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Accounting, Organizations and Society 32 (2007) 463–485

www.elsevier.com/locate/aos

It’s all about audit quality: Perspectives on


strategic-systems auditing q
Mark E. Peecher, Rachel Schwartz, Ira Solomon *

Department of Accountancy, College of Business, University of Illinois at Urbana-Champaign,


1206 S. Sixth Street Champaign, IL 61820, United States

Abstract

We discuss the antecedents of and rationale for what has become known as Strategic-Systems Auditing (SSA). We
also describe the conceptual foundation and key elements of SSA. We observe that the auditor employing SSA con-
ceives the audit as a process of evidence-driven, belief-based, risk assessment. We also illustrate facets of this process,
including how the auditor, by acquiring a rich understanding of how and how well management is executing its busi-
ness-model, develops rich (e.g., distributional) expectations of future financial-statement amounts and disclosures.
These expectations form a benchmark against which the auditor later compares and investigates management’s asserted
financial-statement amounts and disclosures. Finally, we pose and respond to some of the more common questions
about elements of SSA and complete the paper by suggesting some educational innovations and high-value targets
for research.
One salient message is that SSA first emerged in the 1990s as an attempt to enhance audit quality in response to
changes in the audit environment. Another salient message is that SSA continues to equilibrate, adapting to more recent
environmental changes, especially society’s demand for greater protection from financial-statement fraud. Such adap-
tation requires ongoing, significant intellectual investments by audit practitioners and audit scholars/educators.
 2006 Elsevier Ltd. All rights reserved.

Introduction

q
Parts of this paper are based on a presentation made by Tim Our perspective as auditing scholars and educa-
Bell (KPMG LLP) and Ira Solomon at the Shanghai National tors is that Strategic-Systems Auditing (SSA) is
Accounting Institute Conference on Business Risk Auditing, and always has been about audit quality. During
September 2005. In addition, we thank Tim Bell for his the mid-1990s SSA, a new approach to public
comments on earlier versions of this paper.
*
Corresponding author. Tel.: +1 217 333 2451; fax: +1 217
company audits, emerged in response to changes
244 0902. in the nature of value creation activities at a rising
E-mail address: isolomon@uiuc.edu (I. Solomon). number of business organizations (see, for

0361-3682/$ - see front matter  2006 Elsevier Ltd. All rights reserved.
doi:10.1016/j.aos.2006.09.001
464 M.E. Peecher et al. / Accounting, Organizations and Society 32 (2007) 463–485

example, Bell, Marrs, Solomon, & Thomas, 1997; Enron, Waste Management, WorldCom, Royal
Bell, Peecher, & Solomon, 2002). These changes, Ahold, and Parmalat. Cases like these stimulated
which altered organization’s business strategies considerable regulatory reform, including the
and processes, surfaced in response to an interac- Sarbanes–Oxley Act of 20021 in the US, thereby
tion of several factors, most notably innovations communicating in a loud and clear voice to pub-
in information, transportation, and communica- lic-company auditors that society’s expectations
tion technologies, resulting in greater globalization were not being met. Indeed, there now is more
and organizational connectedness (Friedman, clarity around and heightened expectations for
2005). At the same time, more complex valuation the level and nature of auditor responsibility for
assertions began to prevail in financial statements financial-statement fraud, i.e., reasonable assur-
that reflected audited entities’ business risks (Bell ance is high assurance for material misstatements
et al., 1997, pp. 43, 69). Today, these trends con- irrespective of whether they are unintentional
tinue, and they are accompanied by a heightened (error) or due to fraud.2 As more fully discussed
demand for greater protection from financial- later, these clarifications reinforce our belief that
statement fraud. SSA was an appropriate and nec- SSA is an important and valuable innovation in
essary means of enhancing audit quality in the public company auditing.
1990s, and it is all the more so today. Because SSA is a response to features of the
Public company auditing does not exist in a audit environment, we begin the remainder of this
vacuum. Indeed, auditing approaches evolve paper with a Section called ‘‘The contemporary
endogenously in response to changes in society’s audit ecology.’’ Then, in the Section ‘‘What is
information needs, regulations, business organiza- SSA?’’ we describe key elements of SSA and
tion’s value-creation processes, and available explain that it embraces the view that audits most
accounting and audit technologies. Moreover, fundamentally involve evidence-driven, belief-based
changes in audit approaches simultaneously influ- risk assessment. The Section ‘‘SSA illustrations’’
ence and have been influenced by conceptions of then describes how selected elements of SSA work,
the audit. The US Securities and Exchange Com- including how, under SSA, the auditor can
mission’s (SEC’s) ruling in the late 1930s in the develop rich (e.g., distributional) expectations of
McKesson and Robbins case provides an example financial-statement amounts and disclosures to
(Brief, 1982). Prior to that ruling, US external use for ongoing risk assessment purposes. In the
auditors apparently conceived the external audit Section ‘‘What’s controversial?’’ we consider some
largely as an investigation of the consistency of of the more contentious issues relating to SSA. We
financial-statement amounts with various inter- complete the paper with the Section ‘‘Concluding
nal-to-the-client-organization accounting records remarks’’ by observing some implications for edu-
and documents. The McKesson and Robbins cation and research. A couple of disclaimers are in
inventory and accounts receivable fraud high- order before we proceed. First, while we are aware
lighted the limitations of such a conception of that many persons would group several audit
the audit, and the SEC ruling in the case, essen- approaches together under the title of Business
tially mandating inventory observation and confir- Risk Auditing, we only discuss below the anteced-
mation of accounts receivable, changed the way ents, elements, and implications of SSA. Other
external auditing in the US is conducted and audit approaches share some, but not all, of the
conceived.
Globally, there has been an unprecedented level
of alleged corporate lootings during the first dec- 1
The Act’s formal title is Public Law No. 107-204: An Act to
ade of the 21st century, with public-company protect investors by improving the accuracy and reliability of
financial statements often being used to perpetrate corporate disclosures made pursuant to the securities laws, and
for other purposes.
and/or hide the wrongdoing. The names of the 2
See, e.g., International Standards on Auditing 240 The
companies involved have become synonymous Auditor’s Responsibility to Consider Fraud in an Audit of
with corporate dishonesty and excess – e.g., Financial Statements, –21 in IAASB (2005).
M.E. Peecher et al. / Accounting, Organizations and Society 32 (2007) 463–485 465

SSA elements, and thus, are beyond the scope of (3) There is consistent evidence that, although
this paper.3 Second, the discussion herein is infrequent, when audit failures occur, they
framed mainly from a US perspective. That said, are typically due to inadequate control of
much, but perhaps not all, of what follows is likely non-sampling risk/error.
to be applicable across many audit geographic and (4) The Audit Risk Model (ARM) persists as a
institutional domains. prominent aid for planning the audit and
organizing audit quality control efforts on
individual engagements.
The contemporary audit ecology
The context of business has a profound impact
There are many ways in which one can charac- on client organization’s business risk (i.e., threats
terize an environment as complex as the audit to the organization’s business model) and, in turn,
environment. We choose to emphasize four dimen- on audit risk.5 In today’s business world, advance-
sions of the audit environment of today: ments in communication, information and
transportation technologies have created a hyper-
(1) Audited entities are employing new business competitive environment. No longer, for example,
models,4 business strategies, and processes; does geographic proximity generally provide a
there are reduced barriers to competition; major competitive advantage. Indeed, potential
the pace of change is accelerating. competitors and innovations can and do come
(2) There is heightened concern about and from virtually anywhere around the globe. Simi-
responsibility for detecting management larly, many businesses create value less via deploy-
fraud resulting in misstated financial ment of tangible assets and more by creating and
statements. deploying intangibles such as intellectual property
and business processes. These new business models
have stressed the financial reporting system, ele-
vating the presence and import of estimates, espe-
3
Some authors characterize business-risk auditing as any cially valuation estimates, highlighting the role of
form of auditing that incorporates client–firm strategy and/or judgment in the accounting. And, in today’s busi-
business risk into the assessment and planning of audit risk (see, ness world the pressures, opportunities, and
e.g., Curtis & Turley, 2006; Robson, Humphrey, Khalifa, & rewards for earnings management, and even for
Jones, 2005), while others characterize it as any form of
auditing that considers client business risk as part of the audit
outright financial-statement fraud, are as great as
evidence process (e.g., Knechel, 2005). SSA, under these anytime in the past.
characterizations, would be a form of business-risk auditing. Despite business model complexity and earnings
We believe that SSA is distinctive, however, because of its management threats, the external auditor must
collective emphasis on complex systems, systems thinking, opine on the veracity of financial statements.
evidentiary triangulation, non-sampling risk, and viewing the
entire audit as a recursive process of evidence-driven, belief-
Financial statements capture retrospective and for-
based risk assessment. Further, although SSA is associated with ward-looking consequences of business model
KPMG’s LLP audit methodology circa 1997–2006, the manners complexity via numerous estimates and intricate
in which SSA has been and will continue to be implemented disclosures. The auditor must develop expectations
remain open empirical questions. that help gauge the reasonableness of estimates and
4
Chesbrough and Rosenbloom (2002) discuss antecedents to
the term business model and note that this term generally is
disclosures as well as strategies for acquiring addi-
loosely defined. They cite one explicit definition for which they tional, sufficient evidence to attest to their veracity.
credit the consulting firm KMLab, Inc.: ‘‘a description of how
your company intends to create value in the marketplace. It
5
includes that unique combination of products, service, image, We define audit risk more formally later; for now, audit risk
and distribution that your company carries forward. It also can be thought of as the possibility that the auditor will issue an
includes the underlying organization of people and the oper- inappropriate opinion when the financial statements contain
ational infrastructure that they use to accomplish their work’’ one or more material misstatements (i.e., departures from
(p. 532). generally accepted accounting principles).
466 M.E. Peecher et al. / Accounting, Organizations and Society 32 (2007) 463–485

It is now generally recognized that the auditor’s For example, per SAS No. 16, The Independent
expectations and evidence acquisition strategies Auditor’s Responsibility for the Detection of Errors
need to be conditioned on a rich understanding or Irregularities (AICPA, 1977), the auditor’s
of the client’s business model. Indeed, the auditor’s responsibility was primarily to react to indicia to
understanding of the client’s business model and of fraud should they come to the auditor’s attention
changing industry conditions is generally recog- during the normal course of events. Per SAS No.
nized as a critical part of the understanding on 53 The Auditor’s Responsibility to Detect and
which the auditor’s opinion ultimately rests (see, Report Errors and Irregularities (AICPA, 1988),
e.g., ISA 315 in IAASB, 2005). the auditor had the responsibility to plan and per-
Related, in response to revelations/allegations form the audit to obtain reasonable assurance that
of financial-statement fraud during the first few any material misstatements (including those
years of this decade, the auditing profession in caused by fraud) would be detected. This docu-
many countries has been transformed from a ment also offers illustrative client business risk fac-
self-regulated to a government-regulated industry. tors that may indicate an elevated fraud risk. In
A substantial focus of the regulation has been SAS No. 82 Consideration of Fraud in a Financial
financial-statement fraud, especially clarifying the Statement Audit, the AICPA (1997) attempted to
auditor’s responsibility with respect to fraud. That further clarify the auditor’s responsibility by stat-
is, reforms stimulated by the alleged financial ing that the auditor should specifically assess the
reporting shortcomings have now clarified that risk of material misstatements that are due to
reasonable assurance is high assurance even with fraud. This pronouncement also required the audi-
respect to misstatements in the financial statement tor to document the fraud risk assessment. SAS
that are due to fraud (see, e.g., ISA 240 in IAASB, No. 99 Consideration of Fraud in a Financial State-
2005). The motivation for such regulatory clarifi- ment Audit (AICPA, 2002) is a more recent
cation is clear when one reflects on the history of attempt to spell out what society expects from
the issue, especially as documented in the US the auditor with respect to financial-statement
authoritative guidance. fraud. Two of its main innovations require the
Early audits focused on detection of book- auditor to brainstorm about the risk of material
keeper fraud (see related discussion in the Section misstatement due to fraud, regardless of any past
‘‘What’s controversial?’’). Later, as corporations honest dealings with entity management. Its utility
began to emerge as popular business structures, for improving the auditor’s assessment of fraud
there was a concomitant shift in the external audi- risk, however, remains an open question.
tor’s focus from detection of bookkeeper fraud to Importantly, there now is considerable evidence
fair presentation of income in accord with that when financial-statement fraud has occurred
accounting principles. Such fair presentation can and the auditor has not detected it, it is quite likely
be compromised by intentional and unintentional that the client organization senior management
misstatements. While generally accepting responsi- has been involved. Specifically, the SOX Section
bility for the latter, auditors have tried in a variety 704 report on the Causes of Fraud and Audit Fail-
of ways to minimize their responsibility for inten- ures (SEC, 2003) reveals that in just over 80% of
tionally distorted financial statements. Intentional the cases studied, at least one member of senior cli-
distortions can arise when there is employee mis- ent management has been implicated. The report
appropriation of assets, but more importantly, concludes that senior managers who commit such
they can arise when management misappropriates fraud commonly are motivated by a desire to meet
assets and/or distorts the financial statements. earnings and other expectations-based targets.
Various incarnations of authoritative guidance in And, importantly, such senior managers often
the US reflect the reluctance of external auditors have aligned the accounting records and books
to accept significant responsibility for detection as well as supporting documents generated by
of financial-statement fraud, especially when fraud the accounting system with the fraudulent misrep-
was perpetrated by high-level management. resentations. As an example, in at least one case,
M.E. Peecher et al. / Accounting, Organizations and Society 32 (2007) 463–485 467

the internal calendar of a company’s computers Audit Risk ðAURÞ ¼ Inherent Risk ðIRÞ
was manipulated at the behest of senior manage-
 Control Risk ðCRÞ
ment to conceal fraud. Consequently, traditional
substantive tests of details as well as traditional  Detection Risk ðDRÞ
tests of controls were unlikely to be effective for where
fraud detection in that situation.
Related, the report cites auditor judgment AUR: The risk that the auditor expresses an
errors like the following as the culprit in most, if inappropriate audit opinion when the
not all, of these situations: financial statements are materially
misstated.7
• Failure to obtain sufficient understanding of the IR: The susceptibility of an assertion to a
client’s business. material misstatement assuming that there
• Failure to sufficiently corroborate manage- were no internal controls.8
ment’s representations and explanations. CR: The risk that a misstatement that could
• Failure to exercise professional skepticism on occur in an assertion and that could be
unusual, last minute, or related party material, individually or when aggregated
transactions. with other misstatements, will not be pre-
• Failure to conduct adequate risk assessments. vented or detected and corrected on a
timely basis by the entity’s internal
In our view, the last shortcoming above is very controls.
much a consequence of the others, especially the DR: The risk that the auditor will not detect
first shortcoming. That is, inadequate risk assess- misstatements that could be material indi-
ments would be virtually inevitable if an auditor vidually or when aggregated with other
were not to obtain a deep and robust understand- misstatements.
ing of the client’s business and industry. And, the
other shortcomings are likely to follow as well, if Sometimes IR and CR are combined into a sin-
the auditor lacks such an understanding. gle term, Risk of Material Misstatement (RMM),
So, having elucidated the criticality of judgment defined as the risk that the financial statements
errors, one might next pose the question—what are materially misstated prior to the audit. Because
guidance is there for auditors with respect to the ARM was designed to aid the auditor in the
how to minimize such errors in the contemporary selection of sample sizes that would achieve audit
audit ecology? Unfortunately, while the guidance objectives, DR often is decomposed in AP and
in international auditing standards is superior to TD, the detection risk associated with analytical
that in extant US public company auditing author- procedures and tests of details, respectively. And,
itative guidance, improvement is in order across TD often is decomposed into sampling and non-
the board. Indeed, it may very well be that extant sampling risk, with the latter then defined to be
authoritative guidance focuses the auditor in the
wrong direction. We consider the following formu-
lation of the Audit Risk Model (ARM) to drive
7
this concern home:6 ISA 320 Audit Materiality defines materiality as information
is material if its omission or misstatement could influence the
economic decisions of users on the basis of the financial
statements. Materiality depends on the size of the item or error
judged in the particular circumstances of its omission or
misstatement. Thus, materiality provides a threshold or cut-off
6
The ARM first appeared in equation form in 1972 in point rather than being a primary qualitative characteristic which
Appendix B of AICPA Statement on Auditing Procedure No. 54 information must have if it is to be useful (–3).
8
Precision and Reliability for Statistical Sampling in Auditing. Assertions include, existence or occurrence, completeness,
The Auditing Standards Board later included a similar equation rights and obligations, valuations or allocation, presentation
in SAS No. 39 Audit Sampling (AICPA, 1981). and disclosure (ISA 500 Audit Evidence, –15–18).
468 M.E. Peecher et al. / Accounting, Organizations and Society 32 (2007) 463–485

outside the domain of the ARM.9 Consider further rather cavalier statements such as the following
the following: about how to minimize judgment errors: ‘‘Non-
sampling (judgment) risk can be reduced to a
• Audit Risk (AUR) is jointly determined by (a) negligible level through such factors as adequate
whether the financial statements are materially planning and supervision. . .’’ History tells us,
misstated prior to the external audit (i.e., however, that doing so is no trivial matter, espe-
whether material misstatements exist in the first cially using traditional audit approaches.
place), and (b) the likelihood that the auditor Perhaps, in part, because the ARM does not
will not detect material misstatements during emphasize non-sampling risk, neither audit
the audit, should they exist. approaches nor historic audit standards tradition-
• Because, for a variety of reasons, the auditor ally focus the auditor’s attention on the identifica-
cannot know (a) with certainty, the auditor tion and mitigation of non-sampling risk factors
assesses the risk of the existence of material (e.g., factors that elevate the likelihood of auditor
misstatements by identifying and assessing a risk-assessment error). Nor do they provide the
variety of states outside of the audit whose pres- auditor with guidance about how different evi-
ence can heighten RMM, or that reveal the exis- dence acquisition strategies likely affect the audi-
tence of actual material misstatements. tor’s propensity to underestimate non-sampling
• According to the current authoritative guidance risk. In other words, even though audit risk assess-
in the US, RMM exists independently of the ment is quite complex and inevitably subject to
audit, and is assessed by the auditor through assessment error, even by audit experts (Bell, Pee-
the exercise of professional judgment.10 cher, & Solomon, 2005), the traditional auditor’s
• DR is assessed and managed by the auditor. attention may well be miss-directed away from
• Judgment errors in assessing RMM or any of its non-sampling risk, likely to a degree that is detri-
elements are likely to cause the auditor to mis- mental to audit quality. As we explain next, SSA’s
assess and, in turn, mismanage DR. As a conse- risk assessment orientation emphasizes non-sam-
quence, AUR is likely to be higher than pling risk and views mitigation of non-sampling
targeted. risk as a key to sufficiently driving down audit risk.

Importantly, current authoritative guidance


(e.g., SAS No. 39 AICPA, 1981) generally makes What is SSA?

In the preceding paragraphs we have summa-


rized several crucial trends in business models,
9
Non-sampling risk [a]rises from factors that cause the intangible value drivers, information technology,
auditor to reach an erroneous conclusion for any reason not and societal expectations of the auditor. These
related to the size of the sample, whereas sampling risk arises
from the possibility that the auditor’s conclusion, based on the
trends jointly shape the 21st century financial-
sample may be different from the conclusion reached if the entire statement auditing context. In light of this context
population were subjected to the same audit procedure (IAASB, we next describe our view of the objective of finan-
2005, Glossary of Terms, –129). cial statement auditing, and then highlight how
10
RMM is not truly independent of DR. The mere existence SSA is well suited to help the auditor attain this
of the audit, and the client’s awareness of the methodology that
will be applied by the auditor, can impact RMM. For example,
objective. Thereafter, we discuss examples of SSA.
client awareness of the procedures the auditor will apply may The financial statement auditor aspires to pro-
serve as a deterrent to material misstatement, and it also can vide high assurance about the extent to which
provide the client who wishes to strategically deceive the management’s financial statement representations
auditor with insight about how and where to place intentional fairly depict select entity business states (EBS in
material misstatements so that they may go undetected. Also,
technically speaking, it is a variety of business states that exist
Fig. 1). Entity business states are all of the entity’s
independently of the audit, and to which the auditor directs business strategies, conditions, processes, and eco-
attention to make assessments of RMM. nomic actions/events, as well as past, current, and
M.E. Peecher et al. / Accounting, Organizations and Society 32 (2007) 463–485 469

The Financial Reporting Process Culminates in Representations of Entity Business States

Suppliers Customers Controls Over


Financial Reporting General Purpose F/S

Automated
Processes

Audited
Entity

Alliance Ptrs. Competitors


Journals & Ledgers MD&A
Manual
Applicable Processes
Reporting
Framework
Regulators Capital Mkts.

Entity Management Management


Business Information Business
States Intermediaries Representations

Fig. 1. The audit addresses whether management’s financial statement representations fairly depict select entity business states. (From
Bell et al. (2005). Used with permission.)

likely future business relationships with other enti- representations attain the fairly depict objective
ties (Bell et al., 2005, p. 4). The auditor’s concern generally is not possible unless the auditor main-
extends to the subset of EBS of potential relevance tains a rich understanding of the entity’s business
to any assertion(s) associated with the entity’s states. One cannot judge the fairness of a represen-
financial statements. tation of a business state without an understanding
As Fig. 1 illustrates, management builds and of the business state.11
maintains a bridge between EBS and its finan- In the 21st century audit context, the auditor
cial-statement representations; we call this bridge must be wary that MII could accidentally or inten-
management information intermediaries (MII). tionally neglect or distort select EBS, resulting in
These intermediaries include financial reporting, unfair depictions of EBS in management’s finan-
internal control, and risk management frame- cial statements. To combat this concern, the SSA
works, computer networks and information sys- auditor views the audited entity through a strate-
tems, as well as documentation and human gic-systems lens. This lens complements the view-
information processing. Such intermediaries point provided by a transactions-oriented lens
gather intelligence about, capture, measure and, (see, e.g., Bell et al., 1997, 2002, 2005), and it
typically, transform various EBS into a variety of broadens the subset of EBS of potential relevance
management business representations (MBR).
These representations appear in electronic and
hardcopy form and affect a variety of judgments
and decisions in contexts within the entity’s eco- 11
nomic web. Judgment and decision-making theorists would note that
auditor’s understanding of a business state is itself a fallible,
Consistently, the auditor employing SSA takes mental representation (e.g., Brunswik, 1943; Hammond, 1955).
the position that accumulation of high assurance We discuss some of the risk-assessment implications of human
about whether management’s financial-statement judgment fallibility later in this paper.
470 M.E. Peecher et al. / Accounting, Organizations and Society 32 (2007) 463–485

to the auditor.12 While non-SSA approaches rec- assurance about whether or not management’s
ognized the helpfulness of understanding an financial-statement representations are unfair as
audited entity’s business for some purposes, such a result of intentional distortion. This treatment
as audit planning (see, e.g., SAS No. 22, Planning also runs counter to the traditional audit risk
and Supervision), such an understanding does far model (ARM) that prevails in US authoritative
more than facilitate audit planning within SSA. audit guidance (cf., Shibano, 1990). Since its ori-
Within SSA, the EBS understanding is paramount gin, the ARM has remained largely silent about
for ensuring the quality of the entire audit process the implications of facing strategic management.13
for without it, the auditor loses the ability to iden- As used with SSA, however, the term strategic
tify the scope and nature of EBS that MII should extends well beyond auditee management to
be capturing and transforming for fair representa- encompass the audited entity’s economic web. This
tion within financial statements. Maintaining the web is comprised of numerous strategic players.
understanding of EBS dynamics arguably is as Whether specific players share incentives with
important to the SSA auditor as is maintaining management of the audited entity depends on the
proficiency with developments in auditing stan- nature of past, current, and likely future relation-
dards and applicable financial reporting ships with the audited entity. Some players likely
frameworks. have symbiotic relationships with management of
In addition to broadening the scope of EBS the audited entity (e.g., alliance partners, employ-
examined, the SSA lens emphasizes the terms stra- ees, and customers), while others likely have con-
tegic and systems. Treating management as strate- flicting relationships (e.g., competitors and
gic is, of course, very familiar to audit scholars regulators). And, these relationships change over
(see, e.g., Antle, 1982; Ashton, Kleinmuntz, Sulli- time. The SSA auditor questions and evaluates
van, & Tomassini, 1989; Dopuch & King, 1991; the audited entity’s value generation capabilities
Shibano, 1990; Wilks & Zimbelman, 2004; Zimbel- by thinking about the various players’ relative
man & Waller, 1999). Still, this treatment runs power as well as the trajectories that they would
counter to the aforementioned audit profession’s prefer the audited entity’s value generation capa-
unwillingness to clarify its duty to provide high bilities to exhibit over time. Different trajectories
have different risk implications for the audited
entity.
12
As Kinney (1997, p. v) notes, prior to SSA, the auditor did To help clarify the auditor’s thinking about
not normally analyze the entity’s business strategy, nor did the
auditor attempt to judge its achievability or viability. Prior to
these potential trajectories associated with select
SSA’s emergence, authoritative auditing guidance generally EBS, the SSA auditor also adopts a systems per-
relegated understanding the auditee’s business to a pre-audit or spective. Compared to SSA’s strategic perspective,
planning activity, described it from a narrow perspective, and its systems perspective is relatively new to audit
omitted a convincing rationale as to why auditors should practitioners and scholars. For example, prior to
acquire such an understanding (Bell et al., 1997, p. 7).
Interestingly, since SSA’s emergence, some audit standards
SSA few audit scholars or auditors customarily
and reporting frameworks have evolved to more richly charac- thought of the audited entity as a complex system.
terize audited entity’s business states and the value of under- Complex systems are systems that adaptively
standing these states (see, e.g., International Standard on learn, says Nobel laureate Murray Gell-Mann
Auditing (ISA) 315: Understanding the Entity and Its Environ- (1994), and thought leader Peter Senge (1990),
ment and Assessing the Risks of Material Misstatement, 2003
and Great Britain’s Accounting Standards Board Reporting
among others, explains how business entities are
Standard 1: Operating and Financial Review, 2005). ISA 315 is
especially interesting in that it construes the auditor’s under-
13
standing of EBS to constitute audit evidence and an interpre- Elsewhere, prevailing US and International authoritative
tative context for other audit evidence. Finally, it is notable that audit guidance more fully embrace the implications of facing
earlier calls for the auditor to more expansively consider EBS- strategic management (e.g., SAS No. 99, Consideration of Fraud
based evidence existed as early as the late 1970s, but such call in a Financial Statement Audit; ISA 240, The Auditor’s
apparently were not embraced by the profession until the mid- Responsibility to Consider Fraud in an Audit of Financial
1990s (see, e.g., Sorensen & Sorensen, 1980). Statements).
M.E. Peecher et al. / Accounting, Organizations and Society 32 (2007) 463–485 471

learning organizations. The components that com- have not been extensively educated or trained in
prise complex systems are better appreciated in complex systems or systems thinking.15
terms of how they relate to other components Yet, an encouraging finding from Hecht (2004),
and together interactively form a whole that equil- is that it appears that one can successfully educate
ibrates over time than in terms that emphasize and train people to be become better systems
each component’s separable identities. Complex thinkers. He observes that training enables his
systems often feature nonlinear, sometimes abrupt experimental participants to better understand sys-
shifts in behaviors over time instead of linear, tem causal structure and system dynamics within a
steady state behaviors over time (see, e.g., Berta- financial-statement auditing context, such that
lanffy, 1968). they become more likely than untrained partici-
The audited entity/complex system examined in pants to identify negative, unintended conse-
SSA is a dynamic web of relationships that has quences that could emerge after management
emerged and continues to exist because of its implements a well-intentioned, redundant control
value-generating capabilities within a broader eco- activity. Consequently, while trained systems-
nomic web (Bell et al., 1997, p. 17).14 One of the thinkers consider whether negative, unintended
biggest challenges that the 21st century auditor consequences may offset any positive, intended
faces is to anticipate how time delays, regulatory consequences, non-systems thinkers largely fixate
shocks, and other nonlinear risk developments on the latter (cf., Sterman’s, 2000 p. 609 examples
that affect an audited entity or its economic web of policy resistance).
will influence the entity’s strategic viability and Summarizing work by Jacobson (2001) and Bell
profitability over time (Bell et al., 1997, p. 23). et al. (2002) observe that research suggests that
SSA adherents believe that auditors who possess systems thinkers develop different mental models
reasonably well-developed systems-thinking skills about complex systems than do non-systems
are more likely to meet this challenge than audi- thinkers. Systems thinkers discount reductionistic
tors who lack such skills. thinking in favor of holistic thinking, recognize
Hecht (2004), who is among the first auditing that small actions can have large effects, anticipate
scholars to examine potential benefits of systems- delayed and/or nonlinear effects, look for interac-
thinking skills, characterizes systems-thinking as tive causality, and try to foresee how a system
the language, cognitive tool set, and perspectives likely will equilibrate over time.
that enable decision makers to form reasonably
accurate and complete mental representations of Risk assessment
complex environments. The auditor who pursues
a systems-thinking perspective, among other SSA proponents’ call for the auditor to adap-
things, recognizes the significant degree to which tively evolve from tradition by using a strategic-
an entity’s dynamic business states hinge on past, systems lens has roots in the adherents’ perception
present, and likely future business states of the of increased societal demand for the auditor to sig-
audited entity and other entities in it economic nificantly improve in the areas of assessing, identi-
web (Bell et al., 2002, p. 4). Because systems think- fying, and, as appropriate, managing down
ing is new to auditing and unlikely to come natu- sources of audit risk. And, this societal demand
rally to many auditors, a threat to successful
implementation of SSA is that auditors historically 15
A growing body of evidence suggests that non-systems
thinkers have difficulty anticipating dynamics within complex
systems (see, e.g., Sterman, 1989; for reviews see, e.g., Brehmer,
1992; Sterman, 2000). For example, as first observed by Booth
14
While some of these relationships have accompanying Sweeney and Sterman (2000) graduate students in business
explicit or implicit contracts, many do not. In this sense, often poorly perform at relatively basic dynamics tasks such as
viewing the audited entity as a complex system is more inclusive plotting the stock of water in a bathtub over time given different
than viewing it as a nexus of contracts as in, e.g., Brickley, faucet inflows and drain outflows (also see, e.g., Kapmeier,
Smith, and Zimmerman (1996). 2004).
472 M.E. Peecher et al. / Accounting, Organizations and Society 32 (2007) 463–485

applies regardless of whether or not these sources the most knowledgeable technical experts. Even
of audit risk stem from management deception. such experts, however, may have an incomplete
Yet, contemporary authoritative guidance pre- understanding. Indeed, their professional training
sumes that auditors already do these things well may even have limited them to certain ways of look-
(see, e.g., AU Section 312 Audit Risk and Material- ing at problems . . .’’ (italics added, Fischhoff, Lich-
ity in Conducting an Audit in AICPA, 2004 and tenstein, Slovic, Derby, & Keeney, 1981, p. xii). If
ISA 200 Objective and General Principles Govern- audit risk assessment is difficult (and it is in our
ing An Audit of Financial Statements in IAASB, view), the wise auditor will recognize that non-
2005). Specifically, the auditor presumptively can sampling risk ordinarily is non-negligible. Under
decompose overall audit risk into RMM and SSA, therefore, the auditor strives to be ‘‘skeptical
DR. And, the auditor presumptively accurately not only of management and of evidence but also
assesses RMM and both accurately assesses and of their own judgment processes’’ (Campbell &
manages down DR to an appropriately low level Hughes in Bell et al., 2005, p. ii).16
so that, overall, audit risk remains acceptably To manage the non-negligible threat of non-
low. In other words, all sources of non-sampling sampling risk, the SSA auditor views the entire
risk – or audit risk sources that pertain to any audit as a recursive process of evidence-driven,
thing other than the size of a sample – are tradi- belief-based risk assessment.17 As Bell et al.
tionally presumed to ordinarily be negligible (see, (2005) argue, the SSA auditor employs an evidence
e.g., Messier, Glover, & Prawitt, 2006, p. 81). Wal- acquisition strategy called evidentiary triangulation
lace (1995, p. 454) summarizes conventional to develop well-justified beliefs and risk assess-
wisdom: ments. Evidentiary triangulation entails the audi-
tor acquiring complementary audit evidence from
Nonsampling risk, such as the auditor’s
the three fundamental sources depicted in Fig. 1.
failure to recognize errors or to select the
As the beliefs on which the auditor bases risk
appropriate audit test, is assumed to be neg-
assessments become well justified via triangula-
ligible, being effectively controlled through
tion, non-sampling risk due to poorly assessed
planning, supervision, review and careful
RMM or DR decreases.
selection of audit procedures whenever
While the SSA auditor gathers evidence of and
weaknesses are a concern [SAS 22, Section
from all three complementary and fundamental
311].
sources of evidence using a variety of tools,18 the
The SSA perspective holds that it is perilous to
rely on the presumption of negligible non-sam-
pling risk, especially when auditors who largely 16
Many interesting research questions pertain to how auditors
are untrained in systems thinking confront audit productively could direct skepticism towards their own judg-
risks that arise from audited entities that are com- ment processes, as we further discuss in the final section of this
paper.
plex systems. This is not an attack on the profes- 17
Interestingly, SSA’s characterization of the audit entailing
sional qualifications of the auditor, but it is a recursive risk assessment underscores yet another limitation of
more sober assessment of how difficult it is to the prevailing, traditional ARM in US authoritative guidance
assess and manage risks. As University of Chicago and today’s auditing textbooks. Citing Kinney (1983); Wallace
economist Steven D. Levitt and his co-author Ste- (1995, p. 454) argues that the ARM is particularly ill-suited for
use as an iterative evaluation tool because such use would result
phen J. Dubner observe ‘‘most of us are . . . terri- in a significant understatement of overall audit risk.
ble risk assessors’’ (2005, p. 150). Decision 18
Auditors employ an array of tools within SSA including, as
theorists have long noted that even experts have examples, strategic analysis and business-process analysis.
trouble assessing risk, ‘‘Although a distinction is These tools, while helpful, carry with them their own risks
often made between perceived and objective risks, (see, e.g., Ballou, Earley, & Rich, 2004; O’Donnell & Schultz,
2005). One concern is that auditors who lack systems-thinking
for most new and intricate hazards even so-called skills may treat the tools as an onerous documentation exercise
objective risks have a large judgmental compo- rather than as a mechanism for improving their understanding
nent. At best, they represent the perceptions of of the audited entity’s EBS.
M.E. Peecher et al. / Accounting, Organizations and Society 32 (2007) 463–485 473

triangulation perspective holds that EBS-based tions, for management’s financial-statement repre-
evidence, along with MII-based evidence that sentations (see Fig. 2). The degree of concordance
management does not normally use for financial- versus discordance between these expectations and
reporting purposes, are especially powerful sources management’s representations fuels the auditor’s
of evidence. Specifically, management is less likely recursive risk assessment process. Specifically,
to strategically distort these two sources of evi- when there is discordance between auditor’s expec-
dence relative to MII-based evidence directly used tations of management’s business representations
to support financial-statement representations or and the auditor’s observations of management’s
the representations themselves. The more difficult actual business representations, the auditor
or less likely it is for management to distort evi- acquires additional audit evidence to discriminate
dence, the greater the auditor can rely upon the whether or not the discordance is caused by mis-
evidence when revising beliefs and making risk statement or non-misstatement.
assessments. In addition, EBS-based evidence has While discordance between an auditor’s expec-
the added benefit of providing the auditor with a tations and observations with respect to an
relatively direct portal to the phenomena that account balance does not necessarily mean there
management is supposed to fairly represent in is a misstatement (e.g., an event previously and
the financial statements. reasonably assessed as having a low probability
Drawing on triangulated evidence, the auditor could occur and cause earnings to increase), it
recursively develops and revises beliefs, or expecta- does at least temporarily elevate the auditor’s

Fig. 2. The audit is a recursive process of risk (re)-assessment. (From Bell et al. (2005). Used with permission.)
474 M.E. Peecher et al. / Accounting, Organizations and Society 32 (2007) 463–485

assessment of RMM. To address the heightened members of management have and likely believe
RMM, the auditor lowers DR by developing mis- they have opportunities to distort their representa-
statement and non-misstatement explanations for tions of select business states significantly drops
the discordance and by subsequently testing the when they have good reason to assume that the
descriptive validity of these explanations with auditor is armed with a deep, up-to-date under-
additional audit evidence. An unlikely but possible standing of underlying entity business states. As
outcome is that the root cause of the discordance Levitt and Dubner (2005, p. 67) succinctly observe,
remains unresolved after further testing, in which ‘‘Information is a beacon, a cudgel, an olive
case the auditor may have to withhold an unqual- branch, a deterrent, depending on who wields it
ified audit opinion. and how. Information is so powerful that the
Bell et al. (2002, p. 8) argue that ‘‘[p]erhaps the assumption of information, even if the information
most important principle giving rise to the need for does not actually exist, can have a sobering effect.’’
SSA is the strong relation between RMM and the To summarize, we believe that auditors who
auditee’s business risks.’’ Over time, the structure presume non-sampling risk is non-negligible and,
or dynamics of the audited entity or other entities accordingly, empower themselves with a strate-
within its economic web can change, increasing or gic-systems perspective, which itself likely
decreasing the threats to the audited entity’s value- improves what auditors learn from evidentiary tri-
generating capabilities. When such threats or busi- angulation, are more likely than other auditors to
ness risks increase or spike, it generally becomes make reasonably accurate recursive assessments of
more difficult for entity management to estimate RMM and DR and reasonably manage DR.
how to fairly depict select entity business states Moreover, we believe that, relative to other audi-
within financial-statement representations. And, tors, the SSA auditor will gain credibility in the
at the same time, management generally faces 21st century, a century in which financial state-
greater temptation to optimistically distort their ment assertions likely will increasingly and criti-
business-state representations. Thus, shifts in busi- cally hinge on the complex dynamics within EBS,
ness risks have audit risk implications. and in which society is likely to continue to expect
In auditing parlance, RMM is dynamic as a high assurance about whether or not management
result of shifting business risks over time. In sys- has engaged in financial-statement fraud.
tems-thinking parlance, the stock of RMM
changes over time and the auditor must combat
changes in RMM by lowering DR when war- SSA illustrations
ranted. How RMM changes over time depends
on inflows and outflows of leading indicators of We next provide some anecdotes and examples
RMM within the audited entity’s complex eco- that one can use to clarify SSA concepts for vari-
nomic web. SSA auditors iteratively assess and ous audiences, including auditing professionals,
react to stocks and flows of RMM by adjusting and we thereafter summarize recent empirical evi-
the nature, timing and extent of their risk assess- dence that is germane to some of these concepts.19
ment procedures. Simple contexts, we have found, can powerfully
For example, the auditor employing SSA recog- illustrate the utility of SSA’s position that the
nizes that the degree to which management has an
incentive to distort selected business states depends
largely on the real current profitability of the 19
Elsewhere more comprehensive illustrations of SSA may be
entity, its prospect for future profitability, and found (see, e.g., Bell & Solomon, 2002). The KPMG LLP/UIUC
management’s belief about how their own wealth Business Measurement Case Development and Research Program
depends on investors’ and others’ perceptions of funded numerous audit and several strategic management
scholars who have provided very instructive, rich, real-world
the entity’s profitability and prospects (Bell et al., SSA cases and teaching notes. To access these prospectuses and
2002). At the same time, the auditor employing cases go to http://www.business.uiuc.edu/kpmg-uiuccases/
SSA recognizes that the degree to which strategic cases/index.html.
M.E. Peecher et al. / Accounting, Organizations and Society 32 (2007) 463–485 475

auditor should broaden the subset of EBS tradi- unhealthy perchlorate levels in the water. Extend-
tionally considered when conducting a financial- ing this line of reasoning, some comment that the
statement audit and, specifically, understand key auditor’s focus should include potential ramifica-
controls an audited entity has over its core busi- tions of severe outflows of customers or contingent
ness processes (i.e., not just so-called internal con- liabilities in the event that unhealthy perchlorate
trols over financial reporting as discussed in, e.g., levels are found. We usually prompt the audience
PCAOB AS No. 2). to think about how the auditor’s assessments of
Consider a hypothetical company that harvests, RMM as well as how the auditor would assess
treats, and bottles natural spring drinking water. and manage down DR would evolve throughout
The company recently has purchased rights to sev- the financial statement audit as perchlorate find-
eral new properties that contain natural springs ings emerged. And, we ask whether the business-
and has experienced a rapid growth in sales, inven- process controls over water quality fall under the
tories of bottled water, and accounts receivable US PCAOB’s definition of internal controls over
from bottled water sales. In the midst of this rapid financial reporting.21 ‘‘If not, why should the audi-
growth, the company has hired new employees tor care?’’ we rhetorically ask.
who unfortunately have been insufficiently trained We also use real-world companies to illustrate
in business processes used to test and ensure that the evidence-driven, belief-based risk assessment
bottled water is sufficiently free of impurities such process, especially how EBS-based informs the
as perchlorate. Perchlorate is a key ingredient of auditor’s expectations of earnings and other
solid rocket fuel and a real risk factor for drinking MBR within financial statements. One popular
water.20 company to use for such purposes is Google.
In this context, we focus on accounts receivable Although it is one of the strongest search engines
and inventory assertions and discuss several tradi- on the Internet (along with competitors such as
tional risk assessment procedures such as review- Yahoo! and MSN.com), Google is much more
ing management’s aging schedule to discern than a search engine. Google is a world-class infor-
whether the allowance for doubtful accounts is in mation generator, organizer, and conveyer that
line with prior years’ reserves, inquiring whether makes about 98% of its money selling online
management has sufficient credit checks in place real-estate on either a per-view or per-click basis
before granting credit, and physically examining to a host of advertisers. Since its IPO in 2003,
inventory of bottled water for existence. However, Google’s market capitalization has ballooned to
other risk assessment procedures emerge through over $100 billion as of March 2006. Its growth
discussion that are less traditional and rooted in has been staggering with a three-year revenue
the operational, business-process controls at the sequence of 2003 $1.5 billion, 2004 $3.2 billion
company. Audience members quickly connect the and 2005 $6.1 billion and net income sequence of
absence of safety testing and the possibility of 2003 $105 million, 2004 $399 million, and 2005
unsafe perchlorate levels in inventoried water or $1,465 million.
water previously sold on credit to customers. Google is apropos for another reason. Some
Some members suggest that the auditor can rely observers have argued that since auditors lack
very little on accounts receivable confirmations to the competency to engage in strategic-systems
test the bona fide existence of receivables because analyses but equity analysts sometimes undertake
the customers would vigorously dispute the exis-
tence of the receivable if they were to learn of
21
Warren (2002, p. 13) reports that strategic management
researchers estimate that between 50% and 60% of the variation
20
See, for example, ‘‘Ground Water & Drinking Water’’ US in business performance stems from industry-wide factors (15%
Environmental Protection Agency. http://www.epa.gov/ to 19%) and business-specific factors (32% to 45%), so the
OGWDW/ccl/perchlorate/perchlorate.html (accessed 3/25/ auditor who lacks an understanding of such factors would
2006). appear to face a steep handicap in risk assessment.
476 M.E. Peecher et al. / Accounting, Organizations and Society 32 (2007) 463–485

such analyses for firms they follow, auditors in illustrating how auditors could develop rich
should rely extensively on equity analysts’ reports expectations. This equity research firm developed
for developing their EBS understanding. We a model of Google’s EBS intended to include
believe this recommendation is without basis 95% of the possible outcomes for Google’s key
because it overlooks the auditor’s ability to learn business measures. To formulate its model,
as well as the auditor’s information advantage Oppenheimer essentially views Google as operat-
over analysts. It also overlooks the potential stale- ing within a complex system and accordingly uses
ness of analysts’ reports as well as analysts’ incen- systems dynamics to analyze implications of
tives for ensuring management has a positive underlying industry factors that drive Google’s
earnings surprise. Finally, it also overlooks the online advertising business. Examined factors
emerging practice of some public companies to include trends in search usage, search monetiza-
provide little or no guidance to equity analysts tion, cost-per-click, click-through-rates, evolving
(e.g., Coca-cola, Ford, Intel, Motorola, etc.). In relative advertising market share, and so forth.
fact, Google is one such company. As the report notes: ‘‘We examine the correla-
We have found it instructive to ask audience tions and interdependencies of industry drivers to
members to think about how auditors could study determine a range of likely outcomes (e.g., online
and lever an understanding of Google’s EBS to advertising is more likely to grow faster in a faster
develop reasonable expectations about Google’s growing advertising market than in a slower grow-
revenue. Audience members have access to Google ing advertising market).’’ To get more reliable esti-
executives’ remarks from its first-ever analyst day mates, Oppenheimer professionals form estimates
on March 2, 2006, read Google’s public filings, of each of these levers after conducting multiple
and study equity analysts’ reports on Google – interviews with industry contacts, both primary
all with the overarching objective to discover (companies themselves) as well as secondary (mar-
how auditors could form reasonable expectations ket research firms). Overall, Oppenheimer exam-
about Google’s current- and future-year financial ines 80 such levers that are deemed to be
statement assertions. predictive of Google’s future performance (e.g.,
The conclusion that emerges is that, despite search query growth, keyword pricing, monetiza-
Google’s muted guidance policy, analysts have tion rates, traffic acquisition cost rates, etc.).
developed expectations that draw heavily on evi- Finally, Oppenheimer evaluates multiple possi-
dence of and from EBS to provide earnings fore- ble scenarios based on its predictive model, and
casts, buy/sell recommendations, and stock price weights each scenario according to its assessed
predictions.22 These expectations do have a rather probability – in all it envisions how over 100,000
wide range, but Google’s auditors, who would separate EBS scenarios could unfold, with differ-
have a substantial information advantage over ent assumptions about various levers. In turn,
such analysts, should be able to develop more pre- for each EBS scenario, Oppenheimer generates
cise expectations. revenue and other estimates germane to Google’s
Oppenheimer’s January 12, 2006 equity income statements, balance sheets, and cash flow
research report on Google is particularly helpful statements.
Oppenheimer provides a sample depiction of its
95% subjective probability distribution for one
22
While auditors are not in the business of generating earnings
lever in its report: the number of Internet users
forecasts, much less stock price forecasts, we believe it may well outside of the United States as of 2010. (They pre-
be in auditors’ best interests to generate such forecasts and sumably have similar distributions for 2006–2009).
predictions for in-house use to enable better assessment of We provide a similar distribution (in millions)
audit-related risks, including auditee management’s business above. Note that the estimate is a single peaked
risk and their own business risk. Whether and the conditions
under which auditors earnings or stock-price forecasts would be
function, but it is not a common normal-bell-
more accurate than similar forecasts made by equity analysts is curve. The distribution ranges from 397.0 m to
a very interesting research question. 695.8 m users, and it has a mean of 537.9 m. The
M.E. Peecher et al. / Accounting, Organizations and Society 32 (2007) 463–485 477

peak of the distribution has an assessed probabil- Revenue ¼ Users  Queries per User  Ads per Query
ity of just under 14%.  Clicks per Ads  Revenue per Click 23

.140
It is apparent that auditors could access ger-
mane information from Google’s information sys-
.105 tems and from many third parties with whom the
auditors could correspond. For example:
.070

Mean=537.9
• Market research firms like comScore Media
.035 Metrix, Nielsen/NetRatings, and Gartner
Research. comScore Media Metrix provides
397.0 471.7 546.4 621.1 695.8
local statistics regarding the number of unique
visitors to specific websites in a locale (e.g., Bos-
Oppenheimer predicts how these levers likely ton).24 Gartner Research also provides market
will translate into eventual MBR at Google, research and consulting regarding the effective-
including gross revenues, net revenues, EBITDA, ness of online advertising.
EPS, and free cash flow. As an example, for • The United States Central Intelligence Agency
2006, Oppenheimer’s estimated distribution for and commercial entities such as ATKearney
Google’s gross revenues (in billions) look some- provide EBS evidence on the number and
thing like the following: growth trends of Internet users with broadband
capabilities.
.138 • Alexa could be tapped to provide EBS-based
evidence of the traffic to Google sites with spe-
.103 cific URL’s via Alexa Toolbar users. It gathers
statistics about different Web sites from diverse
.069 sources. Alexa Toolbar users provide informa-
tion about the sites being accessed and the
.034
Mean=10.2
speed of access.
.000 • DoubleClick’s Performics tracks trends in online
4.1 7.2 10.4 13.6 16.8 advertising. For example, they reported that
monthly cost per keyword spiked in December
2005 to $55 from its $26 August 2005 level
The question that emerges after audience mem- and then fell back to pre-December 2005 levels
bers consider such information is Why would it be in January 2006.25
unreasonable for auditors to come up with their own
estimated distribution of Google’s revenues for risk
assessment purposes? The idea that becomes clear
is that if Google’s asserted MBR later were to fall
23
in the tail of the auditor’s expected distribution, Google Analyst Day slide deck, ‘‘Continual Focus: Ads
RMM at least temporarily would elevate until Examples and Insights.’’ Also, Oppenheimer’s January 12, 2006
initiating coverage analyst report on Google similarly notes that
the auditor could investigate the reason for the ‘‘Search revenue is the product of three inputs: number of
unexpected asserted performance. search queries, conversion rate per search, and price advertisers
The feasibility of the auditor to develop such are willing to pay for a conversion.’’
24
expectations for Google’s revenues becomes See http://www.comscore.com/metrix/ls.asp (accessed
clearer once audience members observe the follow- March 25, 2006).
25
See DoubleClick’s Performics report, ‘‘Search Trend Report
ing formula that Google’s management used dur- DoubleClick Q4 2005’’ (2006, p. 2). http://www.double-
ing its analyst day presentation: click.com/us/knowledge_central/documents/TREND_RE-
PORTS/dc_search_q405.pdf (accessed March 25, 2006).
478 M.E. Peecher et al. / Accounting, Organizations and Society 32 (2007) 463–485

Some audience members ask whether auditors fraud. This predictor significantly discriminates
have been trained in the kind of analytical between a matched sample of 77 fraud firms and
model-building skills applied by Oppenheimer’s 77 control firms. Future archival, field study, and
equity analysts to develop their forecasts. Our experimental auditing research should pursue fur-
answer is no, at least not in the past, but that such ther tests of this conjecture and related research
training could well be provided and applied on questions.27
future audits. Again, auditors need not be content We also are enthusiastic about recent develop-
with exclusively relying on equity analysts for fore- ments in the economics of corruption literature
casts of future financial-statement assertions. They that demonstrate the capability of audits that draw
can acquire and apply some of the same skills but on EBS-based evidence to deter and detect man-
with much richer and confidential information to agement-level (analogous to C-Suite level) corrupt
which they have access by virtue of being an inde- activities.
pendent auditor.26 In particular, we highlight recent findings from
These two examples may seem promising a series of ingenuous studies conducted by Har-
enough, but neither example provides empirical vard economist Benjamin A. Olken (2005). The
evidence that evidentiary triangulation or any evi- studies examine missing expenditures earmarked
dence acquisition strategy that places special value for road-building in hundreds of Indonesian vil-
on EBS-based evidence helps deter or detect fraud. lages by having teams of engineers and surveyors
There is some recent archival-auditing research independently estimate the prices and quantities
suggesting auditors can use EBS-based evidence of all the inputs actually (versus assertedly) used
to detect fraud. Consistent with SSA, Brazel, for road building.
Jones, and Zimbelman (2006) conjecture that Village officials received governmental
when the auditor observes that non-financial-state- resources for road building but could corruptly
ment performance measures (e.g., facilities growth use such resources for personal profit by colluding
or employee count) move in directions that are with suppliers (who could inflate quantities or
inconsistent with financial-statement performance prices on official receipts to generate kickbacks
measures (e.g., revenue), RMM due to potential to village officials) or by manipulating wage pay-
fraudulent reporting likely increases. They also
provide empirical evidence that supports their con-
jecture by using the difference between changes in 27
Notably, a growing stream of accounting research provides
industry-specific non-financial-statement perfor- archival-empirical evidence about the value-relevance and/or
mance measures and changes in financial-state- future earnings-relevance of non-financial-statement perfor-
ment performance measures as a predictor of mance measures. As examples, archival evidence suggests that
environmental pollutants affect utilities’ market value (Hughes,
2000), environmental performance affects the market returns of
firms in a variety of industries that generate toxic waste (Al-
Tuwaijri, Christensen, & Hughes, 2004), population coverage
and market penetration improve the market value and market
26
Undoubtedly, auditors who possess IT expertise would be returns of cellular communications companies even though they
invaluable in obtaining evidence of and from MII (especially can decrease near-term future accounting earnings (Amir &
MII not construed to be part of internal controls over financial Lev, 1996), customer satisfaction is positively and sometimes
reporting) to learn the extent to which operational information nonlinearly associated with improved future earnings (Ander-
in Google’s datawarehouses as to numbers of clicks for various son, Fornell, & Lehmann, 1994; Ittner & Larcker, 1998), and
advertisers match up well with asserted revenue levels from that deposit interest rates and customer satisfaction jointly, but
major customers. According to Malacinski, Dominick, and not in isolation, predict future earnings (Nagar & Rajan, 2005).
Hartrick (2001, p. 4) there are three main locations where Web Such research provides empirical support for the SSA perspec-
data reside: backend servers, Internet Service Providers (ISPs) tive that if EBS based indicators, including non-financial-
that serve as conduits between servers and users’ browsers, and statement performance measures, seem to suggest that
users’ browsers that display Web pages. Advances in Web financial-statement performance measures are too good to be
monitoring allows for real-time analysis that cause little true, the auditor generally should elevate RMM and identify
slowdown for Web page loading. the best path of managing down PDR to the appropriate extent.
M.E. Peecher et al. / Accounting, Organizations and Society 32 (2007) 463–485 479

ments to village workers (e.g., billing the govern- What’s controversial?


ment for a higher rate than paid to villagers).
Olken randomly assigned villages into an audit Is the Development of SSA an attempt to
or no audit conditions and subsequently sent in enhance auditor’s reputations by ‘‘borrowing’’ pres-
teams of engineers and surveyors to villages in tige from consultants? Having observed that some
each condition. These teams built their own test of the activities that SSA auditors perform were
road and examined the composition of the villages’ developed and often employed by non-auditors
roads (by literally digging up 40 cm · 40 cm core (e.g., strategists, consultants), some observers have
samples at randomly selected locations), prices criticized SSA as an attempt to create confusion
paid for raw materials (by interviewing multiple about the true nature of the service being provided
suppliers and by interviewing actual customers of by auditors and to grab prestige from other fields,
suppliers), and prices paid for hourly wages and most notably consulting (see, for example, Jeppe-
hour worked (via worker interviews and surveys). sen, 1998; Robson et al., 2005).
The empirical results compellingly suggest that We find this prestige borrowing criticism to be
EBS-based evidence can detect fraud and that rather curious. Surely such critics are aware that
audits using EBS-based data can deter fraud. history is full of situations in which a product or
Among the villages who were not advised of the service or technique was developed for use in one
audit, 29.1% of the materials or labor that assert- field and subsequently was adopted in another
edly went into roadwork were ‘‘missing’’ compared field. For example, were dentists trying to steal
to only 19.9% among the villages who were advised prestige from medical doctors when dentists bor-
of the audit. This 9.2 percentage point differences is rowed anesthesia from doctors so they could pro-
both statistically significant (p < 0.05) and likely vide painless dentistry? Alternatively, were dentists
economically significant. As for the latter, Olken’s merely trying to enhance patients’ comfort while
cost-benefit analyses shows that the benefits were performing otherwise painful dental procedures?
about 150% of the cost of obtaining the EBS-based Similarly, when the SSA auditor employs business
evidence required to thoroughly audit the expendi- modeling or strategic analysis tools, he/she is try-
tures. He further conjectures that the cost-benefit ing to develop a richer base on which his/her risk
analyses might have been even more supportive of assessments ultimately will rest. Throughout this
the net benefits of the audit regime if less than a paper, we have explained that the motivation for
100% audit rate were applied, but he provides no developing SSA is audit quality enhancement.
empirical evidence on this particular issue. We also have discussed and illustrated the sources
Together, our SSA examples and recent empir- of such audit quality gains when SSA is employed.
ical evidence provide reason to believe that finan- Lastly, we contend that greater prestige and finan-
cial-statement auditors can lever EBS-based cial rewards will follow from performing higher
evidence, via evidentiary triangulation, to improve quality audits. Indeed, we believe that enhancing
the justifiability of their evidence-driven, belief- audit quality is the only sustainable way to achieve
based risk assessments about fraud. The first two the other two goals.
of the examples are thought experiments, one per- Is SSA an attempt to expand the sale of non-audit
taining to a hypothetical bottling company and the advisory services rather than to improve audit qual-
other pertaining to Google. However, the empiri- ity? This question is not voiced today as much as
cal evidence we report, is real and, in the Olken it was during the 1990s as the Sarbanes–Oxley law
study, draws on engineering evidence that would in the US and various regulatory initiatives in other
be familiar to managerial accounting academics countries have greatly limited the extent to which
and practitioners. In combination, we believe there non-audit services can be provided by audit firms
are sufficient parallels to the financial-statement to companies that whose financial statements they
auditing context exist to make a strong case for audit. Further, when raised, it has not been articu-
the emphasis placed on EBS, triangulation, and lated in a detailed enough fashion for us to discern
risk assessment within SSA. exactly what is meant (see, for example, Jeppesen,
480 M.E. Peecher et al. / Accounting, Organizations and Society 32 (2007) 463–485

1998; Robson et al., 2005). We see two lines along might first appear. It is useful to reflect on the gen-
which this question may be developed. One possibil- esis of substantive tests of details when considering
ity is that SSA auditors somehow sell more non- their role in the contemporary audit. We begin in
audit services to audit clients by virtue of their the 1800s, a time when the audit generally was a
employment of SSA. Another possibility is that service provided to the owner-manager of a small
SSA auditors embed non-audit services within the business intended to prevent and detect book-
audit, thereby effectively charging for non-audit ser- keeper and employee defalcation and error. Of
vices as part of the audit fee itself. course, at that time bookkeeping was manual
Both versions of this question may be addressed and error prone. The auditor’s work, therefore,
via a single unified response. As observed earlier consisted principally of an examination of all of
and discussed in the response to the first question, the details contained in the company’s accounting
SSA is primarily directed toward improving the books—the so-called detailed audit. The focus of
auditor’s assessment and management of DR this detailed audit was consistency within the
and thus, audit risk. Thus, to the extent that the books e.g., tests of footings, postings within jour-
external auditor performs some procedures as part nals, subsidiary journals, and general ledger, trial
of SSA that generally are offered to clients and balance and financial statements (Mettenheimer,
other organizations as non-audit services, it only 1869). Sprague (1907) described the typical
is because what can be learned from those proce- approach to the detailed audit as follows:
dures is germane to the external audit. Indeed, it
‘‘It is quite usual to work in a team of two, in
simply is not productive to classify learning activ-
the process called ‘calling back,’ ‘calling off,’
ities on the basis of the original use to which they
or ‘calling over.’ One person reads off the
have been put. Rather, learning activities are bet-
name or number of an account and the
ter thought of in terms of what one can learn from
other, turning to the proper page, responds
them. Thus, when an auditor employs techniques
with the figures. I am aware that this method
like strategic analysis and risk assessment, he/she
is used by many public accountants in
is performing an audit procedure rather than a
auditing.’’
non-audit procedure. Related, we do not under-
stand why an auditor would embed non-audit pro- And, reflecting on his experiences, Montgomery
cedures within the audit engagement as a means of (1939) noted that, ‘‘In some audits, and not only
selling the former. Indeed, it is our understanding small ones, we verified every footing and every
that fee constraints, especially during the 1990s, posting.’’ Such exhaustive verification, however,
were much greater with respect to audit services consisted of assuring mathematical accuracy and,
than non-audit services. as noted earlier, consistency within the company’s
Are too few substantive tests of details performed books.
under SSA? Some observers have contended that Even before the dawn of the twentieth century,
auditors employing SSA effectively over-rely on however, the feasibility of a selective rather than a
other procedures (e.g., analytical procedures) detailed audit was being discussed. One sees, for
thereby reducing the extent of detailed substantive example, a pre-1900s New York CPA exam ques-
testing to problematic levels (e.g., Knechel, 2005). tion asking – In an audit where an exhaustive
Our view is that the sufficiency and competency of detailed examination . . . is not stipulated or practi-
the requisite audit evidence in specific circum- cable, what examination is necessary to assure . . .
stances is a matter of professional audit judgment. general correctness? As business organizations
That said, we have argued that it generally is pref- grew larger and more complex, it became generally
erable for audit evidence to be obtained from the recognized that the audit had to evolve to selected
three fundamental sources – EBS, MII and MBR tests of the account details rather than examining
(see Bell et al., 2005). all of the details in the companies books (Staub,
The role of substantive tests of details in today’s 1942). These tests came to be called substantive
audit landscape is a more complex issue than it tests of details. Importantly, for many years such
M.E. Peecher et al. / Accounting, Organizations and Society 32 (2007) 463–485 481

tests would be focused on the internal consistency tant audit issues (Bell et al., 2005, pp. 20–21; Mautz
among the details contained in the company’s & Sharaf, 1961). As a consequence, the auditor per-
books. Indeed, in the US it was not until the afore- forms tasks (e.g., confirms receivables) that pro-
mentioned McKesson and Robbins case in the duce evidence that, in turn, forms the basis for
1930s that substantive tests of details took the belief formulation and revision (see Fig. 2). Then,
auditor out of the MBR into the MII and to a lim- based on such beliefs, the auditor assesses risks
ited extent, into the EBS (e.g., observe the com- and in turn, is able to make choices, initially about
pany’s inventory counts). the additional procedures to perform but ulti-
Another change of great import during the late mately about the audit report that is most appro-
1800s is the rise of absentee ownership. The impli- priate in the circumstances. The key point here is
cations for the auditor were manyfold, but most that even the most powerful audit procedures gen-
notably, detection of management fraud that erally do not provide a basis for justifiable certi-
causes the financial statements to be misstated tude. That is the case even for classical
appeared on the auditor’s radar screen, while substantive tests of details. Indeed, one need look
detection of bookkeeper fraud became a less no further than infamous cases of alleged audit fail-
important audit objective. While the extent to ures such as the ZZZZ Best case in the US or the
which auditors are responsible for detecting such more recent Royal Ahold case. In the former case,
management fraud has been contentious, society the auditors visited ostensible insurance restoration
now seems to have spoken. Specifically, there sites but, unknown to the auditor, management
now seems to be little doubt that the auditor is had staged these sites in their entirety (Domanick,
responsible for providing reasonable assurance 1989). In the latter case, unknown to the auditor,
(which is high assurance) that financial statements confirmations send by the auditor to third party
are free of material misstatements due to manage- vendors were allegedly intentionally falsified (see
ment fraud. SEC, 2005). Inasmuch as the auditor today must
In today’s world, while concerns continue to provide high assurance with respect to these types
exist about unintentional financial statement mis- of fraud, it is no longer acceptable, if it ever were,
statements (i.e., errors), there are equal or even to think that these or any other audit acts can pro-
greater concerns about intentional misstatements duce evidence that supports justifiable certitude.
(i.e., due to management fraud). Indeed, the spate What do we know about economic (cost) consid-
of alleged audit failures that appear to have trig- erations under SSA? Some observers have argued
gered massive new regulation in Australia, US that perhaps the primary motivation for the devel-
and several other countries generally claim that opment of SSA was a desire to control the costs of
the auditor failed to detect alleged financial-state- producing audits (see Knechel, 2005; Robson
ment fraud in a timely manner. The ability of tradi- et al., 2005). It is true that the period in which
tional audit procedures to detect fraud is suspect, SSA was developed was characterized by signifi-
however, especially if the auditor performs them cant audit pricing pressures. SSA, however, was
without making their nature, timing, and extent not, to our knowledge, conceived as a way of driv-
conditional on a deep understanding of the audited ing down audit costs. Rather, SSA was conceived
entity’s EBS. We believe that SSA’s evidentiary tri- to bring greater value to the audit by enhancing
angulation framework provides considerable audit quality. And, indeed implementation and
promise for the major challenge of improving the ongoing refinement of SSA has significant, if not
auditor’s fraud detection capabilities. enormous, intellectual and other resource
Are all audit procedures really risk assessment implications.
procedures? We have contended that the essence For example, as noted earlier, the SSA
of auditing is evidence driven, belief based, risk approach holds that audit quality is enhanced
assessment. Implicit in this contention is the notion when auditors apply strong systems-thinking
that justifiable certitude (required for one to have skills. Yet, it is unclear how many auditors practic-
knowledge) is rarely, if ever attainable for impor- ing today actually possess such skills. While some
482 M.E. Peecher et al. / Accounting, Organizations and Society 32 (2007) 463–485

auditing educators now integrate systems thinking the association between SSA implementation,
in their audit courses, greater coverage of systems audit costs, audit hours, and audit-team mixture.
thinking in both university audit courses and audit How can SSA be effective when auditors have
firm training likely is warranted. Meanwhile, audit such difficulty implementing it? When authors
firms may well benefit from hiring or retaining the (e.g, Curtis & Turley, 2006) or others pose this
services of a significant number of strategic man- question, our typical response is to ask another
agement or engineering professionals who are sys- question — Is it better to perfectly implement an
tems thinkers, especially those with considerable inferior strategy or imperfectly implement a supe-
industry-specific expertise. rior strategy? Moreover, as learning is itself non-
As another example, the SSA approach holds linear, we contend that too little time has passed
that audit quality is enhanced by greater deploy- to truly judge how well auditors will be able to
ment of more senior professionals (managers and implement SSA; better education and training,
partners) relative to a traditional audit. More coupled with a greater appreciation for the value
senior professionals are more likely to possess of high audit quality by persons involved with cor-
the greater understanding of the client organiza- porate governance and society in general bode well
tion1s business and industry than are more junior for the future implementation of SSA.
professionals. Thus, a richer audit-team mix (i.e., We also respond to these and similar questions
relatively more partner and manager time) likely with a reminder that it is plainly hasty to assert
is spent on the audit for SSA audits, relative to tra- that SSA per se contributed in any fashion to
ditional audits. Related, for SSA audits, relative to any recent alleged audit failure. Even the coinci-
traditional audits, there should be more variability dence of alleged audit failures and audit methodol-
in the audit team composition and in the audit ogies that share some properties with SSA
procedures performed across audits by team mem- provides a very weak cue to causality. One gener-
bers. These notions are not consistent with cost ally should avoid inferring causality simply from
control being the primary motivation. temporal contiguity (Einhorn & Hogarth, 1986).
Of course, questions about the extent to which We do not have the ability to know how many
the SSA audit methodology increased or decreased of the recent alleged corporate frauds and lootings
the costs of audits and whether such costs were or how many more of these instances would have
passed on to audit clients are empirical in nature. emerged in the absence of SSA, nor do we yet
To date, very little empirical evidence directly know much about just how closely the audit pro-
addresses these questions (but see, e.g., Blokdijk, cesses associated with alleged audit failures faith-
Drieenhuizen, Simunic, & Stein, 2003). Archival fully implemented important facets of SSA.
evidence from 1989, which predates SSA, indicates
a positive association between business risk and
audit hours (Bell, Landsman, & Shackelford, Concluding remarks
2001). This association is consistent with auditors
responding to increases in business risk by increas- Society has loudly and clearly communicated its
ing audit work instead of by simply charging a demands with respect to the veracity of external
higher underwriting-like fee premium. More recent auditing. Explicit or implicit conceptions of audit-
archival evidence from the period 1996–2001, ing as what auditors have been doing are unlikely
which falls within the window in which SSA to lead to significant progress in addressing those
emerged, also indicates a positive correlation demands. We have suggested in this paper that
between business risk (e.g., due to corruption con- Strategic-Systems Auditing (SSA) is one way to
cerns) and audit costs (Lyon & Maher, 2005). Fur- re-conceive the audit with substantial promise for
ther, it appears that the auditor passes these meeting society’s needs and demands for high-
incremental costs to the audit client via higher fees. quality audits. We recognize, however, that we do
Additional archival-empirical research certainly is not have a monopoly on good ideas—we encour-
warranted, however, to more directly measure age others to develop and report other conceptions
M.E. Peecher et al. / Accounting, Organizations and Society 32 (2007) 463–485 483

of auditing and attendant audit approaches that EBS-based evidence may contain more noise than
may hold similar or greater promise. does other evidence.
We also recognize that the promise of SSA is Three, many research questions pertain to ways
more likely to be realized if there are accompany- for auditors to direct skepticism towards their own
ing enhancements to accounting education. We judgment processes. One way for scholars to pro-
find it useful to think about the kinds of knowl- ceed would be to consider how individual auditors,
edge and skills it would be helpful for auditing stu- multiple auditors, or entire audit firms could
dents and auditors to acquire via education and implement this variant of skepticism. For example,
training. For SSA to be effective, auditors require individual auditors could build in a cushion for
knowledge of disciplines such as strategic manage- error, defer rapid cognitive closure (Kruglanski &
ment, business policy, and systems dynamics. Fur- Webster, 1996) or explicitly counter explain why
ther, they need to be equipped with skills to apply arguments underlying a risk assessment or other
and lever such knowledge. Examples of applicable audit judgments could be problematic (cf., Koo-
skills include systems-thinking skills, risk- assess- nce, 1992). As another example, audit teams could
ment skills, and model-building skills. We believe appoint aggressive devil’s advocates into key con-
that, at least historically, accountancy curricula sultations or discussions (cf., Kennedy, Kle-
insufficiently incorporated these kinds of knowl- inmuntz, & Peecher, 1997), or they could require
edge and skills. multiple auditors to assess risks and work from
And, finally, we recognize that there is a huge the composite assessment (Surowiecki, 2004).
need for research on many of the elements of Finally, for select audit engagements, an audit firm
SSA. Throughout this article we explicitly have or the profession overall could exercise such skep-
noted several opportunities for research, and the ticism by, for example, employing predominantly
astute reader will have inferred numerous other contemporaneous (instead of predominantly retro-
opportunities. Before closing, though, we would spective) second-partner reviews or peer/regulator
like to emphasize three areas that we believe to reviews. Similarly, for select engagements, an audit
hold much potential for bearing fruit. One, firm or the profession could require dual audit
researchers should consider productive ways to teams, perhaps from different firms (cf., Francis,
reconfigure if not overhaul the traditional audit Richard, & Vanstraelen, 2006).
risk model. For years now, audit researchers have If audit scholars and educators faithfully and
identified multiple shortcomings of this risk model fervently pursue these instructional and research
(e.g., Cushing & Loebbecke, 1983; Kinney, 1989). opportunities, we believe that there would be a sig-
Our view is that the cumulative weight of these nificantly improved chance of SSA evolving to sat-
individual papers, when coupled with our observa- isfy society’s unwavering demand for audits
tion of the model’s bold suppression of non-sam- providing high assurance against material misstate-
pling risk, strongly suggests that a new model of ment, whether due to management error or fraud.
audit risk is warranted.
Two, although we believe that evidentiary trian-
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