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    FOR INTERNAL USE IN INDIAN AUDIT AND ACCOUNTS DEPARTMENT ONLY  

    MANUAL OF

    PERFORMANCE AUDIT

    (Revised Edition, 2009)

    Issued by

    Principal Accountant General (Civil & Commercial Audit), Kerala.

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    P R E F AC E

    With the revision of Auditing standards in 2002 and the issue of

    “Performance Auditing Guidelines” by the Comptroller & Auditor General of

    India (May 2004), the existing Manual of Efficiency cum Performance Audit

    (1998) needed revision. “The Guidelines” contain comprehensive implementation

    standards in relation to performance audit. This Manual, includes salient features

    of ‘The Guidelines’, consisting of, inter-alia, strategic planning in pursuit of

    realisation of goals and objectives, risk based planning and selection of subjects

    and attainment of the ultimate objective of value addition to the public sector

     programmes. It also contains orders/instructions issued by the Headquarters

    Office and this office for the guidance of staff engaged in performance audit.

     Nothing in this Manual shall be quoted as authority in correspondence

    with outside authorities.

    Suggestions for the improvement in the form and content of this Manual

    are welcome. The Manual of Performance Audit will be maintained and updated

    from time to time by the EPA(HQ) Section.

    Thiruvananthapuram S.NAGALSAMY

    Dated: 3.11.2009  Principal Accountant General (C&CA),Kerala,

    Thiruvananthapuram

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    C O N T E N T S

    Chapter Subject Page

    I General 1-10

    II Procedure for Performance Audit 11-33

    III Nature and drafting of Performance Audit Report 34 - 41

    IV Miscellaneous 42 - 49

    Annexures

    Annexure I 50

    Annexure II 52

    Annexure III 54

    Annexure IV 68

    Annexure V 70

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    1

    CHAPTER 1

    GENERAL

    1.1 Introductory

    SAI India has been carrying out performance audits, hitherto termed as

    ‘review’, or ‘efficiency-cum-performance audit,’ or ‘value for money audit’, over

    the past 40 years relating to the receipts and expenditure of the Union and State

    Governments, Government supported autonomous bodies and other public sector

    undertakings on a variety of subjects.

    1.2  Efficiency-cum-Performance Audit Section (EPA) was formed with effect

    from 1st

      January 1964, reorganizing the erstwhile Higher Audit Section. The

     purpose of the reorganization was to enable the section to devote more attention to

    Efficiency cum Performance audit of development schemes (Comptroller &

    Auditor General’s letter No.2806-Admn 1/8 codes 61 Vol.II dated 18.11.1963 and

    O.O.H.A/2-1.60-64/796 dated 1.1.1964).

    1.3  The existing guidelines for performance auditing have been fine tuned in

    the context by the ASOSAI performance Auditing Guidelines and INTOSAI

    Exposure Draft Implementation Guidelines for performance Auditing Standards

    and contemporary best practices. ‘Performance Auditing Guidelines-SAI

    India’(May 2004) replace, en-block, section III, Chapter 8 of the Manual of

    Standing Orders (Audit), in the context of performance auditing in SAI India. The

    Salient features of these guidelines consists, inter-alia, of strategic planning in

     pursuit of realization of strategic goals and objectives, risk based planning and

    selection of subjects and attainment of the ultimate objective of value addition to

    the public sector programmes. The guidelines also provide for a very high degree

    of interaction with the auditees. Close interaction with auditees is essential for

    realising value addition to the public sector programmes through performance

    audits.

    The instructions contained in Chapter 7 of Regulations on Audit and

    Accounts issued by Comptroller and Auditor General in January 2008 may also be

    referred to while doing Performance Audits.

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    §  the economy, efficiency, effectiveness, equity and ethics of the means

    used to implement a programme/ activity.

    §  The intended and unintended, direct and indirect impacts of

     programmes/ activities; for example, the environmental impact of

    government activity etc, and

    §  Compliance to applicable laws and regulations in the context of the

     performance audit objectives.

    Performance audit should not confine the objectives to ‘what has been

    done’ but also examine ‘what has not been done’ to meet policy objectives.

    Appendix-C of Performance Auditing Guidelines contains illustrative list of issues

    in performance audit of public sector programmes.

    Given the size, complexity and diversity of entity operations, it is

    generally not practicable to attempt assessment of the overall performance of

    departments or entities. Consequently, performance audits are usually directed

    towards specific functions, activities, programmes or operations of the entity.

    Performance audit findings are not a random assortment of various financial and

    regularity audit findings but an assessment of either the whole or part of the

     programme/subject/function/system.

    (Paragraphs 1.30,1.31 and 1.32 - Performance Auditing Guidelines-SAI I ndia)

    The Process

    1.6  The first stage in performance auditing is strategic planning for

     performance audits, which requires the development and maintenance of

    information on the entity that will assist in identifying potential areas for

     performance audit. Potential topics can then be analysed to form audit strategy

    documents. The EPA (HQ) section should formulate the annual operational plans

    in tune with the strategic plan.

    Once a subject has been selected, performance audit is initiated by

    developing a plan with the details for the conduct of the audit. The

    implementation stage of the performance audit involves:

    §  Development and execution of an audit programme

    §  Collection and documentation of sufficient, relevant and reliable

    evidence, including quantitative and qualitative analysis;

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    §  Development of audit findings, conclusions and recommendations

    and ;

    §  Development of discussion papers/draft field audit reports and

    confirmation of audit findings at exit conference.

    Every performance audit culminates in the development of a draft

     performance audit report containing audit findings and recommendations,

    confirmation, acceptance and comments, if any, by the entity and approval of the

    report within the SAI and presentation to Parliament/Legislature.

    Throughout each stage of performance audit, the objective should be on

    the production of a final report that is balanced and has value added impact. The

    report writing process should be viewed as a continuous one of formulating,

    testing and revising conclusions, if necessary. Therefore issues such as the

    expected impact and value of the audit, the likely improvements, better value for

    money and quality of expenditure resulting from the audit should be considered

    throughout the audit.

    (Paragraphs 1.50, 1.51, 1.52, 1.53 and1.54 - Performance Audit ing Guidel ines -

    SAI India).

    Mandate for Performance Audit

    1.7  The mandate of SAI India for audit is derived from the constitution of

    India, as established under the Comptroller & Auditor General’s (DPC) Act 1971.

    The mandate of Comptroller & Auditor General of India for performance audit is

    governed under Sections 13, 14, 15, 16, 17, 19 and 20 as the case may be, read

    with Section 23 of this Act.

    Annexure I contains instructions of the Government of India and Annexure

    II contains instructions by Government of Kerala issued to all

    Department/Autonomous Bodies/ PSUs to facilitate the conduct of performance

    audit by Comptroller & Auditor General.

    Duties and functions

    1.8  The Performance Audit Wing comprises EPA HQ section and EPA parties

    entrusted with the performance audits. The EPA parties each under the control of

    an Audit Officer/Senior Audit Officer and the HQ section headed by an Audit

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    Officer/Senior Audit Officer are under the charge of a Group Officer who is the

    designated supervisory officer.

    Supervision of performance audit involves ensuring that:

    §  the members of the audit team have a clear and consistent

    understanding of the audit plan;

    §  the audit is carried out in accordance with the auditing standards and

     practices of the SAI;

    §  the audit plan and action steps specified in the plan are followed unless

    a variation is authorised;

    §  working papers contain evidence, adequately supporting all

    conclusions recommendation and opinions;

    §  the auditor achieves the stated audit objectives; and

    §  the audit report includes the audit conclusions and recommendations as

    appropriate.

    1.9  Performance audit being more open to judgment and interpretations

    requires close and careful supervision. Supervision procedures and system of

    monitoring compliance for each assignment should be documented and got

    approved by the Prl Accountant General as part of the detailed operational

    guidelines.

    (Paragraphs 7.3 to 7.4 – Performance Auditi ng Gui del ines-SAI India)

    Structure of Supervision

    1.10  Supervision to be exercised at vari ous levels is as detai led under :

    §   by the group supervisory officer and the Prl Accountant General,

    during planning of individual performance audits;

    §   by the audit officer, during the course of field audit, further supervised by group supervisory officer; and

    §   by the Prl Accountant General during review of periodic reports,

    monitoring and interim appraisals at the close of the audit of a

     particular phase or unit.

    1.11  The key supervisory role for the performance audit planning,

    implementation of the audit and reporting rests with the group supervisory officer,

    who should be involved with all key elements of the performance audit process.

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    The performance audit and the process documentation should demonstrate the

    discharge of his/her supervisory role at each stage.

    1.12  All audit staff and officers are individually and collectively responsible for

    the quality of the audit reports. It is, however, imperative that the audit personnel

    understand the most important role that they have to play. The Audit team is

     primarily responsible for data collection. The Audit Officer and the Group

    Supervisory Officer are responsible for data analysis. Audit findings, conclusions

    and recommendations should be arrived at with the prior approval of the Prl

    Accountant General.

    (Paragraphs 7.5, 7.6 and 7.7.-Performance Auditing Guidel ines-SAI India)  

    Responsibil ity of the Supervisory Of f icer

    1.13  Some of the more important responsibilities of the supervisory officers in

    relation to performance audit are to ensure:

    §  that the work plan is executed with integrity and care in relation to the

    auditing standards;

    §  that the implementation of audit is carried out in accordance with the

    operational audit plan and all significant deviations, where necessary,

    are made with prior authorisation of the Prl Accountant General.

    §  adherence to the best practice contained in the performance Audit

    Guidelines-SAI India.

    §  documentation-both the performance audit documentation(working

     papers) as well as the performance audit process documentation, which

    demonstrate various actions and options considered and decided in the

    course of implementation; and

    §  the confidentiality and integrity of information obtained from the

    entity, persons and other sources are maintained and that the factual

     basis of information, description, analysis and recommendations are

    accurate and they are fair, balanced and well founded, that they are

    correctly communicated to the entity and the audit team is provided

    oral and written guidance in conduct of the audit.

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    Supervision by the Audit Of f icer of f ield audit party.

    1.14  The day to day supervision and control of the performance audit

     particularly the filed audit rest with the Audit Officer. Some of the more important

    supervisory responsibilities of the audit officers are:

    §  ensuring that the audit work is carried out in harmony with audit plan,

    more particularly in tune with the audit objectives;

    §  Identification of important issues in course of audit.

    §  Ensuring that no significant matters in the context of the audit

    objectives and evidence required, therefore, remain unresolved;

    §  Evidence collected fulfils the criteria prescribed in the Auditing

    standards;

    §  the work performed and the results including the process of audit are

    separately documented, first in support of audit findings, conclusions

    and recommendations and the second in support of due diligence

    exercised by the audit team; and above all

    §  Ensuring that the objectives of audit are fully met.

    Progress reporti ng

    1.15  The Audit Officer and Group Supervisory Officer will be responsible for

    reporting the progress of audit to the Prl Accountant General, at intervals as may

     be provided in the detailed audit implementation plan or as ordered by the Prl

    Accountant General. The progress report should contain all important information

    relating to the progress of audit, extent of data collection, sources of data

    collection, analysis of evidence, time spent in audit against the time allotted,

    dialogue with entity, problems encountered in the course of audit and modification

    applied to the audit plan, if any.

    The Group Supervisory Officer and the Audit Officer should also furnish

    assurance Memo, as prescribed by the Prl Accountant General, on completion of

    audit of each unit or stage in the performance audits.

    (Paragraphs 7.8 to 7.11 of performance Auditing Guidel ines-SAI India)

    1.16  The Group Supervisory Officer and the Audit Officer should discuss with

    the Prl Accountant General the progress of performance audit periodically and get

    his guidance.

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    Headquarters Section

    1.17.  EPA Wing comprises EPA (HQ) section and EPA Parties entrusted with

     performance audit of selected topics. EPA Parties each under the control of an

    Audit Officer and the HQrs section headed by an Audit Officer are under the

    change of Sr. Deputy Accountant General (Commercial).

    The following are the main items of work assigned to the EPA(HQ)

    section:

    (i)  Collection of various basic data, essential for performance audit,

    such as budget documents, plan reviews, study and evaluation

    reports, copies of important rules and orders and other publications.

    (ii)  Selection of topics for performance audit and their allotment

    among EPA parties.

    (iii)  Arrangement of preliminary studies of the schemes selected for

     performance audit and collection of details called for by the

    officers of the CAG/DGACR, PD(ESM) etc. relating to

     performance audits.

    (iv)  Communication of various instructions and guidelines on

     performance audit to the field parties from time to time.

    (v)  Coordination of the work by various EPA parties, monitoring the

     progress of performance audit and tracing its pace to ensure

    finalization of reports by the due dates fixed by the Prl Accountant

    General/Audit implementation plan

    (vi)  Finalisation of performance audit reports submitted by EPA

     parties, submission of the reports for approval by the Prl

    Accountant General with such details as are required and

    forwarding copies of the reports to the officers concerned

    (vii)  Furnishing copies of performance audit reports and such additional

    details, as are required by Report(Civil) section to finalise draft

     paragraphs based on the performance audit and supplying

     performance audit files to Report(Civil)for reference when called

    for.

    (viii)  Review of audit reports of the Union Government and other

    States/UTs with a view to seeking guidance for selection and

    conduct of performance audit.

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    (ix)  Maintenance of prescribed registers/records.

    (x)  Submission of tour programmes of EPA parties for the approval of

    the Group Supervisory Officer.

    (xi)  Checking TA claims of field parties with approved tour

     programmes, tour diaries, leave account, etc.

    1.18.  In order to watch the progress of work connected with performance audit

    EPA(HQ) section should maintain a register showing the names of schemes

    selected for performance audit, details of allotment among various parties, the

    stage of work from time to time, details of performance audits finalised, details of

    issue of copies of performance audit reports etc. This register should be submitted

    to the Prl Accountant General on the 15th of every month.

    The responsibility for keeping this Manual up-to-date rests with

    EPA(HQ)/Section.

    1.19.  The general instructions in the Manual of the Outside Audit Department

    applicable to OA(HQ) and OA Parties will apply mutatis mutandis to EPA(HQ)

    and EPA parties.

    Leakage of i nformation

    1.20.  Performance audit of a scheme may often involve probing into policies of

    governments. It may happen that the facts brought to light may be such as will not

     be in public interest to be divulged to any but officers competent to deal with them

    finally. Leakage of information on such points will not only cause considerable

    embarrassment to the Government but also result in possible damage to the

     prestige of this office. It has therefore, to be ensured that cases dealt with by the

    EPA wing are processed with utmost secrecy and tact notwithstanding the fact that

    they may be eventually brought to the notice of the Legislature/Parliament

    through the report of the C&AG. The instructions laid down for dealing with

    secret documents should be observed by all the members of the staff in dealing

    with such cases.

    Data coll ected by Audi t

    1.21.  Data collected by Auditor either directly or through consultants or through

    other sources engaged to carry out surveys etc. in connection with Performance

    Audits should not be made available to any other individual or organisation.

    (H eadquarters Off ice order No.391-Rep(C)/141-2006 dated 15 November 2006)

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    CHAPTER II

    PROCEDURE FOR PERFORMANCE AUDIT

    2.1  With the attainment of independence, the role of Government as just a

    “law and order” and “revenue collections” agency has enlarged and the activities

    of the Government embrace multifarious functions and developmental

     programmes covering almost all sectors of the State economy. This has

    necessitated a reorientation of the approach of audit. Regularity and propriety

    audits generally applied to individual transactions are not adequate for

    assessments of the performance of a plan, project, programme, scheme or

    organization in terms of its goals and objectives. The approach of audit has

    therefore been reoriented. Comprehensive performance audit of the ongoing

     projects, schemes, etc. in terms of their goals, objectives and programmes is

    conducted to see how far the expected results have been achieved using the

    available resources of men, material and money. Performance audit assesses and

    evaluates the economy, efficiency and effectiveness of development schemes,

     projects or organizations.

    2.2  Performance audit is directed to examining the systems, procedures,

     planning, implementation and operational performance of programmes, activities

    etc. bringing out among other things, weaknesses and deficiencies as also lapses

    of various types including those relating to individual transactions for appropriate

    action. The audit envisages a comprehensive review of the project/scheme/activity

    to ascertain:

    (i)  how far the physical and financial targets have been achieved.

    (ii)  how far the social and economic objectives have been realized.

    (iii)  whether the operations are conducted economically(iv)  whether there are any cases of overpayment, loss, extravagance,

    avoidable excess or infructous expenditure due to improper

     planning, delay in completion of projects, overstaffing, over-

    capitalization, unsound pricing policy, idling of assets etc. and

    (v)  Whether the utilization of the resources is in accordance with the

     projected outlays and if not, the reasons therefor.

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    2.3  It is neither practicable nor desirable to conduct performance audit on pre-

    determined lines as schemes differ in their concepts, techniques of performance,

    nature of objectives etc. Information available for analysis may also differ.

    Selection of subj ects

    2.4  The selection of the projects/schemes for performance audit should be

    done with utmost care after making a preliminary study and taking into account

    the various factors apart from the financial outlay involved. It is desirable that

    schemes which are going on for atleast two to three years are taken up for

     performance audit.

    2.5  EPA(HQ)section should carryout an indepth exercise for performance

    audit strategic planning. After setting the strategic goals and objectives, the data

    on entity contained in budget papers, programme papers, plan documents, annual

    reports, parliamentary debates and reports, media concerns, research and reports

    of international agencies, follow up and leads from past audits etc. should be

    analysed on the parameters of risk, materiality, significance, visibility, coverage

    etc. to select subject for performance audits to be carried out over the strategic

     plan period.

    2.6  It is not always necessary to conduct performance audits of the entity or

    the programme as a whole. EPA(HQ) section should select a mix of performance

    audit subjects covering either the programme or activities of the entity

    comprehensively and the subjects for which the scope and audit objectives are

    confined only to significant aspects of the programmes or activities. The selection

    of the components or parts of the programme may be guided by the materiality

    and risk profiles. This will enable Audit to increase the coverage to large number

    of relatively more important and contemporary issues, which may be expected to

    enhance the perceived and actual value addition through performance audits. One

    of the options could be to conduct performance audits of various components of a

    large programme or entity in the form of series, covering a few aspects every year.

    2.7  The subjects of performance audit may also be selected cutting across

    various departments or entities. This will provide a platform for performance

    audit on a theme or thrust area over a cross-section of entities, who are entrusted

    with the responsibility for the programme, activity etc.

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    2.8  While the amount of expenditure or revenue associated with a programme

    or function is a significant consideration for selection of a subject, we may also

    select topics for which there is either no budget or these are insignificant, or

    whose materiality cannot be determined with reference to expenditure, receipts or

    assets and liabilities only. Yet, the subject or the deficient performance could

    affect a large or vulnerable section in a significant manner. Most of these issues

    may relate to governance or good governance (examples: system of ensuring

    quality control and assurance of quality of drugs, prevention of adulteration of

    food and beverages, quality of information, communication and delivery of social

    service benefits etc.) Selection of such subject will demonstrate the sensitivity of

    audit to the governance issues and people-centric issues.

    2.9  While performance audit is mainly a posteriori exercise, there is no bar to

    conduct performance audit of programmes, concurrently or at the initial stages of

    the implementation of the programmes, in cases where the risk and materiality are

     perceived as being significant. Concurrent performance audit of long-term on-

    going schemes should be undertaken at appropriate intervals.

    2.10  Active co-operation of the concerned departments and their proper

    appreciation of the performance audit undertaken is essential for a meaningful performance audit. As such pre-performance audit enquiries may be held with the

    departmental authorities soliciting suggestions regarding areas and aspects to be

    taken up for study and assistance in making available the records and data. The

    suggestions regarding schemes to be taken up for performance audit may be

    collected from Group Officers/Branch Officers of various sections also.

    2.11  The following documents should also be referred to at the time of selection

    of topics for performance audit.

    (i) Performance Audit suggested by the Comptroller & Auditor

    General, DGACR etc.

    (ii) Portfolios maintained by Central Audit Sections and

    EPA(HQ)Section.

    (iii)  Performance Audit, if any, suggested by the State Government/

    P.A.C

    (iv)  Press cuttings(v)  Performance Audit Reports of other states.

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    (vi)  Review Files on Administration reports of Departments

    2.12 All the performance audits suggested by the CAG should be taken up and

    number of other subjects may be suitably decided based on human resources

    available.

    (HQs Letter No.D3-R(s)/1988 No.REP(S)/183-86 dated 7.3.1988).

    2.13  The list should include:

    (a)  Performance Audits suggested by the Comptroller & Auditor

    General/DGACR etc.

    (b)  Performance Audits already approved by the Comptroller &

    Auditor General but could not be completed and performance

    audit already approved in advance and proposed for the current

    year.

    (c)  Additional performance audits proposed for the year.

    2.14.  Performance Audit Topics proposed for inclusion in State Audit Report

    have to be sent to CAG’s Office by such dates as intimated by HQrs. For this

     purpose the process of selection of topics has to be started sufficiently early. For

    getting suggestions from State Government, letters are issued by EPA Hqrs to

    Government Secretaries of important departments like Finance and Planning and

    Economic Affairs in September/October each year. Suggestions are also invited

    from all Group Officers. Topics suitable for Performance audits are also identified

     by EPA Hqrs from budget documents, administrative reports, plan documents etc.

    From the list of topics available eight to ten topics are short listed for further

    examination. While selecting these topics the following factors may also be

    considered.

      Topics which have been reviewed during the last five years may not beconsidered

    •  Schemes/Projects which are nearing completion may not be considered

    •  Schemes/Projects the implementation of which is the responsibility of

    Local Self Government Institutions may not be considered.

    •  Priority should be given to schemes where performance audit can have

    significant impact.

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    Preliminary study of the short listed topics is to be conducted by deputing

    EPA Parties. The Party may make an assessment of the topic by visiting a few

    offices implementing the Project or Scheme and submit a report containing

    information on the funding, organizational set-up, components of the scheme,

    schedule of implementation, progress so far etc. and submit a Report, explaining

    the suitably of the topics for performance audit.

    From these topics so studied three or four topics are to be selected. The

    number of topics would depend on the instructions received from HQrs. The final

    selection would be made based on factors like financial materiality, significance, 

    visibility, past performance audits as well as regularity audits, estimated impact,

    coverage, stage of programme development etc. The topics selected would be

    submitted for approval of Prl. Accountant General and forwarded to CAG’s office

    within the prescribed time.

    On receipt of approval of HQrs letters would be sent to the Secretaries of

    the Administrative Departments of Government which are responsible for

    implementation of the scheme/ project intimating the decision to undertake the

     performance audit. The Secretary would be requested to issue necessary directions

    to the subordinate offices as contemplated in Government circulars No52/2006/Fin dated 13.November 2006. An entry meeting is to be held with the

    Secretary of the implementing department to discuss the audit plan and

     programme. Minutes of the meeting signed by Prl. Accountant General and the

    Secretary should be kept for record

    Pil ot study/preliminary survey

    2.15.  It is a good practice, particularly for relatively larger programmes, to

    conduct a pilot study in one or two representative units of the entity to assist the

     performance auditor in refining the risk analysis, audit objectives, audit criteria,

    audit approach and audit test programme. In some cases, the result of pilot study

    may necessitate more intense field audit and in others, the result may lead to either

    defer the audit or abandon it for one or more reasons. Some illustrative findings

    of the preliminary study could be: special skills and more time required for

    finalization of the guidelines, higher risk perception, the subject being difficult

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    from the auditability angle, sensitive subject from one or other points of view,

    very low risk or materiality and negligible perceived impact of audit. The topics

     proposed for Performance Audit are assigned to EPA Parties for pilot study. The

     pilot study should be completed within one month. The Party may visit offices

    connected with the implementation of the scheme/project, collect necessary

    documents, hold discussion with the implementing officers so that an overall

    idea on the scheme is obtained for preparation of detailed guidelines.

    The objective of the Pilot study is to have a comprehensive insight into the

     broad picture obtained at the time of initial selection to locate areas requiring in-

    depth examination. The following list illustrates some of the documents which

    will facilitate study of a scheme.

    (1)  Plan outline, Annual Plan budget and accounts of plan expenditure.

    (2)  Annual Budget documents

    (3)  Accounts

    (4)  Economic Review

    (5)  Administrative Reports of Departments implementing the scheme

    (6)  Project Reports

    (7)  Acts, Rules, Departmental Manuals, Reports and Brochures

    (8)  Any special published document pertaining to the scheme (issued

     by Research Cells of University, Department etc.)

    (9)  Evaluation Reports by the Planning Board.

    (10)  Reviews of plan schemes published by the planning Board.

    (11)  Review by the R.B.I

    (12)   News paper cutting

    (13)  Important reported judicial decisions.

    (14)  Audit Reports of other states(to see whether similar scheme has

     been covered)

    (15)  Audit Reports (Civil) of Kerala State for earlier years and Audit

    Reports for Revenue Receipts/commercial undertakings.

    (to see whether the scheme has been reviewed already in whole or

     part)

    (16)  Reports of the Public Accounts Committee.

    (17)  Reports of the Committee on Public Undertakings

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    (18)  Inspection Reports of the Departments implementing the

     programmes.

    (19)  Portfolios required to be maintained in Central Audit.

    (20)  Secretariat files

    (21)  Departmental files

    2.16  While conducting performance audit of a programme, it is necessary to

    understand the nature of the programme right from the stage it was conceived.

    During the pilot study, it should be seen :

    (i) Whether adequate survey was made before launching the project

    (ii) Whether proper feasibility report was prepared

    (iii) Whether there exists a detailed project report and details of

    deviations, if any, available.

    (vi)  Whether the specification and performance of the various items of

    equipments were properly matched

    (vii)  Whether there were proper procedures for inventory control and

    material management, ie. whether an effective system of material

    management existed

    (viii) Whether contract systems have been laid down

    (ix)  Whether there were any operational problem and if so, how it was

    got over

    (x)  Whether the project was functioning as it should be

    (xi)  What were the areas where it was being implemented and who were

    the implementing agencies.

    2.17 The results of the pilot study should be submitted to the Prl Accountant

    General within the time allowed and his instructions obtained for the conduct of

    detailed performance audit.

    Perf ormance Audit -Implementation

    2.18  The approach of audit should be systematic, methodical, logical and

    rational. “The Performance Auditing Guidelines” (Comptroller and Auditor

    General of India-May 2004) contain a frame work for the entire process of

     performance auditing. They provide the best practices that the SAI must follow in

     planning, implementation, reporting, follow up processes and quality assurance in

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    all performance audits. They outline consistent principles, objectives, approach,

    methodology, techniques and procedures for performance audits.

    2.19  The phases of performance audit can be categorized as:

    (i)  Strategic planning for performance audit (Chapter 2 of the Guide

    lines)

    (ii)  Initiating performance audit (Chapter 3)

    (iii)  Implementation (Chapter 4 & 5)

    (iv)  Reporting Process (Chapter 6)

    (v)  Supervision, review and quality control (Chapter7)

    (vi)  Follow up procedures (Chapter 8)

    (vii)  Quality assurance in performance audit (Chapter 9)2.20  While all steps and actions in performance audit process consisting of

     planning, implementation, reporting and follow-up are important and must be

    negotiated deftly, the most critical among them are outlined below with the

    objective of at a glance recapturation (critical issues in performance audit-Chapter

    10 –The Guidelines). The crucial issues are presented in two sections. The first

    section contains the important considerations in the context of management of

     performance audit and consists of steps that must be traversed and documented to

     provide assurance of consistent high quality of audit. The second section consists

    of the most crucial issues in relation to techniques and documentation that should

     be applied to performance audits. It should be noted that the list is not exhaustive

    and must be understood in the context of the detailed expositions in Chapters 2 to

    9 of the Guidelines. The list of issues will assist the group supervisory officer, the

    audit officer and the audit team to ensure the quality of audit, monitor and review

    the crucial procedures in management and implementation of performance audits.

    Section I: Audit Management Issues

    2.21  Mandate for performance audit

    §  Mandate under the Constitution of India and Comptroller & Auditor

    General’s (DPC) Act 1971

    §  Section of the Act under which a particular audit is covered, read with

    Section 23 of the Act; and

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    §  Mandate strengthened through convention-performance audits carried

    out over the past 40 plus years on a variety of subjects, the reports on all

    of them having been presented to the parliament and state legislature.

    2.22  Strategic planning for performance audit.

    §  Strategic planning for performance audit is not the same as the strategic

     planning of SAI India, but should be consistent with it.

    §  Set strategic goals and strategic objectives to be achieved through

     performance audits;

    §  Prepare performance audit strategic plan to fulfill the strategic goals and

    objectives and document how the selected performance audits will

    accomplish them.§  Prepare comprehensive directory of data sources, collect and update all

     possible data that assist the strategic planning:

    §  Ensure that the strategic goals and objectives are set in the context of

     perceived risks and materiality of issues of financial, non financial or

    governance nature;

    §  Be alive to the major policy shifts affecting the governance and large

    sections of public and select cutting-edge and sunrise subjects for

     performance audit;

    §  Prescience of the policy shifts and anticipation of the risks associated

    with the policy shifts and emerging national or internal environment

    demonstrate the cerebral capability of the institution; and

    §  Plan performance audits in time to ensure value addition to the

    management of the programmes.

    2.23  Annual operation plan

    §  Consists of the performance audits of the subjects, including the subjects

     brought forward from the previous years that are to be implemented

    during the year;

    §  Provides an opportunity to review the plan in the light of new

    developments and risk assessment since the approval of strategic plan;

    and

    §  Provides a basis for assessment of the performance of the Audit Offices

    on annual basis and affords an opportunity to assess and re-assess the

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    skill and knowledge required and those available in-house which forms a

     basis for training programmes, engagement of consultants/experts and

    outsourcing.

    2.24 Performance audit implementation of plan

    §  Gather all relevant data and documents to understand the entity and the

     programme;

    §  Intimate the entity about the intent to carry out the performance audit.

    §  Facilitate/persuade formal presentation by the entity to explain the

    various aspects of the programme;

    §  Invite representatives of other departments/agencies which have a stake

    in the programme by way of provision of funds, evaluation, etc;§  State the reasons for conducting the performance audit by setting out

    audit objectives and sub-audit objectives;

    §  Set audit objectives in the form of complete statement of questions, the

    answer to which will satisfy the reasons for conducting the performance

    audit;

    §  Set audit objectives under distinct themes and sub-themes with reference

    to programme objectives, further developed in the context of audit

    concerns;

    §  Specify the audit concerns of economy, efficiency and effectiveness that

    the audit objectives and sub-audit objectives address individually or

    severally as also the equity and ethics aspects, in so far as they affect one

    or more of the primary concerns of economy, efficiency and

    effectiveness;

    §  Set quantitative and qualitative audit criteria against which the

     performance will be tested to develop audit findings;

    §  Set one or more criteria for each audit objective or sub-objective;

    §  Identify tentatively the evidence/data required to be collected for testing

    each criteria;

    §  Identify sources of data and determine the methods of data collection;

    §  Plan for procurement of expert advice or the services of consultant;

    §  Assign duties and responsibilities; and

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    §  Make a formal presentation to the entity of the audit plan, including the

    audit objectives, criteria, evidence required and tentative location of

    audits and invite the representatives of other concerned departments also.

    2.25 Use of expert, consultant and outsourcing

    §  Document transparently the assessment of knowledge and skill required

    for each performance audit;

    §  Examine and document how the required skill can be fully met in-house;

    without compromising audit quality; and

    §  Follow the procedure in vogue within the SAI in the matter of procedure

    for procurement of services of expert/consultants.

    2.26 Entity consultation, cooperation and response

    §  Entity cooperation and response being the hallmark for the success of

     performance audits, Prl Accountant General will be called upon to adopt

    a persuasive approach to attain goal-matching;

    §  Rather than quitting in the face of inadequate response, the objective will

     be to continue making efforts with a view to making such cooperation a

    routine in time to come;

    §  The methods of persuading the entity for full cooperation is left to the judgment of Prl Accountant General;

    §  The cooperation of the entity is not to be confused with agreement on all

    issues. Recognition of possibility of difference in opinion and its

    resolution is inherent in cooperation;

    §  Entity cooperation and response should be obtained throughout the

     performance audit process-from the intimation of the intent to the

    recommendation and finally to the implementation of therecommendations and

    §  Entity cooperation is to be secured through a series of transparent

    measures:

    ♦  Sharing of the subject selected for performance audit in the

    strategic plan with the Secretary;

    ♦  Intimation to the Secretary when the subject is taken up for

     performance audit;

    ♦  Presentation by the entity for understanding the subject;

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    §  A summary of the results of quality assurance reviews should be

     published highlighting good practices for emulating and deficient

     practices and procedures to be addressed for improvement.

    2.30 Duties, responsibilities and accountability

    §  The duties and responsibility of each member of the audit team, audit

    officer and supervisory officer shall be stated clearly with reference to

    compliance to the prescribed procedures, professional conduct, field

    audit, evidence/data gathering, quality of data and documents,

    documentation, dialogue with entity, audit test, audit findings,

    recommendations, guidance to the team members, monitoring,

    supervision, reporting and preparation of reports etc.§  A review may be made during the course of audit and upon conclusion

    of the performance audit on the quality of fulfillment of the

    responsibility by the performance audit team members and supervisors;

    §  Assessment of the quality of audit and the performance of audit

     personnel for each procedure, data collection, data analysis,

    documentation and output during the performance audit cycle enhance

    the quality of performance audit.

    2.31 Process documentation

    §  Process documentation of all management actions and judgments may be

    retained throughout the audit to provide a trail for review of management

    actions;

    §  The process document should contain all considerations that do not form

     part of the working papers for the performance audits in support of the

    audit findings, conclusions and recommendations; and

    §  The more important among the process documentation, which

    demonstrates management actions, should be sent to SAI top

    management with the draft performance audit report along with the

    assurance memo in the format prescribed by SAI top management.

    2.32 Impact evolution of performance audits

    §  All performance audits will be conducted keeping the expected impact

    on the programme in mind. The expected value addition- qualitatively

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    and quantitatively - will be estimated before taking up the performance

    audits;

    §  Impact evaluation against the expected impact of each performance audit

    and collectively for all performance audits conducted by the Prl

    Accountant General shall be carried out annually; and

    §  The impact evaluation will be carried out with reference to the

    recommendations accepted and implemented.

    Section II: Critical technical issues in performance audits

    2.33 Fundamental principles

    §  Performance audit is an assessment of efficiency and effectiveness of the

     programmes, with due regard to economy;

    §  Addresses the issues of inputs, processes, outputs (products) and

    outcomes (impact);

    §  Apart from the question whether the things are being done the right way,

    it also addresses the question of whether the right things are being done,

    in other words, it also focuses on what is not being done rather than only

    on what is being done;

    §  Performance audits also address the issues of equity and ethics, which

    impacts one or more of the core concerns of economy, efficiency and

    effectiveness and include, apart from other, integrity in preparation of

     performance reports;

    §  Distinction between regularity and performance audit should always be

    kept in mind;

    §  Performance audits are undertaken with the objective of improving

     performance of public sector programmes and, therefore, in assessment

    of the expected impact-qualitative and quantitative-on the programme

    must be made before undertaking the audit;

    §  The subjects selected for performance audits could be a programme,

    segments of a programme-including the processes, procedures and

    systems, an entity itself or parts of an entity. etc.;

    §  The subjects of performance audits could be financial, non-financial or

     public interest and governance issues.

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    §  The subjects selected for performance audits should include cutting edge

    issues that form the core of governance and sunrise issues in the light of

     policy shifts;

    §  Prescience of the risks to programmes or public interest demonstrates the

    competence of the institutions;

    §  Performance audits can be carried out posteriori or concurrently;

    §  Performance audits use many techniques used in programme evaluation;

    §  While the performance audit may and should assess the implementation

    of the policy through one or more programmes, the scope of audit should

     be limited to assessing the impact of the implementation of policy and

    the policy per se should not be questioned;§  Performance audit conducted in time, when there is scope for remedial

    measures is encouraged; and

    §  Performance audits being knowledge-based exercise, in which

    conclusions emerge from interpretations, call for special skill,

    knowledge and competence of the audit personnel.

    2.34 Audit Plan and programme - detailed guidelines for conduct of audit

    §  The detailed audit implementation guidelines will consist of all relevantinformation and document required for complete understanding of the

    entity, besides the audit objective, criteria, types and sources of evidence

    to be gathered, audit test programme, delineation of duties and

    responsibilities among team members and supervisors, progress reports

    etc.;

    §  The implementation guidelines should be such as to address all issues

    designed in the prescribed structure; and

    §  Unless authorised by general or special order, the performance audit

    guidelines will be approved by SAI top management.

    Each topic approved for Performance Audit would be assigned to one or

    more EPA Parties. Usually the Party which did the pilot study would be assigned

    the topic. Based on the Pilot study the Party is required to prepare detailed audit

    implementation guidelines. The guidelines should inter alia specify the

    manpower requirement, time frame of completion, coverage, sample selection

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    method, size of sample, audit objectives, audit criteria etc. The time frame in the

    guidelines should be such that the Report is finalized within the overall time

    limit prescribed by CAG’s office for submission of Performance Audit Reports.

    The guidelines approved by Prl AG are forwarded to CAG’s Office for approval.

    Changes suggested on comments of HQrs on the guidelines should also be

    considered while conducting performance audit.

    For All India Performance Audits the detailed guidelines are received from

    DGACR, PD(ESM), PD(SD) etc. and the audit is to be carried out strictly as per

    the guidelines and adhering to the prescribed time schedule.

    2.35 Audit objectives

    §  Audit objectives will be the focus of field audit and data collection;

    §  All audit objectives and sub-objectives will address one or more of the

    core audit concerns of economy, efficiency and effectiveness and the

    concerns addressed by each audit objective and sub-objective will be

    identified against each of them;

    §  The evidence testing will also revolve around the audit objectives; and

    §  Audit objectives need not be limited to testing of the programme

    objectives. The audit objectives go much beyond the programme

    objectives to test the programme for economy, efficiency and

    effectiveness. (Annexure III)

    2.36 Audit criteria

    §  Audit criteria are performance measures against which the evidence is

    tested for arriving at the audit findings and conclusions;

    §  For each audit objective or sub-objective there must be at least one

    criterion and testing on more than one criteria against the same audit

    objective enhances the acceptability of audit findings and makes them

    convincing;

    §  Audit criteria should be acceptable to the entity;

    §  In the event of disagreement in a few cases, it may be a good practice to

    request the entity to suggest alternative criteria;

    §  All possible sources of criteria should be consulted to arrive at the best

    fit;

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    §  Criteria developed by or in consultation with the experts of repute

    assume enhanced credibility and are easily acceptable;

    §  Institutional consultancy for criteria and for other consultancy or advice

    in the performance audits have better credibility and acceptance;

    §  Performance criteria prescribed in the programme or later developed by

    the entity should be tested for appropriateness and unless otherwise

    established that they may hide underperformance or over-pitch the

     performance, these should be adopted in performance audits;

    §  Performance audits need not confine to the entity established criteria, but

    should go beyond to establish more criteria to provide tests for all audit

    objectives and sub-objectives; and

    2.37 Audit evidence for testing against criteria

    §  All data and evidence to be gathered will, as far as possible, be

     predetermined with reference to each criterion, which are intrinsically

    lined to each audit objective or the sub-objective;

    §  The sources and location of data/audit evidence and method of gathering

    them shall be determined in the audit implementation plan;

    §  Evidence in support of each audit finding will be transparently tested on

    the standards of relevance, competence and sufficiency (reasonableness)

    in the working papers;

    §  The secondary evidence viz. surveys, photographs, physical inspection,

    etc. should be corroborative and should not form the only basis of audit

    finding, unless accepted by the entity;

    §  Prl Accountants General are encouraged to identify secondary/

    corroborative sources of evidence and establish means for gathering

    them with the approval of the SAI top management; and

    §  They may also determine approach and methodology for physical

    verification in programmes in which asset verification and beneficiary

    survey are crucial inputs to establish the actual delivery of the output and

    the quality of output/delivery. While nothing prevents physical

    verification by audit team, the question of credibility and acceptance

    should also be taken into account, since physical verification by audit

    team may, sometimes, be contested later as incorrect. Some of the

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    methods that could be considered are joint physical inspection with

    attestation from both sides, survey by reputed agencies etc.

    2.38  Sampling

    §  The audit findings should be based on objective sampling and thesampling techniques used should be disclosed;

    §  As far as possible, statistical sampling techniques should be used;

    §  Assistance of statistical adviser in the SAI headquarters may be obtained

    for statistical sampling and

    §  Adequate sample size should be selected to be able to generalize the

    audit findings and be able to meet the standards of sufficiency.

    2.39 Audit findings

    §  Audit findings should be developed on the basis of audit tests carried out

    on the sample;

    §  Audit findings should be in the context of the audit objectives and

    criteria.

    §  The causes of underperformance should be determined to be able to

    recommend remedial measures; and

    §  All evidence used for audit findings should be tested transparently or thestandards of relevance, competence and sufficiency and the basis on

    which the satisfaction of fulfilling the standards is established, should be

    documented in the working papers.

    §  Audit findings should be discussed with the Secretary of the

    implementing department of State Government during the exit meeting.

    For this purpose a copy of the draft report will be forwarded to the

    Secretary from EPA (HQ)rs. The minutes of the meeting signed by thePrl. Accountant General and the Secretary should be kept for record.

    2.40 Recommendations and follow-up procedure

    §  All audit reports must contain recommendations arising out of audit

    findings and the cause of audit findings;

    §  As the performance audit revolves around the audit objectives, the

    follow-up procedure is built around the recommendations and the impact

    of performance audit is measured on the basis of implementation of the

    recommendations; and

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    §  Follow up procedure is conducted with reference to the information on

    the implementation of the recommendations and the quality of

    implementation of recommendations through a more detailed follow up

    audit.

    2.41 Supplementary Guidelines and practice Guide Series

    In addition to the performance Auditing Guidelines, HQ have issued

    supplementary Guidelines on Evidence Gathering, Analysis and Evaluation

    Techniques and five Practice Guides for guidance during performance audit.

    Salient features are given below. For details refer to the respective publications.

    A.  Supplementary Guideline I on Evidence Gathering, Analysis and

    Evaluation Techniques

    After audit objectives and criteria are finalised following steps are taken to

    determine the appropriate data collection technique to be used.

    a. Determining the data that will answer the audit objectives/questions

     b. Identifying appropriate sources/types of data which are cost effective

    and defensible

    c. Deciding on suitable methods for collection of data

    d. Analysis of data collected

    Some methods other than those given in Appendix D of Performance

    Auditing Guidelines commonly used for evidence gathering are given below.

    a.  Observation /photos

     b.  Searching the database of literature on the subjects

    c.  Programme/entity database and files

    d.  questionnaires

    e.  expert opinionf.  using results of other studies and audits

    Evidence evaluation and analysis

    Evidence may be evaluated on the basis of its persuasiveness, meaning the

    confidence it offers the auditors in reaching conclusions with respect to audit

    objective.

    Following provide a structure for measuring persuasiveness

    i.  Relevance

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    ii.  Objectivity

    iii.  Documentation

    iv.  Externality

    v.  Sample size

    vi.  Sampling method

    vii.  Corroboration

    viii.  Timeliness

    ix.  Authoritativeness

    x.  Directness

    xi.  Adequacy of controls

    B. 

    Practice Guide Series I Audit of Procurement

    Main points to be looked into while conducting performance audit of

     procurement are:

    •  Policy guidelines and documentation

    •  Record management and documentation of purchase /procurement

    •  Requirement /provisioning

    •  Rate analysis/estimated rates

    •  Inviting tenders, tender documents, correction/changes in tender

    documents, receipt and opening of tenders, system transparency.

    •  Post tender negotiations, advance payment, performance guarantee

    etc.

    •  contract management – price variations, delivering, taxes and duties,

    warranty, dispute reconciliation.

    •   post contract management – monitoring, inspection, user readiness,

    dilution of contract terms

    C.  Practice Guide Series 2 Audit of Poverty Al leviati on Programmes

    Important points to be examined during the performance audit of Poverty

    Alleviation programmes (PAP) are:

    •  Proper formulation of programme

    •  Targeted beneficiaries correctly identified

    •  Financial planning and funds management at various levels•  Works - generation of employment and creation of durable assets

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    •  Execution of work – economic, efficient and effective

    •   Non exploitative and dignified working conditions

    •  Utilization of funds earmarked for weaker sections

      Payment of wages and supply of food grains•  Generation of income through micro enterprise development

    •  Identification of site for dwelling

    •  Flow of credit and subsidy

    •  Drinking water and sanitary schemes – implementation

    •  Monitoring at various levels

    D.  Practice Guide Series 3 Audi t of Contr act Management

    Following main points are to be covered during the performance audit of

    Contract Management.

    •  System for project appraisal

    •  System of selection and classification of contractors

    •  Tender procedures

    •  System of review of conditions of contracts and tender documents

    •  Periodical financial reporting covering work done, payments made etc.

    •  System of on site control regulating valuations of work for interim

     payment

    •  System for examining and controlling price fluctuations and variations.

    E.  Practice Guide Series 4 Planning Individual Performance audits

    In addition to the guidelines issued in Performance Auditing Guidelines,

    the practice guide discusses in detail various stage in planning individual

     performance audits. Main points are:

    Audit objective

    Limit the number of audit objective to five at the maximum and sub

    objective to five. A question should not be broken down into more than five sub

    questions. Each question should address an independent area. Taken together all

    the questions should satisfy the audit objective completely.

    Audit criteri a  should be 

    specificMeasurable / quantitative

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    Agreed by entity

    Free from auditor’s bias

    Clear, understandable and comparable.

    F.  Practice Guide Series 5 - Outsourcing : Use of consultants

    Following sequences in the process of appointing consultants are

     prescribed:

    a) Determining the need for a consultant

     b) Identifying and engaging the consultant

    c) Monitoring the work of the consultant

    d) Evaluation of final out put

    Determining the need for a consul tant

    Services of consultants can be used for advice and guidance on a specific

    issue before audit or for carrying out specified tasks on behalf of Audit.

    I denti fying and engaging consul tants

    GFR and Manual of Policies and Procedure of Employment of Consultants

    issued by GOI in August 2006 are applicable which cover the use of -

    Individual consultants

    Consulting firms

    Universities and research organizations

    Government agencies and

     Non – Governmental organizations

     Engagement of consultant is normally done in two stages:

    a) by inviting expressions of interest and

     b) by asking the short listed consultants to submit technical and financial

     proposals.

    Monitori ng the work of consul tants can be done by

    a) Appointing a nodal officer

     b) Through a work plan to be approved before commencing work

    c) Consultants interaction with auditee

    Evaluation of work done by the consultant

    Final compliance by the consultant with contract engagement would be

    carried out using commonly applicable bench marks of completeness of work,

    availability of inputs when required, reliability, usability, accuracy, timeliness,

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    flexibility and responsiveness in reaching departmental requirements, maintenance

    of confidentiality and overall satisfaction.

    CHAPTER - III

    NATURE AND DRAFTING OF PERFORMANCE AUDIT REPORT

    3.1 Nature and drafting of Performance Audit Report

    Chapter 6 of the Guidelines deals with the reporting process from

    discussion papers to draft performance audit report, forwarding of the draft report

    to the entity for confirmation, acceptance and comments, if any, procedure for

    approval of performance audit report within the SAI and presentation to the

    Parliament, Legislature etc. Thus the reporting process begins with discussion

     papers, navigates through the stages of audit observation, field audit report and

    ultimately to the draft performance audit report and the final report. While every

     performance audit is to culminate in development of a report containing the audit

    findings and recommendations, report writing is to be viewed by the performance

    audit teams as a continuous process.

    3.2 The performance audit teams should keep the following in mind during

    audit as well as at the time of finalising the report.

    Ø   Audit comments should be based directly on the information contained in

    departmental records so that the department may not contest later. When it

    is not directly evidenced, audit enquiries should be issued and the facts and

    figures got accepted by the departmental officers. The field officers

    should take action to get timely replies to the audit enquires. In case the

    replies are not received till the finalization, it should be mentioned in the

    report that information called for by audit (period) has not been received

    from the department till then (period). The data collected or obtained from

    departmental offices and unit offices should be consolidated.

    Ø   The emphasis should be on quality than on lengthy narration. More stress

    should be on analysis of the strength and weakness of the organisation.

    The performance audit should encompass economy, efficiency and

    effectiveness of the project/scheme. The report should be so balanced that

    among other things, points from financial audit as well as achievements ofsocial objectives/aspects of the scheme are highlighted.

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    Ø   There may be some plus points in favour of the project authority. The

     positive aspects noticed in the performance audit shall also appropriately

     be included. However, serious irregularities like non-realisation of social

    and economic objectives, non-observance of time schedule and cost

    estimates, over capitalisation, large overhead expenditure, over-staffing,

    idle personnel, work backlogs, delay in construction of projects resulting

    in cost overrun, absence of trained manpower, plants operating below rated

    capacity, excessive inventories, absence of sound pricing policy,

    unauthorized occupation of government lands, idle plant and equipment,

    leakage of revenue, overpayments, loss due to pilferages or non-

    observance of proper procedures, improper, avoidable or infructuous

    expenditure etc. should be included in the Report.

    Ø   For expenditure and receipts figures, the accounts figures should generally

     be adopted. The departmental figures should also be mentioned, specifying

    the reasons for the differences, if analysed or pointing out the non-

    reconciliation of the figures by the department. When figures are not

    ascertainable from accounts and departmental figures are adopted, the fact

    should be mentioned in the report.

    Ø   In the case of centrally assisted schemes, the pattern of central assistance,

    conditions attached, actual amount of central assistance received,

    expenditure incurred and position of excess/shortfall in respect of central

    assistance should also be mentioned. When a scheme is implemented in

    more than one sector, such as under plan with central assistance and under

    non-plan with state finance alone, the audit observations may be so

    grouped that it is easy to identify, to which sector they relate.

    Ø   Information regarding the number of units test checked and out of how

    many, particular defects or weaknesses that have been noticed is to be

    furnished so that the comment in the performance audit report is

    appreciated by the PAC in its proper perspective.

    Ø   The report should contain significant evidence of audit. As such leaning

    heavily on departmental reports and just copying from them should be

    avoided. Even when extracts from departmental records are quoted, it

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    should be done after analysis and audit observations on the inaccuracies in

    the statement, if any, should be mentioned.

    Ø   The audit team should make themselves conversant with the observations

    of HQ office on performance audit reports in the past and draft the reports

    on the performance audit conducted by them in such a way that similar

    deficiencies do not occur in the report.

    Ø   The presentation and language of the performance audit report should

    abide by the “style guide” of SAI India. The essence of the style guide is

    to adopt uniform format and language, render the report simple and reader

    friendly as well, as interesting. Accountability-centered, third person

    active voice, narration by designation enhances the readability and interest

    of the reader and induces objective response from the entity. It should be

    followed uniformly. (Para 6.18 The Guidel ines)

    3.3  Characteristics of good report (Para 6.4 –Guidelines)

    The following points need to be emphasized in regard to performance

    audit reports:

    v   The audit report should be complete i.e. all pertinent information

    required to satisfy the audit objective, including the information relating

    to the scope, criteria, evidence, conclusions and recommendations should

     be available in the report;

    v   The obligation of the audit report to be accurate implies that the evidence

     prescribed is true and the conclusions are correctly portrayed;

    v   The objectivity of audit report is convincing if the results of audit are

     presented persuasively and the conclusions and recommendations

    followed logically from the facts presented;

    v   The report should be clear, which signifies that it should be easy to read

    and understand

    v   The report should be concise, which requires that the report should be of

    optimum size, no longer than necessary to convey the audit opinion and

    conclusions.

    v   Balanced reporting should be adopted in the presentation of reports.

    Audit findings and conclusions should not only be based on relevant and

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    sufficient evidence, but also presented in an objective, fair and non-

     partisan manner. For this,

    o  apart from deficiencies / short comings/ lapses, the positive

    contribution of audited entities should also be mentioned in the

    reports wherever possible.

    o  use of the terms “tenable” and “irregular” may be discontinued and

    instead suitable expressions may be used such as

    (i)  the reply does not explain why….

    Or

    (ii) the reply is not in consonance with ….

    Or

    (iii) the reply is contrary to ….

    Or

    (iv) the reply does not correctly interpret etc.

    The rebuttals should always be in the form of a reasoned argument.

    v   Consistency of the report is secured by ensuring that it does not contain

    contradictory findings or conclusions in similar context or the

    conclusions on the same segment in different sections or parts of the

    report are not incompatible.

    v   The report is constructive if it manifests a remedial approach rather than

    a critical approach and includes appropriate recommendations.

    v   The report adds value to the entity, if it is timely.

    v   The acquiescence to the report, including the audit conclusions and

    recommendations grows with display of entity cooperation, entity

    responses, audit methodology, audit criteria and evidence, etc. within the

     performance audit reports.

    3.4 Structure of the report (Para 6.29 – The Guidelines)

    The performance audit report should be presented as per the following

    structure:

    ♦  Title : the subject of the performance audit.

    ♦  Highlights : major audit findings either in the sequence of their

    materiality or in the same sequence as the audit objectives and sub

    objectives;

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    ♦  Recommendations : While recommendations may be included at

    various places in the report in different contexts, all major

    recommendations should be presented together, immediately after the

    highlights, preferably, in a box or highlighted print. Ideally all matters

    of facts/figures/evidence, audit findings and conclusions included in

    the report should have been accepted by the entity by the time the final

    report is prepared. Thus, in so far as the entity and the SAI are

    concerned, the action would revolve around implementation of the

    recommendations and follow-up respectively. It would, therefore, be

    desirable to gather all recommendations together.

    ♦  Introduction : consisting of a brief description of the subject of study,

    information on programme/activity/institution, its objectives, inputs,

    implementation structure, expected outputs and outcome etc. The

    introduction should be brief, yet sufficient to enable the reader

    understand the context of the programme;

    ♦  Scope of audi t: Scope of performance audit in terms of the period of

    the programme covered in audit and segments of the programme

    audited should be set out precisely;

    ♦  Audit objectives : are the pivots of the performance audit, which set out

    the reason for undertaking the audit. The entire exercise of

     performance audit is built around the audit objectives. These should,

    therefore, be stated in simple and clear terms. It is useful to set out the

    audit objectives and sub-objectives within each audit objective in the

    form of complete statement/question;

    ♦  Audit criteri a : to arrive at the audit findings and conclusions with

    reference to each audit objective and sub-objective which should be

    stated with appropriate explanations;

    ♦  Audit methodology : used for data collection/evidence gathering and

    testing may be stated in brief. This adds to the acceptability of the

    audit findings and forms a statement for transparency of the audit

     procedure;

    ♦  Audit findings : in respect of economy, efficiency and effectiveness

    should be presented in a logical manner, preferably in the same order

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    as the statement of the audit objectives. Conclusions,

    recommendations and impact (outcome) analysis: with reference to

    each audit objective should be stated, preferably immediately

    following the audit findings. The completeness of the report enhances

    if recommendation(s) with respect to each conclusion is/are kept

    together with the conclusions. Distinctiveness between the

    conclusions and recommendations may be achieved through formatting

    techniques;

    ♦  Lessons learnt and sensitivity to error signals :  under this caption

    significant audit findings on sensitivity and effectiveness of the

    internal control system to ensure that the management recognized

    major causes of underperformance brought out in internal or external

    studies/reports, including past audit reports and the remedial measures

    may be included. Also the audit findings on the sensitivity of the

    management to various error signals generated through internal

    inspections, evaluations, media reports, complaints, study by interest

    groups etc. and effectiveness of the action taken may also be included.

    In both cases, the audit findings that could have been avoided with

    effective lessons learnt and error signal response system may be

    highlighted.

    ♦  Acknowledgement :  The co-operation, acceptance of the

    criteria/findings and recommendations by the entity may be

    acknowledged briefly. In case the co-operation or response was not

    forthcoming at any stage it may be indicated if it has resulted in any

    limitation along with its implication and the special efforts made by the

    Prl. Accountant General to seek co-operation or response. Care should

     be taken to state them as a matter of fact rather than giving an

    impression to convey any accusation;

    ♦  Graph, charts, diagrams, photographs etc.: Prl. Accountants General

    are encouraged to illustrate the audit findings with the use of graphs

    and charts and improve the visibility of the analysis and findings.

    Photographs can be used as evidence where they are able to

    corroborate evidence.

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    ♦  Glossary of terms : explaining all technical and uncommon terms used

    in the report that need to be explained.

    ♦  References or bibliography : containing reference to all published

    material utilized in developing the report.

    A list of key documents should be attached to the report and the serial

    number of the key documents in the list should be indicated against the relevant

    observation in the report. Duplicate copies of key documents should be arranged

    in serial order in a separate folder.

    The report drafted by the audit officer of the EPA party should be

    submitted to the group supervisory officer and after his/her approval, it should be

    forwarded to the EPA(HQ) for submission to the Prl Accountant General through

    Report (Civil) section.

    The Reports, Questionnaires, Checklist and other materials relating to

    Kerala and Union Territory of Lakshadweep intended for Union Audit Reports are

    sent directly by EPA HQrs to the concerned audit wing at HQrs. Simultaneously

    copies of the Reports are sent to the Secretary of the implementing State

    Government Department (State Report) and the Administrative of the Union

    Territory of Lakshadweep (UT Report).

    3.5  Forwarding of the draft report (Check list at Annexure IV) 

    After the report is approved by the Prl Accountant General, it should be

    sent to the Secretary to the Government department with a demi-official

    forwarding letter and with a copy to the Secretary to Government, Finance

    Department. It should contain the following:

    o  Subject of the performance audit and reference to previous dialogue;

    o  Gist of major audit findings and recommendations along with the risk

    and materiality of the issues;

    o  Attention to the orders of the Government issued on the

    recommendation of the parliamentary/ legislature committee, setting

    time limit for formal response.

    o  Invitation to formal discussion and presentation of the audit findings and

    conclusions; and

    o  The expected value additions to the programme management, if the

    recommendations are implemented.

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    Simultaneously, a copy of the draft performance audit report along with a

    copy of forwarding letter to the secretary to the Government should be submitted

    to the HQ office.

    • An assurance memo in the prescribed form should be appended to draft

    review report.

    • While sending the draft reviews and long paragraph to headquarters,

    matrix identity, money value and matrix value are to be indicated. Details

    of instructions are given in Annexure V.

    3.6  On receipt of the response of the entity and observations of the SAI top

    management, we may incorporate the modifications, warranted by them and

    forward the draft report along with a response sheet for further action at head

    quarters.

    3.7 Publication 

    §  Stand-alone volume for each performance audit report;

    §  Deviation from this with authorization; and

    §  Performance audit reports prepared and presented during all sessions of

    Legislature round the year as per the pre-determined schedule.

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    CHAPTER- IV

    MISCELLANEOUS

    4.1  Period to be covered in reviews relating to autonomous bodies 

    The duties of audit department in respect of audit of accounts of

    autonomous bodies are limited to the period of entrustment of audit. Therefore,

    any performance audit attempted in respect of an autonomous body is to be

    confined to this period and it would not be advisable to examine the transactions

    or review the operations which fall outside this period. However, such

    clarifications and statistical information pertaining to past period as may be

    necessary to take a proper view of the transactions and operations audited can be

    obtained by audit and taken into account (Comptroller & Auditor General of

    India's circular No.3 AuditII/6-87 No.63 Audit II/6-87 dated 28.1.1987-File

    EPA/HQ/1/4-40/86-87).

    4.2 Public Sector Programmes

    The performance audit team should keep in view and cover the following

    important issues in the performance audit of public sector programmes.

    Mandate •  Has the management obtained the approval of the

    competent authority (i.e. Legislature) for the

     programme

    Objectives •  Has the management developed clear objectives?

    •  Have the programme objectives been appropriately

    determined to fulfill the policy objectives?

    •  Are the objectives specifi