless of whether these are in addition to what is listed or intended as alternatives to what is listed). The keys to the framework also indicate an intention that tailoring of the proposed frameworks is seen as an acceptable, if not necessary step. All of these should further be read in the context of the “global profession, local solution” principle that is explained further in the document.While no further changes has been made on the framework on page 5, the principle highlighted in the comments was further expanded on in the section of “global profession, local solution”.8EUROSAIPage 11We would like more information on what the following sentence means and what it would imply for Regions – “it may be necessary to expand on this draft FRP by adding the option for regional bodies to confirm local and/or tailored competency frameworks to its list of potential services to its members SAIS, as it is not 100% clear to usReformulated to “ it is suggested that the FWRP should also recognise a role for regions in supporting the tailoring of an INTOSAI-approved core competency framework in order to accommodate the unique mandates and needs of the region’s SAIs in line with the principle of “global profession, local solution”.9EUROSAILooking forward and action / responsibility matrix (page 18)Concerning the looking forward and the action / responsibility matrix, we would change the mandatory tone of some of the actions, in particular when referred to the Regions, since we can indeed be encouraged to follow a specific course of action, but at the same time we need to have discussions within our regions. Example of such a case where another more flexible drafting would be welcome - according to item 4 of the table on page 18, INTOSAI regional organisation must by 2017 support the adoption of the framework for regional professional professionalism. What does this support really mean and entail?Although the responsibility matrix was intended as a mechanism to indicate which groupings within INTOSAI could potentially be impacted by the developments listed and, hence, would need to consider the impact of these, it is understandable that the format used can be misleading. The matrix has, accordingly, been removed.10EUROSAIGeneral We have some doubts about supporting the concept of partnering with IFAC, we would welcome more information on this…The point made here refers to partnering with others as a principle. IFAC, IIA and ATD are mentioned as examples. Beyond initial discussions, nothing has been confirmed yet – for that matter the document asks of the INTOSAI Governing Board to mandate the CBC chair to explore this further. The emphasis in this envisaged partnering is on knowledge-sharing and preventing possible duplication of efforts, as spelt out at the bottom of page 17 of the document.11SAI Brazil / PSCGeneral - responsibilitiesI would like to make an additional comment, with the perspective of the future leadership of PSC. In the end of the paper “Enabling mechanisms position”, in the “proposed responsibility matrix”, for the second point “supports the process of further development of professional pronouncements on auditor competence”, I suggest that, besides the FIPP, PSC could be consulted too. It?s because this action is linked to the third strategic objective for Goal 1: “promote the ISSAIs as a source for the development of auditor education and certification programs, as well as education and training standards”. So, it will be important for us to follow up the development of such action.Done12GAOGeneralShould we have a section or discussion about the benefits and commitments required by the SAI?This makes sense, but may imply a duplication with other developments prepared for the theme 2 discussion at XXII INCOSAI (and specifically the main theme paper). We will confirm this in the build-up to INCOSAI and add the CBC submissions, if not already done elsewhere.13SAI India / KSCNoneNoneNone14SAI Austria / INTOSAI GSIn my understanding, we are ultimately working in the (proposed) framework for professional pronouncements in an area where SAIs will be expected to comply if they want to claim ISSAI compliance. Thus, the framework and content is of significant relevance. In other words, we need to get it right. You rightly mention a certain “unease” to significantly build pressure on SAIs, but I believe this is not necessarily due to not wanting to have rules on the side of the SAIs, but also due to some problems in the concepts:I think we are still unclear in at least three important areas that in our opinion we have been asked to look into under the mandate of further research by the Governing Board and that still are not done: How do different SAIs actually do it? (i.e. respond to the need for a competent staff) What do they teach? What do they require prior to staffing? How does that depend on the level of development of the country, the SAI; on the mandate (focus on financial or performance audit) or on the type of SAI (Westminster, French, German type)?I want to emphasize that INTOSAI comes from the sharing of experiences and only starts to develop into standard setting, i.e. the tradition has been to first gather documents of how individual SAIs do things, discuss and share these documents and then carefully consider if common elements are useful for everybody. Thus it is ensured, that only concepts that go through each individual SAI?s full quality control and cost/benefit considerations are used. In other words, we don't use ideas of members of INTOSAI (sub)committees as such, but ideas that have proven useful in national use by whole SAIs.I think we still need this information and this discussion. How do we all do auditor education and - if at all - certification? Do we do it the same way? How much of our education is process, or content? Which content? How strongly is it standardized, how much do we want diversity in our team members?I think a lot of “unease” would go away if the task force would first research and offer this information in a well structured way and observe if some principles strengthen themselves on a voluntary basis before deciding to create rules.What role does education really play in the concept of professionalism and how does that interact with the other elements? We believe that limiting the concept of professionalism (p. 2) is too narrow. As mentioned a few times in the working group, it is my conviction that for many SAIs appointment to an office and the resulting constitutional rights and obligations (like a judge) or political “election” (e.g. by parliament) is at least as significant for the standing of a SAI and the definition of the competencies of individual auditors. The INTOSAI framework recognizes this by stressing the relevance of independence and institutional aspects. I don't know how “arrangements regarding working environment” is to be understood, but I don't think it gives enough emphasis on these important aspects. This, I believe is highly relevant in distinguishing the audits of SAIs from “contracted” work from private sector auditors in the public sphere. This is a matter of competition and is relevant for a cost/benefit analysis. What is the real cost/benefit/risk analysis? (Not of educated vs. uneducated auditors, but of “centralized, uniform” educational standards in a world full of diversity) Before creating a rule on what SAIs need to be doing we should actually estimate costs, risks and benefits.What if we formulate rules and then see “con - compliance”? (i.e., emphasis on different aspects than those envisioned in the INTOSAI papers). Will that undermine the credibility of SAIS? Or of INTOSAI? What if we see compliance but resulting lack of education needed?These documents are part of the foundation of what will ultimately become part of the “standards for auditor competence” section of the newly proposed ISSAI framework and the team share your view that we have to get it right. All that the task group can say about these two documents is that they recognise a fair share of traveling along the road towards ISSAI inclusion, but that they do not yet “pretend” to be the final documents that will go into that space. We hope that the use of the term “unease” (albeit in a slightly different context of how it was used in the document) does indeed represent people’s ambition to make sure that this core framework can work as an enabler, and that it does not imply resistance to core requirements. When the Governing Board asked the CBC and TGIAC to take on the work that we have done in the original whitepaper further, the scope of work channelled to the team was quite ambitious! we had to seriously prioritise within the mandate given and decided to focus on just two core areas – making the discussion on competencies a tangible one (hence the proposed core competency framework) and positioning the project better (hence the enabling mechanisms documents). The positioning focus does perhaps require further explanation – not only did we have to step back from certification to the broader concept of professional development, but we also had to bring some structure to a sometimes overwhelming set of work on professionalization that was being done in INTOSAI in anticipation of the theme 2 discussions at INCOSAI later this year. We do not pretend to have scratched the surface on many issues listed here and fully agree that many of these issues still require attention. At the same time, we should not undersell the amount of work and feedback that has gone into some of these developments. Many of the projects in the enabling mechanisms document represents immense work over many years – the SAI PMF has been developed and tested over the better part of a decade, while something like the framework for regional professionalism represents direct inputs from all regions both at last year’s CBC meeting in Stockholm and in their theme 2 submissions for INCOSAI. As much as the TGIAC has not done a lot to document the detailed experiences and practices of the many INTOSAI members regarding professional development, one should not unnecessarily pretend that this presents a totally unknown body of knowledge. In working on these documents, we were amazed at the extent of work done and the fact that this was easily accessible. What is clear to us, even at this early stage of research, is that INTOSAI regional bodies and SAIs are – at heart – all public sector auditors, as defined in the ISSAIs. At the same time, it is also abundantly clear that, despite this “similar core” that binds us together, we have very different mandates, legislation, methodology, practices, etc. Our talking about the concepts of “international profession, local solution” in the enabling mechanisms document and “core consistency” in the competency framework, are recognition of this realisation. We are deeply under the impression that in moving beyond this year’s INCOSAI, a lot more work needs to be done to surface similarities in requirements, practices and needs and use these to build our requirements to the level of possible standards of auditor competence. A lot of what is mentioned here is critically important, but will only rget attention post 2016 INCOSAI. As to unease – at the moment, we are not writing any rules of regulations relating to the competency framework. We are only defining building block that we believe should be in place to pave the way towards the discussion on standards and guidance. And, as to the content, we have created nothing new, we have just structured the requirements of the ISSAIs into individual “can do” statements for an auditor….. Reading the web-sites / documents of many INTOSA regional organisations will convince the reader that these structures and their member SAIs actually have a very good grasp on what the processes around professional development mean, generically and in the context of their own needs. Similarly, reading the web-sites of the IIA, IAESB and others will convince the reader that there pretty well-researched thinking on these issues in the market place. All these bodies had to deal with the same challenges of balancing international requirements, with local requirements and needs. We do certainly take the comment on the definition of professionalism as it relates to work environment to heart – it would make sense to expand that description.15SAI Austria / IMTOSAI GSI am unclear about the meaning of process/content principles on P. 9 of the “enabling” document and especially the last paragraph on p. 9, first on P. 10 (“It would appear that INTOSAI should limit its global profession efforts to process principles” (not on content). Does that mean we want to make rules on training structure and certification but not on competency frameworks and curricula? Why then, do we produce a competency framework? (defined as a content element above)The principle in the document indicates that one should only deal with matters are “universally true” at the level of standards. While the document does argue that this would in all probability mean a focus on process requirements, it also specifically indicates that it believes that there is value in guiding on competencies for public sector auditing at the level of core consistency (competencies that are true for a public sector auditor regardless where he/she would operate). This principle also explains why we have limited our core competency framework descriptions to only matters that we picked up from the ISSAIs. In response to this and other comments, we have tried to improve the wording here to reflect exactly this principle – which is also in line with the statement regarding page 10, supporting the view that we should just deal with the uniqueness of public sector auditing in competency work at international level.16SAI Austria / INTOSAI GSIn light of the points mentioned above I strongly support the idea (p. 10) that it may be necessary to reflect on the uniqueness of the public sector and public sector auditing.See comment on item 1517SAI Austria / INTOSAI GSI am still unclear on the section on key definitions if each individual needs to have the required competencies or the team in total. What does it mean to argue that a framework is not limited to an individual but may exist for teams or organisations (p. 13)?The whole idea of a core competency framework is that, at a specific level, there would be a set of generic competencies that all staff at that level may share. As SAIs add to this core competencies (reflecting their unique needs) they can add other competencies that may differ from individual to individual – hence the term success profile. For example, Person A and Person B may share the same core competencies for financial auditing at the heart of their profiles,? but in the add-on part, Person A may have some abilities related to international work, while Person B may have some abilities related to academia. While they share the same core, their success profiles (the full combination of what they require for their jobs) will differ. It does therefor mean that in team composition, you would be combining certain different success profiles to make sure that you have a strong team. When you combine person A and Person B in a team, you may find the combined value of their different success profiles as the key enabler for making the project on which we partner, work out. The term competency modelling is intended as a way to describe the matching of success profiles at team or organisational level, depending on the task at hand. There is therefore flexibility to decide whether the full set of competencies is pitched at individual or team level, although we do believe that there should be a basic level of similar knowledge and skill within all individual staff. The whole notion of competency modelling (allowing for flexibility around determining competency requirements at individual, team or organisational level) stems from the comment SAI Austria regarding the importance of audit teams, made at the time of the finalisation of the original whitepaper. We do acknowledge that, in the draft for consultation the moment, these concepts are just contained in the definition section of the document and have, accordingly, expanded the narrative in this section.18SAI Austria / INTOSAI GSIn terms of process, since the document ends with tasking I am unclear what exactly we want from INCOSAI XXII? We have not yet reached a level where we seek approval of the competency framework as an ISSAI or a document in the proposed IFPP, I presume?The task group have been silent on what it wants from INCOSAI when it gets to the competency framework. This is different from the enabling mechanisms document where the drafters have been quite specific on what they want. The reason for this difference lies purely in the fact that the team has very recently completed the competency framework and it will judge the “strength” of the request to INCOSAI from the comments that come in in the coming months. Just based on discussion with the broader TGIAC (the current commenting process), one could say that the TGIAC would want INCOSAI to take note of this framework as a basis for further discussion and refinement of concepts related to professional development to the point where we would see a set of professional pronouncements on auditor competence in another 3 to 6 years’ time. The framework has been updated accordingly19SAI Austria / INTOSAI GSCBC and IDI with structuring and guiding the process of further developments of professional pronouncements, does that mean we propose abolishing the Task Force?The CBC do not envisage the abolishment of the TGIAC at all, but are quite specific that it wants to reposition this as a full CBC subcommittee / work-stream with a broader mandate to deal with further work on the competency framework, including some initial reflections on the utilisation of this in the various ways of professional development.20SAI Austria / INTOSAI GSI am a bit concerned about a general mandate to unnamed “appropriate INTOSAI organs” to enable partnerships with, e.g. IFAC; because I think this is a highly strategic ISSAI. Who in INTOSAI should structure the relationship with partnering organisations?The idea in mandating specific INTOSAI organs to forge formal relationships with bodies that can contribute to the professionlisation discussion, is to empower the CBC chair to handle this responsibility on behalf of INTOSAI, as indicated in the responsibility matrix. In the reworked document, we have deleted the matrix and have, accordingly, added wording to indicate this specific intention to the “looking forward” section.21SAI Austria / INTOSAI GSWe support the idea of the competency framework to be ISSAI based and - given the close relation of the competencies mentioned to the ISSAI level three - it is hard to argue that any of the competencies in the framework are not relevant. Agreed22SAI Austria / INTOSAI GSHowever, I wonder how helpful the current framework will truly be in shaping the education of auditors - is it possible to develop actual training according to the framework? Our domestic example in the Austria Court of Auditors (with its emphasis on performance audit) might exemplify this: We currently require academic education from prospective auditors as well as five years of professional experience. We also (generally) expect new employees to complete a tailored MBA Programm within four years after entrance to the Court of Audit. Yet, most of what is taught there (administrative law, economics, statistics, theories on regulation, etc.) is not mentioned in the proposed competency framework. On the other hand, many of the things mentioned (documentation, materiality) are taught in Austria outside of formal education “on the job” and influence the required evaluation of the work people do and thus their career. However, obviously the knowledge of economics, statistics, etc. strongly influences a person’s capability to evaluate materiality (and many other aspects of auditing, risks, etc.).As indicated in the framework document, the team believes that understanding specific competency requirements is at the heart of many human resource decisions, including the appropriate education requirements, on the job requirements, etc.? From a very practical point of view, we know of many SAIs and at least one INTOSAI regional organisation where they do use competencies as the basis of developing actual training interventions, with huge success. One has to be careful to try and equate the competencies in total to an education or a training program. Competencies can be gained (and assessed) in a variety of ways. Similarly, the specific education route that underpins a SAI’s requirements (such as the MBA that SAI Austria require) may address a lot more than what is in the framework. The comment that this “broader” educational base strongly influences a person’s capability to deal with some of the concepts in the framework, certainly holds true.23SAI Austria / INTOSAI GSI want to conclude by emphasizing that we strongly agree that highly qualified staff are an essential element of a strong public sector auditing function and that helping SAIs achieving that is an important field of work for INTOSAI. Noted – wording also reflected in the introductory section of this documentTRACKING OF COMMENTS FROM INTOSAI COMMUNITY (GENERAL CONSULTATION)Note:This commentary was provided on the cleaned-up version of the document, after task group inputsTask group memberReferenceCommentResponse1European Court of Audit (ECA) (PSC vice chair)Not applicableI am very happy and confident that the position paper proposes the key initiatives that will provide an adequate environment for structured and competence-based professional development to take place in INTOSAI. The competency framework describes very well the key principles necessary to underpinning its development.I would like to congratulate the Task Group on INTOSAI Auditor Certification for preparing bothdocuments and I can assure you that, as a Member of the CBC and Vice Chair of the PSC, we stand ready to support the Task Group in its future work.Noted with appreciation2Brazilian Federal Court of Accounts (TCU) (PSC chair)Page 1Identification of INTOSAI priorities in creating the appropriate environment for….I suggest that the identification of priorities be consistent with the statements in the white paper for professional development. I think that the list should give due priority to the approval of the syllabus for the three audit types as well as the approval of guidance on the recruitment of auditors and on continuous professional education. Those elements are key at SAI level.? Besides, I think that there is too much emphasis on regional arrangements (two bullets), considering that the document refers to the SAI levelNoted that there is a clear need for work at INTOSAI level to move beyond dealing with the building blocks of professionalization (the topic of this position paper) and that the focus should move to guidance on topics such as development of curricula, development and implementation of certification of auditors and perhaps even other human resource challenges. Such work has been flagged for 2017 and beyond as the task group believed that it, in keeping with the Theme 2 for XXII INCOSAI, it is critical that the appropriate environments and enablers for professionalism are created at all levels within INTOSAI.It is important to note that the position paper proposes that work around detailed matters such as the development of curricula and certification programs is best placed at INTOSAI regional or SAI level, at most guided from an INTOSAI perspective, through core principles contained in guidance or standards on auditor competence.As much as the document focus on professionalization at SAI level, the task group believes that a lot can be done at INTOSAI and INTOSAI regional organisation level to enable this process. The ability of INTOSAI regional organisations to guide the process of professionalization is critical, especially from the point of view of preventing duplication, creating synergy, etc. 3Brazilian Federal Court of Accounts (TCU) (PSC chair)Page 3“the first element refers to the professional standards framework or the requirements that all member bodies of the profession should meet” (…) “The second element relates to the competencies that the member bodies of the profession will require of their staff …”I am not sure if it is appropriate to use the expression “member bodies of the profession”. I know the expression “professional bodies”, which is used for associations of professionals. I also know the expression “member bodies” used, for example, for national professional organizations that are members of international organizations (not members of a profession). SAIs are not professional organizations. I think the position paper uses this expression to refer to SAIs. However, the members of the profession are professionals, not organizations (so far). I suggest that SAI is used instead of “member bodies of the profession”. Text adjusted accordingly4Brazilian Federal Court of Accounts (TCU) (PSC chair)Page 4Again, because the paper is about the SAI level, I think that reference to the forth element (checking compliance with requirements) should include the quality control and quality assurance arrangements that must be established to ensure compliance of audit practice to the professional standards.Text adjusted accordingly5Brazilian Federal Court of Accounts (TCU) (PSC chair)Page 6, last paragraphPage 6 last paragraph -? I suggest that the text recognizes that there are other aspect of uniqueness in INTOSAI. Firstly, it deals with three different audit types, while IFAC (the only example cited in the text up to this point) deals only with financial auditing. Another aspect is that professionals linked to IFAC are accountants while auditors of the public sector may have any professional degree. Those are the main reasons why building a profession such as public sector auditing is so hard. Suggested text “…manner. However, in the SAI context, professionalization should pay due regard to the aspects that single out INTOSAI, such as being an organization of state bodies (instead of professional bodies), setting standards for auditors with a wide variety of academic background (not only accountancy) and for three different audit types (instead of only one).Noted. Text was adjusted to reflect examples of public sector and SAI uniqueness, albeit at a slightly more generic level.6Brazilian Federal Court of Accounts (TCU) (PSC chair)Page 9I am very surprised by the use of “licensing” in this text. SAIs work under national legal frameworks that set the criteria to auditors to perform their functions. The requirements established by INTOSAI in no way override the nation legislation and cannot be seen as prerequisites to perform auditor functions. I suggest that you use “specialist recognition” instead of specialist licensing.This section still refers to the generic research carried out in the compilation of this document – hence the term “licensing”. We further understand that in certain circles in INTOSAI the term licensing is indeed used. Did update the document, leading with the term “specialist recognition” with “licensing” as an alternative explanation.7Brazilian Federal Court of Accounts (TCU) (PSC chair)Page 10, note 7I think INTOSAI is the best possible organization to write about requirements for a profession that includes performance and compliance auditing. However, a serious research effort should be done in this direction. There is some material about performance auditing conducted by internal auditors, which is focused on organizational aspects but lacks the programme evaluation perspective. Please see attached the syllabus on PA approved by ALGA. INTOSAI can also conduct a benchmark with the American Association for Evaluation in Education. This is the best recognized organization in evaluation in the world and should be taken into account, considering that PA methodology shares its DNA with programme evaluationAgreed. The intention on page 10 is definitely for INTOSAI to take the lead in deciding on how to take these matters forward and to guide on certain unique areas of focus in public sector auditing, such as compliance and performance auditing. No changes has been made to the text on page 10, but the section on “partnering for success” (page 13) has been enhanced with references to organisations with which INTOSAI can benchmark / engage with on areas such as performance auditing.8Brazilian Federal Court of Accounts (TCU) (PSC chair)Page 10“as much as the INTOSAI CBC …… in consultation with the forum”. For the sake of consistency with page 14, bullet 3, “….. in consultation with the INTOSAI PSC and the Forum for INTOSAI Professional Pronouncements (FIPP) ….” I suggest to change the wording in page 10 to “…… in consultation with the INTOSAI PSC and the Forum for INTOSAI Professional Pronouncements (FIPP)Done9SAI Vienna / INTOSAI GSThank you for sending us the improved version of the two papers incorporating your reaction to our comments. We sincerely appreciate the way you dealt with our comments, especially points 12 to 19. We also acknowledge that the task group had to prioritize concerning the work done and thus many points we addressed in point 10 cannot be managed before the INCOSAI. We do hope, however, that there will be a possibility to look into these matters (analyze experiences and practices of INTOSAI members regarding professional development, revisit the concept of professionalism and conduct a real cost/benefit analysis) as the work done according to the proposals to the Governing Board and/or the INCOSAI proceedsNoted, issue per par 2 of comments flagged for post INCOSAI1011121314 ................
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