Write On

BY SHEILA SHANKER

The Sarbanes-Oxley Act has brought both opportunities and challenges. CPAs engaged to write documentation enter a new world of narratives, control assessments, testing and remediation plans—but writing documents with clarity is an art form. To improve your skills, avoid painful rewrites and produce great documentation, here are some simple tips:

Write to the least knowledgeable reader. Put yourself in the place of someone with minimal technical and accounting skills and explain processes in clear, simple language to that audience. Do not assume the reader will know what a control activity or test is.

Set up templates to standardize documentation and use consistent terminology. For example, always call an MIS department by the same name (not the “IT department” or “computer group” or both).

Make editing and reviews intrinsic parts of the documentation process. The time spent on the audit increases dramatically when management doesn’t perform documentation reviews, says a KPMG partner.

Be mindful of questions. Questions are an indication that you need to make issues clearer.

Write short sentences instead of long ones. Describe process flows, paperwork, software, control activities and procedures in brief concise language. Specify whether an item is a paper or a computer process.

Don’t use humor or subjective remarks. Avoid writing sentences such as “The overworked payroll clerk somehow manages to input a huge number of changes.” Stick to the facts.

Use active voice whenever possible. Passive voice can create ambiguities and confusion about who does what, which is crucial in evaluating internal controls. Passive : “The inputting of the changes is performed by the payroll clerk.” Active : “The payroll clerk inputs the changes.”

Use titles of positions instead of names. People may leave the company, but the position will remain.

Prepare a detailed table of contents or an index. They are helpful for looking up information such as specific control activities.

Be mindful of language differences if documentation will be used outside the United States. American jargon such as “shortcuts” and “downtime” may not be clear to professionals in other countries.

If possible, use samples to clarify and illustrate processes. However, beware of confidentiality issues and do not include sensitive information such as payroll data, signed forms or trade secrets.

Print the documentation and read it aloud. Many grammatical errors, misspellings and style issues become obvious when you read aloud. Do not rely only on spelling checkers.

Let the papers cool off. Before finalizing any documentation, set it aside for at least a day.

Think about taking a technical writing class. You can take one online, and it can be a good investment.

Source: Sheila Shanker, CPA, is a Sarbanes-Oxley consultant based in Culver City, Calif. Shanker’s Web site is www.geocities.com/sshanker34/index.html . Her e-mail address is sshanker2@hotmail.com .

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