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SAS 70 | Overview & Analysis of Type I and Type II Audit Reports

Statement on Auditing Standards No. 70, commonly known as SAS 70, is a highly recognized auditing standard put forth by the American Institute of Certified Public Accountants (AICPA). In CPA technical terms, it’s used to report on controls placed in operation (Type I audits) and tests of operating effectiveness (Type II audits). In simpler terms, it’s an audit used by auditors for examining the control environment of service organizations.

SAS 70 Type I Audits

Type I audits are looked upon as an audit done for a snapshot in time. Essentially, a service organization’s control environment is examined by auditors for a specific date in time, such as August 27, 2008. What this means is that the audit report issued for the service organization is a report on controls placed in operation for August 27, 2008. You might be asking how relevant is an entity’s control environment that is examined and attested for by a CPA firm for only that single day? Well, not too terribly relevant, and as such, SAS 70 Type I reports have limited value from a regulatory compliance perspective. They are, however, seen as an excellent stepping stone in moving towards a SAS 70 Type II audit, which actually tests controls over a state time period. Furthermore, it must be noted that SAS 70 Type I audits do not suffice for Sarbanes Oxley, as only a Type II report provides the necessary assurances for section 404 internal control requirements for user organizations. Sound a little confusing? Let me explain in detail the relationship between Sarbanes Oxley (SOX) and SAS 70 audits, which will hopefully clear up any vagueness or misunderstandings you might have.

SAS 70 and SOX

The unique relationship between SOX and SAS 70 begins with section 404. Because management must report annually on the effectiveness of internal controls, it then has an obligation to examine all controls considered vital to the organization (user organization in SAS 70 jargon) as a whole, but more importantly, to its financial reporting process. And because a large number of publicly traded companies outsource numerous critical services, these outsourcer providers, known as service organizations, are considered an integral component for purposes of financial reporting. Therefore, an in-depth, due-diligence process must be enacted to have their internal controls observed and certified. The Securities and Exchange Commission’s (SEC) Chief Accountant and the Division of Corporation Finance has stated that “In many situations, a registrant relies on a third party service provider to perform certain functions where the outsourced activity affects the initiation, authorization, recording, processing or reporting of transactions in the registrant’s financial statement. In assessing internal controls over financial reporting, management may rely on a Type 2 SAS 70 report.”

SAS 70 Type II Audits

Type II audits are audits conducted over a stated time period, usually anywhere from six (6) to twelve (12) months, however, circumstances can arise where the audit is done in a shorter time period. SAS 70 Type II audits suffice for SOX regulatory requirements and are seen as effective, viable audits done on service organizations for examining their control environment. Because Type II audits actually test the worthiness of internal controls over a stated time period, these audits have wide acceptance through many industries and are looked upon as the de facto audit for examining a company’s internal controls. Type II audits can take a considerable amount of time and effort in planning and preparation. Most organizations begin with a SAS 70 Type I audit, then move towards Type II compliance in subsequent years. However, some organizations do go directly towards Type II compliance; it all depends on the circumstances that arise for service organizations.

What is a Service Organization?

Service organizations are essentially third-party outsourcing entities that provide critical services to another company. Common example of these service organizations are payroll companies, third party administrators (TPA), data centers, Software as a Service (SaaS) providers, medical claims and billing companies, fulfillment houses, along with many others.

Preparing for a SAS 70 Audit

The best way to prepare for a SAS 70 Type I or Type II audit is to undertake a SAS 70 Readiness. Any reputable CPA firm should be able to provide you with a series of sas 70 readiness questionnaire forms and templates which will help identify the scope of the audit, while giving your organization a good understanding of what the audit actually entails. Even more, sas 70 readiness questionnaire forms and templates will help your organization identify any gaps, remediation, or deficiencies that will need to be addressed and corrected before the audit commences. It’s a good example of being proactive in the audit process, ultimately allowing for a high degree of efficiency and cost effectiveness for the SAS 70 Type I or Type II audit.

If You Are considering having your organizatin go through a SAS 70 Type I or Type II audit, then SAS 70 sample reports are available from the SAS 70 Resource guide.

About the Author

Expertise in the following areas: SAS 70 audits, Regulation AB Item 1122/1123 compliance, Sarbanes-Oxley compliance.

Keen understanding and sound interpretation of all compliance rulings/regulations and associated standards/frameworks/methodologies used for auditing and risk assurance compliance:

GLBA, Sarbanes-Oxley, HIPAA, FISMA, FFIEC, COBIT, COSO, ISO 27001. Payment Card Industry Compliance, Securities Compliance (Regulation AB-1122/1123).

Additionally, advanced search engine optimization (SEO) and online viral marketing expert.