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
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
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
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.
Sheila Shanker, CPA, is a Sarbanes-Oxley
consultant based in Culver City, Calif. Shanker’s
Web site is
Her e-mail address is firstname.lastname@example.org