One Key Requirement Needs Emphasis


The checklist “ A Practical Guide to Complying With SAS No. 99’s Key Requirements ” ( JofA , May04, page 24) was well-done. However, I would like to point out one of the key requirements of SAS no. 99 is that “the auditor should incorporate an element of unpredictability in the selection from year to year of auditing procedures performed” (paragraph 50). This is an important part of SAS no. 99 that should be emphasized.

Chuck Manganiello, CPA
AuditWatch of FL/PA
Palm Harbor, Florida

Author’s reply: Due to the nature of the article, space did not permit listing or discussing “unpredictability” among “overall” or “specific” responses to risks encountered.

“Unpredictability” has been in the professional audit literature for decades prior to SAS 99. It manifests itself in many forms, such as random sampling or year-to-year audit procedure variation, and is a very important concept.

Thomas E. McKee, CPA,
Visiting professor
College of Charleston
Charleston, South Carolina


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