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Audit programs were specifically mentioned in SAS No. Audit programs may provide evidence of audit planning as well as limited evidence of the execution of audit procedures, but the Board believes that signed-off audit programs should generally not be used as the sole documentation that a procedure was performed, evidence was obtained, or a conclusion was reached.An audit program aids in the conduct and supervision of an engagement, but completed and initialed audit program steps should be supported with proper documentation in the working papers. The proposed standard would have adapted a standard of reviewability from the U. General Accounting Office's ("GAO") documentation standard for government and other audits conducted in accordance with generally accepted government auditing standards ("GAGAS").Audit documentation may be in the form of paper, electronic files, or other media. The Board's standard on audit documentation is one of the fundamental building blocks on which both the integrity of audits and the Board's oversight will rest.The Board believes that the quality and integrity of an audit depends, in large part, on the existence of a complete and understandable record of the work the auditor performed, the conclusions the auditor reached, and the evidence the auditor obtained that supports those conclusions.Also, other changes made the requirements easier to understand.The following sections summarize significant views expressed in those comment letters and the Board's responses to those comments. The objective of this standard is to improve audit quality and enhance public confidence in the quality of auditing.This principle is not new and was found in the interim standard, SAS No. Audit documentation also should demonstrate compliance with the standards of the PCAOB and include justification for any departures. The proposed standard would have adapted a provision in the California Business and Professions Code which provides that if documentation does not exist, then there is a rebuttable presumption that the work had not been done. The objections to this proposal fell into two general categories: the effect of the rebuttable presumption on legal proceedings and the perceived impracticality of documenting every conversation or conclusion that affected the engagement. They argued that the rebuttable presumption might be understood to establish evidentiary rules for use in judicial and administrative proceedings in other jurisdictions. Some commenters also had concerns that oral explanation alone would not constitute persuasive other evidence that work was done, absent any documentation.

If the work was not documented, then it becomes difficult for the engagement team, and others, to know what was done, what conclusions were reached, and how those conclusions were reached.

In addition, good audit documentation is very important in an environment in which engagement staff changes or rotates.

Due to engagement staff turnover, knowledgeable staff on an engagement may not be available for the next engagement. Several commenters suggested that audit documentation should include audit programs. The Board accepted this recommendation, and paragraph 4 in the final standard includes audit programs as an example of documentation.

This experienced auditor also should have been able to determine who reviewed the work and the date of such review. Some commenters suggested that the final standard more specifically describe the qualifications of an experienced auditor.

These commenters took the position that only an engagement partner with significant years of experience would have the experience necessary to be able to understand all the work that was performed and the conclusions that were reached.

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