Practical Guide Quality Control
Practical Guide Quality Control
Quality Control
1 January 2013
Establishing a system of quality control................................................................................................................................ 3
Developing and implementing a system of quality control................................................................................................. 5
Documenting the quality control system............................................................................................................................... 6
Elements of a quality control system.................................................................................................................................... 7
Leadership responsibilities for quality within the firm............................................................................................................ 8
Relevant Ethical Requirements............................................................................................................................................. 9
Independence................................................................................................................................................................... 9
Assurance Practices only.................................................................................................................................................. 9
Minimum documentation recommendations:..................................................................................................................... 9
Example Independence Checklist....................................................................................................................................... 12
Example Independence Resolution.................................................................................................................................... 14
Acceptance and continuance of client relationships and specific engagements.................................................................15
Minimum documentation recommendations:................................................................................................................... 15
Example Welcome Letter.................................................................................................................................................... 17
Welcome letter................................................................................................................................................................ 17
Client Retention Checklist................................................................................................................................................... 18
Human resources............................................................................................................................................................... 19
Assignment of engagement teams.................................................................................................................................. 19
Minimum documentation recommendations:................................................................................................................... 19
Engagement performance.................................................................................................................................................. 21
Consultation.................................................................................................................................................................... 21
Assurance Practices only Engagement Quality Control Review.....................................................................................21
Differences of Opinion..................................................................................................................................................... 21
Engagement documentation........................................................................................................................................... 21
Minimum documentation recommendations:................................................................................................................... 21
Example Checklist for Engaging Outside Consultants........................................................................................................ 23
Example Differences of Opinion Resolution........................................................................................................................ 24
Monitoring........................................................................................................................................................................... 25
Assurance Practices only................................................................................................................................................ 25
Complaints and Allegations............................................................................................................................................. 25
Minimum documentation recommendations:................................................................................................................... 25
Appendices......................................................................................................................................................................... 30
2 January 2013
This is a practical guide to establishing and maintaining your documented quality control policies and procedures. For the
purpose of this guide it will be referred to as your quality control manual. This should be used in conjunction with both the
short form quality control manual and the detailed quality control manual that CPA Australia has already published.
Each section deals with some of the practical considerations involved in establishing and maintaining a quality control
manual in your firm. It includes commentary on the requirements to document the quality control system and
communicate the quality control policies and procedures to all staff.
Should be something about the basic principles and concepts that are embedded in your firm
Firm’s Goals
Have a main or primary goal for the firm and then other smaller goals, all of which support the firm’s philosophy and
strategy. Think about what the firm is trying to achieve.
3 January 2013
Establishing a system of quality control continued
State the engagement work that is offered by your firm going into a little detail
Talk about your understanding you’re your client’s market place/industry, about your client’s understanding
(strengths/weaknesses) of financial information, state what occurs when work requests are outside existing skill set, your
commitment to quality
Degree of Operating Autonomy of the Principals and Staff in Delivering Service to Clients
Discuss what measures you have in place to have operating autonomy between principles and staff
4 January 2013
Establishing a system of quality control continued
For sole practitioners with staff and multi partner firms document who will be responsible for the quality control system
outlining the persons expertise
For example
John Taylor – Partner is responsible for the design and maintenance of the quality control system. He assumes this
responsibility having spent time studying APES 320 standard as well as looking into supporting reference material
provided by such bodies as CPA Australia.
Assisting John will be Catherine Smith – Associate who will be responsible for regular review of the manual updating
both John and other partners on any changes to the standard and ensuring that our manual reflects our current
business practices. She will also be responsible for organising and chairing quarterly meetings about our quality
control manual so as all staff are aware of any changes to the manual and the standard itself
5 January 2013
Documenting the quality control system
Documentation of quality control policies and procedures is an important overarching requirement of APES 320.
Documentation ensures the firms’ policies and processes are visible and accessible to staff, providing guidance whilst
instilling discipline in organisational practices. Documentation can also be used to protect members in the event of a
negligence claim.
Your firm must formalise its quality control policies and procedures as well as ensuring on going development and
maintenance. This requires documentation that adequately describes the policies and procedures comprising the quality
control system. Your firm will need to determine the procedures and level of documentation required to ensure your
quality control system is effective, and meets both the APES 320 requirements and therefore the requirements of CPA
Australia’s Quality Review Program.
The level of appropriate documentation will depend on:
The size of your firm and the number of offices;
The degree of authority granted to personnel and offices; and
The nature and complexity of your firm.
How the policies and procedures are documented and maintained is your firm’s decision. Smaller firms may use less
formal methods of documentation, including written checklists, memos and notes. Documentation may be in the form of
electronic, hard-copy or a combination of both.
It would be advised that as each of the 6 elements needs to be addressed that you design a “Policy Statement” for each
element outlining all the policies that you have established. This is then supported by the procedures you have in place
that demonstrates how you are following those policies.
To satisfy APES 320, your firm should develop and maintain a quality control policy manual. This document will assist
with the formulation of your quality control system and becomes the centralised point of reference for all quality assurance
aspects of the firm.
A policy manual should be designed to achieve the following:
(a) Communicate the firm’s vision and core objectives;
(b) Clarify management structure and responsibilities;
(c) Provide an administrative guide for the firm;
(d) Standardise the office policies, processes, procedures and work instructions; and
(e) Provide standard job descriptions for administration staff.
When talking about policies on documentation more often these are outlined when addressing the 6 elements of APES
320. However you also need to design policies for documentation which outline matters such as file retention, access to
files (how it’s limited) and how client’s privacy is protected. At the very least file retention should be a period of time to
sufficient to permit those performing monitoring procedures to evaluate the firm’s compliance with its system of quality
control or for a longer period if required by law or regulation.
6 January 2013
Elements of a quality control system
This section describes the six elements of a system of quality control referred to in APES 320. Each element must be
applied to the extent that each one is applicable to your firm, or to particular practices within your firm (e.g. financial
reporting/compilation, audit, taxation, etc.). This is especially important when separating non-assurance services from
assurance services for the purposes of APES 320. A synopsis of the elements of quality control is provided below for
easy reference:
Leadership Responsibilities for Quality Within the Firm – places responsibility on partners to promote a strong
internal culture of quality, and to assume ultimate responsibility for the firm’s system of quality control.
Relevant Ethical Requirements – requires the firm and its personnel to act with integrity and objectivity, and to be
free from relationships with a client which may impair independence.
Acceptance and Continuance of Client Relationships and Specific Engagements – aims to minimise the
likelihood of association with a client whose management lacks integrity, and to ensure the firm has the necessary
competence to perform the engagement.
Human Resources – expects firms to have sufficient personnel with the necessary competence, capabilities, and
commitment to ethical principles to perform its engagements.
Engagement Performance – requires engagements to be performed in accordance with relevant standards and
requirements, appropriate consultation to be available and to take place, and engagement documentation to be
properly documented and stored.
Monitoring – places an emphasis on independent monitoring of the quality control system to ensure it is relevant,
adequate, and operating effectively.
As discussed there are also overarching responsibilities for the quality control policies and procedures to be documented
and communicated to the firm’s personnel.
To begin the process document all your firm’s policies and procedures remembering that a Policy is the action that you
will take and a Procedure is how your will perform that action. Eg It is the firm’s policy to register all incoming mail
(policy). The firm does this by recording the date the mail was received, what the mail pertains to and if it relates to a
client (procedure). Once doing this exercise see how and where these fit among the 6 elements of quality control. This
will start to help assist you develop your manual as well as work out what areas need to be addressed/investigated
further.
7 January 2013
Leadership responsibilities for quality within the firm
The firm must design a system of policies and procedures, and create a suitable culture, to help ensure all work it
undertakes is performed to the highest quality. Underlying this section of APES 320 is that quality is an integral aspect of
a firm’s quality control system. Including statements about quality control demonstrates that you/your firm is taking their
responsibility for quality control seriously.
Document the firm’s policies and procedures for Leadership responsibilities for quality within the firm, including:
the firm’s commitment to a culture of quality
the person(s) ultimately responsible for the firm’s system of quality control;
the firm’s compliance with professional standards and legislative requirements;
the firm’s commitment to review quality control policies and procedures at least annually; and
the firm’s assignment of operational responsibility to the quality control manager.
Policies for Leadership responsibilities for quality might begin with the following statements
Procedures for Leadership responsibilities for quality might include (ensuring appropriate documentary evidence)
Document how the manual is stored and where it is available for easy access.
Sole practitioners might like to include in their processes regular review of existing documents/checklists to ensure that
they are current and reflective of quality control (including the standards requirements). At least on a half-yearly basis.
Sole practitioner with staff/multi partner firms have it that quality procedures form part of your regular agenda items at
team meetings. Discussion will focus on what processes are already embedded, are there any additions or amendments
to these.
Include quality in all staff annual review process and in their contracts. Each staff has an area that they are specifically
accountable for. Regular review and sign off by responsible partner(s)
For multi partner firms assignment of quality control is reviewed and agreed on between the partners and addressed at
least annually.
Induction process includes a review of the existing quality control manual with a discussion held with the relevant partner
over key points to be aware of
8 January 2013
For a more comprehensive list of areas to consider, you should consult Section 3 of the CPA Australia Quality Control
Manual, which is available at the CPA Australia website (cpaaustralia.com.au).
Independence
Independence is a characteristic that is crucial to the accounting profession. The related characteristics of objectivity and
integrity are essential to maintaining actual and perceived independence. Independence is both a state of mind and a
guideline to action undertaken by an individual and a firm. To be independent, you must be intellectually honest and not
influenced by any obligation to or financial interest in the client, its management, or its owners.
Firms must ensure all personnel remain independent, in accordance with the requirements of the Code. To assist in
meeting this requirement, the firm’s system of quality control must outline procedures for communicating independence
requirements to all personnel. The system must also allow the firm to identify threats to independence and implement
procedures to address these threats.
The following are policies which your firm may like to modify for your firm’s situation.
For a sole practitioner with no staff you are still able to adapt the following policies. Where you will differ is the level of
complexity involved in ensuring your compliance with APES 110 (the code) and other regulatory requirements based on
the engagements you perform.
As a member(s) of CPA Australia and the Accounting Profession we recognise the importance of being ethical. At the
forefront of this is ensuring adherence to:
APES 110 Code of Ethics for Professional Accountants
Other APES standards as issued by the APESB
By Laws as issued by CPA Australia
Other applicable regulation
9 January 2013
10 January 2013
Relevant Ethical Requirements continued
We recognise that there is an overarching responsibility to act ethically for our clients and that to act in the public interest.
We need to ensure that in all of our professional engagements we in no way bring our firm’s reputation into question nor
the reputation of CPA Australia. We do this through requiring that all personnel maintain high standards of personal
conduct.
APES 110 sets out the fundamental principles which our firm ensures that we abide by for all engagements performed.
These are Integrity, Objectivity, Professional Competence & Due Care, Confidentiality and Professional Behaviour. We
ensure personnel are familiar with the fundamental principles through communication at team meetings and processes
embedded into the operations of the firm.
Integrity: All personnel are straightforward and honest in their business dealings. Any material believed to be false or
misleading are communicated directly to the partner(s).
Objectivity: Personnel to ensure that they do not compromise their professional or business judgement because of bias,
conflict of interest or the undue influence of others. Relationships that bias or unduly influence the professional
judgement, or impair objectivity, of team members are avoided.
Professional Competence and Due Care:- Personnel maintain professional knowledge and skill at the level required to
ensure clients and firm receive competent professional service.
Confidentiality: Personnel are to refrain from disclosing outside the firm confidential information acquired as a result of
professional and business relationships without proper and specific authority from the firm or unless there is a legal duty
to disclose.
Professional Behaviour: Personnel comply with relevant laws and regulations and avoid any action or omission that
may bring discredit to the profession and the firm.
These are reinforced through leadership of the firm, education and training, monitoring and processes for dealing with
non compliance and ensuring that all personnel address the requirements of APES 110 (The Code).
Procedures you might like to consider adapting for your firm. For sole practitioners with no staff your procedures may be
very simplistic in their nature to have a process where by you review your ethical requirements annually, make any
necessary amendments and sign off to provide evidence that this has occurred. Regular review will ensure that you are
aware of any changes to the standards as well as demonstrating consideration for any changes to the engagements that
you perform.
Include in the staff induction process a run through of your ethical requirements including the compliance requirements of
APES 110.
Include in the annual review of your staff’s performance process to review compliance.
Have a referral process for any issues or evidence of non-compliance outlining what is to happen and who the referral is
to be given to
For any consultants or agents used by the firm have a process which, at least annually, reviews their compliance with
your ethical requirements
11 January 2013
Policies and Procedures for Independence Requirements
The following policies and procedures are for Audit and Assurance Engagements
12 January 2013
Example Independence Checklist
Insert name of firm
Name of employee
Office
Completion of this form provides data for determining that the practice is complying with the independence rules,
regulations and interpretations of CPA Australia and any relevant statutory bodies.
Yes* No
☐ ☐ Do you have a direct or indirect material financial interest in a client or its subsidiaries/ affiliates?
☐ ☐ Do you have a financial interest in any major competitors, investees or affiliates of a client?
☐ ☐ Do you have any outside business relationship with a client or an officer, director or principal
shareholder having the objective of financial gain?
☐ ☐ Do you owe any client any amount, except as a normal customer, or in respect of a home loan
under normal lending conditions?
☐ ☐ Are you connected with a client as a promoter, underwriter or voting trustee, director, officer or in
any capacity equivalent to a member of management or an employee?
☐ ☐ Has anyone in your family been employed in any managerial position by a client?
☐ ☐ Are any billings delinquent for clients that are your responsibility?
☐ ☐ Have you received any benefits such as gifts or hospitality from a client that are not
commensurate with normal courtesies of social life?
☐ ☐ Are there any other independence issues that you believe are relevant to disclose?
*Note: if you answered ‘YES’ to any of the answers above, please also complete the Professional Independence
Resolution Memorandum.
13 January 2013
Example Independence Checklist continued
I have read the Independence Policy of the practice, and professional standards related to independence, and I believe I
understand them. I am in compliance except for the matters listed below.
14 January 2013
Example Independence Resolution
Insert name of firm
To be completed whenever a ‘YES’ answer is recorded on the Professional Independence Checklist for Employees.
Date of enquiry
Client
Employee/Principal
A firm’s policies and procedures must also document the action the firm is to take if it discovers information concerning a
current client that, if the information was known earlier, would cause the firm to decline the client engagement. Such
action must be determined after considering all professional, regulatory and legal requirements, and may include
reporting the client to the relevant authorities and/or withdrawing from the engagement or client relationship.
Policies for acceptance and continuance of client relationships and specific engagements
Our/My firm will ensure that it has the competence capabilities and resources to undertake a new engagement, either
from an new client or existing client, We’ll ensure that when making our assessments we will consider issues relevant to
the engagement including our/my ability to service the client, ethical requirements and client integrity.
The level of investigation and enquiry will be dictated by the type of engagement needing to be performed. For example
Individual Tax Returns will be less onerous as compared to a sole trader.
We/I will be responsible for determining whether, based on all relevant information, we/I will formally accept or decline the
engagement.
All engagements will have engagement letters/documents in place so as to ensure that all parties agree the terms of the
engagement. This document will outline each parties responsibilities, the scope of the engagement, involvement of
anyone specialists or experts (where applicable), billing arrangements and confirms ownership of the documents.
For recurring engagements there will also be an assessment as to whether there is need to issue a new engagement
document to replace the existing document. This will occur generally when there is any change to the areas listed above.
16 January 2013
Procedures for acceptance and continuance of client relationships and specific engagements
For new clients the I/We will conduct a briefing session with any prospective clients in order to make an initial assessment
of the ability of the firm to service the client, any ethical issues that may arise, particularly with regard to independence
and conflicts of interest, and the integrity of the client.
Decisions based on this initial meeting will be documented on file including whether to accept or decline the engagement.
Where the decision is to decline, the client is notified of this decision in writing with the letter and any notes documented
on their file.
If the decision is to accept a client then the client is sent a welcome letter. The firm will conduct a background search to
further assess the areas discussed during the initial briefing session. An ethical letter will also be sent to their current or
previous professional accountant (if applicable) to assess any outstanding professional or ethical issues. A New Client
Acceptance Checklist is also created and completed to assist in the decision making process,
If, after further investigations, the prospective client is declined, the client is notified of the decision in writing with the letter
and any notes documented on a file.
If, after further investigations, the decision is to accept the prospective client the firm will create a New Client Details Form
to be completed as well as generating an appropriate engagement document outlining the terms and scope of the
engagement.
For existing clients I/We a review will occur annually through the completion of a Client Retention Checklist to monitor the
appropriateness of the engagement considering areas such if issues were raised during the existing engagement.
The following webpage will take you to a list of tools that have been developed by CPA Australia that you can
use to help you in this area
17 January 2013
Example Welcome Letter
The following is an example welcome letter that members can provide to their clients. Members are welcome to utilise
and make the changes necessary for their practice.
Welcome letter
Dear (Insert Practice Name),
Welcome to the accounting and financial services of (insert Practice Name)!
It is with great pleasure that we welcome you to our firm and look forward to a mutually beneficial partnership together.
Our firm has a wealth of knowledge and expertise in the areas of accounting, management and business and through our
partners, team members and associates. Our aim as CPA Accountants is to continuously look for the optimal way to
assist our clients achieve their desired business and personal goals.
We enclose a letter [see Sample Letter to Existing Accountant], addressed to your previous accountant, advising them
that you have chosen our firm as your new tax agent. Please sign where indicated and return the letter to our office in the
envelope provided as soon as possible.
Thank you for choosing (insert pratice name) to be your finance business partner. We are sure that it will be a long and
prosperous venture together.
If you have any queries or require any assistance in the above matter, please contact our office on (insert phone number).
Yours sincerely,
[Insert name]
[Insert job title]
18 January 2013
Client Retention Checklist
Client integrity has been considered and we do not have information that would lead us to conclude that the client lacks
integrity?
Independence considerations
Assurance engagement – independence checklist completed?
Non-assurance engagement – no significant threats to independence?
For a more comprehensive list of areas to consider, you should consult Section 3 of the CPA Australia Quality Control
Manual, which is available at the CPA Australia website (cpaaustralia.com.au).
19 January 2013
Human resources
From a quality control perspective, the firm must document and implement steps to ensure it employs enough personnel
possessing the required competence to undertake the position occupied.
Quality considerations address:
Recruitment;
Performance evaluation and compensation;
Capabilities and competence;
Career development and promotion; and
Estimation of personnel needs.
20 January 2013
the life experience and attitude.
I/We will support my/staff with continuing professional development (CPD) through structure learning opportunities as well
as self study. As a member(s) of CPA Australia we make sure that we undertake the minimum 20 hours CPD per year and
meeting the required minimum of 120 hours CPD per triennium.
I/The Partners will assess staffing levels at least annually to ensure that the right amount of resources are in place.
All staff will have their own personnel file which they will have limited access to. These files will include application forms,
resumes, and other administrative items.
All professional staff will have job descriptions outlining what required qualifications and experience required to perform the
role, what the accountabilities are, what technical abilities are required.
All professional staff will have job descriptions outlining what required qualifications and experience required to perform the
role and what the accountabilities are.
Annual reviews will be conducted against key measures agreed on at the beginning of the year. The key measures are
signed off on by both the staff member and myself/appropriate partner.
For each engagement an assessment will be made to ensure the appropriate allocation of staff to meet the requirements of
the client. The assessment will include understanding and similar practical experience, appropriate technical knowledge
and expertise, knowledge of relevant industries and ability to apply professional judgement.
I/We will monitor the workload to ensure that all individuals have sufficient time to adequately discharge their
responsibilities.
I/We will ensure that staff are provided the opportunity to attend professional development opportunities relevant to the work
that they are performing. Some training may be conducted in house while there may be a need to source external training
providers as well. Staff will also be encouraged to seek their own self-education in their development and look for
opportunities to enhance their skills further eg through networking opportunities, online resources and other means
Succession planning to take place at least on an annual basis in conjunction with annual review results
The following are a list of tools that have been developed by CPA Australia that you can use to help you in this area
that are located in the Practice Management Toolkit section of the CPA Australia Website
For a more comprehensive list of areas to consider, you should consult Section 3 of the CPA Australia Quality Control
Manual, which is available at the CPA Australia website (cpaaustralia.com.au).
21 January 2013
Engagement performance
It is important that firms seek to establish consistency in the quality of engagement performance and to demonstrate that
they have not been negligent in performing their duties. APES 320 requires firms to document and implement the steps to
be taken to ensure engagements are performed in accordance with all relevant professional, regulatory and legal
requirements and that all reports issued by the engagement partner are appropriate.
Consultation
It is important that the firm encourages a culture of consultation and referral of difficult matters to continually develop the
competence and capabilities of the staff and the firm. The firm shall establish and implement the required steps to ensure
that appropriate consultation takes place when difficult situations are encountered and, especially for assurance practices,
that the nature and conclusions of such consultations are documented. Consultation should be with those possessing
appropriate levels of knowledge, competence, judgment and authority on significant technical, ethical and other matters.
Differences of Opinion
Differences of opinion may be common in assurance engagements, especially where professional judgments are
required. Policies and procedures must be established and implemented to explain how the firm will deal with and resolve
differences of opinion with clients, others members of the engagement team, consultants, engagement partners, or the
engagement quality control reviewer. The audit/assurance report must not be issued until differences of opinion have
been documented and resolved.
Engagement documentation
It is important that the firm maintains control over the engagement documentation, such that it is of professional quality,
timely in its preparation, properly secured, and retained.
22 January 2013
Policies for Engagement Performance
Minute your review of junior staff members for each engagement they are involved in outlining where the development
opportunities this can also form part of your human resources procedures
For Audit and Assurance firms develop a differences of opinion resolution form
Include the use of work checklists to maintain consistency. Example of this might be the planning checklist, non-audit
engagement checklist and the accounting job sheet.
Include work papers which provide evidence that your policies are being followed
23 January 2013
Example Checklist for Engaging Outside Consultants
Client name Client code
Date Prepared by
Yes* No
Partner
Date
24 January 2013
Example Differences of Opinion Resolution
Facts
Implication
Treatment/opinion #1
Treatment/opinion #2
Recommended/agreed approach/resolution
Partner
For a more comprehensive list of areas to consider, you should consult Section 3 of the CPA Australia Quality Control
Manual, which is available at the CPA Australia website (cpaaustralia.com.au).
25 January 2013
Monitoring
The monitoring of the quality control system provides the firm with added confidence that its policies and processes are
working as designed, and meet the objectives of APES 320. As professional standards, legal and regulatory requirements
change, so too must the firm’s system of quality control. Similarly, as the firm’s clientele, philosophy of operation or
specialties change, it is important to update the firm’s system of quality control. The monitoring function assists with the
identification of these changes. Additionally, the firm must determine whether there have been any system design flaws or
implementation issues, so that improvements can be made and communicated.
Ensuring the quality control policies and procedures are up-to-date is an important responsibility. This is ideally a role for
the firm’s quality control manager.
Assurance Practices
If my firm receives a complaint from an assurance client where it is deemed to be “serious” I will refer the matter on to a
consultant who will be responsible for investigating and resolving the matter. This is to ensure that the matter is dealt
fairly and equitably.
26 January 2013
Policies for Monitoring continued
Assurance Practices
If my firm receives a complaint from an assurance client where it is deemed to be “serious” I will refer the matter on to a
consultant who will be responsible for investigating and resolving the matter. This is to ensure that the matter is dealt
fairly and equitably.
27 January 2013
Policies for Monitoring continued
Assurance Practices
If our firm receives a complaint from an assurance client the complaint will be assigned to a partner not involved in the
engagement who will be responsible for investigating and resolving the matter.
28 January 2013
Procedures for Monitoring
29 January 2013
Procedures for Monitoring continued
For a more comprehensive list of areas to consider, you should consult Section 3 of the CPA Australia Quality Control
Manual, which is available at the CPA Australia website (cpaaustralia.com.au).
30 January 2013
Appendices
In your quality control manual you may like to introduce an appendices section where all your templates
(eg checklists, engagement letters etc) are stored and cross referenced to within your manual. At the front of the section
you may like to list all the documents like an index and then place copies of all documents from there.
To discover more about the resources CPA Australia has designed to assist our members in public practice, such as
sample engagement letters, checklists and more please visit the Practice Management Toolkit on the CPA Australia
website cpaaustralia.com.au/practicetoolkit
31 January 2013