October 7, 2002
TO: CPAs, City, Villages, Townships and Counties
FROM: Richard L. Baldermann, CPA, CGFM
Administrator, Local Audit and Finance Division
Subject: New GAO Independence Standards versus AICPA
Independence Standards
The required audit standards that must be followed to satisfy the
requirements of Act 2 PA 1968, as amended, are stated in section 7 of the act.
Sec. 7 (1) The state treasurer shall prescribe minimum auditing procedures and
standards and these shall conform as nearly as practicable to generally
accepted auditing standards established by the American Institute of Certified
Public Accountants.
The required audit standards that must be followed to satisfy the requirements
of audits of Federal financial assistance are contained in Government
Auditing Standards (Yellow Book) issued by the United States General
Accounting Office (GAO). The independence standards in the Yellow Book are
currently more restrictive than the AICPA independence standards, particularly
as they relate to the provision of audit and non-audit services.
EXAMPLES
A local CPA in a rural area (or any other area) of Michigan provides
bookkeeping as well as audit services for nearby township, city or village
governments.
- If the local government does NOT receive federal financial assistance or
receives less than the threshold amount requiring a single audit, the CPA
may follow the AICPA audit standards and may continue to provide both
services. The audit will satisfy the requirements of Act 2 PA 1968, as
amended.
- If the local government receives more than the threshold amount requiring
a single audit, the CPA must comply with GAO’s Government Audit Standards.
Under the new independence rules, the CPA could no longer provide non audit
services as defined by GAO. The CPA and/or local government will have to
make a choice as to which of these services the CPA will continue to
provide. The remaining services will need to be provided by another CPA firm
(audit services) or other vendor (non-audit services).