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2010

Internal Auditing and Management Testing: Sampling


Techniques
By
Finn Consulting LLC James J. Finn, MBA, CISA, and CIA
Independent Consultant
James J Finn
James J. Finn, is the founder of an independent Financial, IT, and
ICFR consulting business, and has worked as a CFO, program
manager (PMO), internal auditor, and compliance consultant for
small, medium and large public companies and for Mutual Insurance
Companies. Mr. Finn holds a BSBA degree in Finance with Honors,
and an MBA from Northeastern University, Boston Massachusetts. Through the years, Mr. Finn
has acquired over 25 years of hands-on experience at various financial positions ranging from
Management Trainee at the First National Bank of Boston, to CFO and VP of Finance at a
commercial printer, Dynagraf Inc. Also, as a qualified, CIA, and CISA, he has focused on
internal controls and compliance programs for Sarbanes Oxley, since 2004.
In addition to authoring this Guideline, he has written comments to the SEC on Sarbanes
Oxley related issues, and was the editor for a comprehensive accounting policy and procedures
guideline for Digital Equipment Corporations worldwide internal Product Line Management
Accounting system, and a White Paper titled The Great SOX Caper which discusses the
impact of AS-2 and AS-5 on SOX programs.

Version 1.50, 2/10/10

While this document is believed to contain correct information, the author, James J. Finn does
not make any warranty, express or implied, or assume any legal responsibility for its accuracy,
completeness, or usefulness. Reference herein to any specific product or publication does not
necessarily constitute or imply its endorsement, recommendation, or favoring by the author. The
views and opinions expressed are those of the author.

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Table of Contents

I. Guideline Overview.................................................................................................3
A. Description.......................................................................................................3
B. Scope and Application of the Guideline..........................................................3
C. Purpose of the Guideline..................................................................................4
II. Sampling and Risk...................................................................................................5
A. What is sampling?............................................................................................6
B. What is Sampling Risk?...................................................................................7
III. Sample Bias.............................................................................................................9
A. Risk of Sample Bias.........................................................................................9
B. How Sample Bias Arises................................................................................10
1. Bias from Sampling Procedures..........................................................10
2. "Crazy Eddies, Inc.", an example of fraud..........................................12
IV. Use of Sampling in Auditing.................................................................................15
A. Sampling Methods and Procedures................................................................15
B. Statistical Sampling........................................................................................17
1. General considerations.........................................................................17
2. Specific Considerations for Auditing...................................................20
3. Valid Statistical Sampling Examples...................................................21
C. Nonstatistical Sampling.................................................................................27
1. General Considerations:.......................................................................27
2. Specific Considerations for auditing...................................................28
D. Testing of Controls, Non Inferential sampling...............................................32
1. Intended End Use of a Sample (inferential vs. non inferential)..........32
2. Sampling Steps for tests of Controls...................................................36
E. Practical Limitations on Sampling.................................................................37
F. Statistical Inference and Sample Size............................................................38
G. The Rise and fall of Statistical Sampling in Auditing....................................39
V. Effective Statistical Sampling................................................................................40
A. Probability Theory.........................................................................................40
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B. Sampling Method vs. Sample Selection Methods.........................................41
1. Techniques for selecting samples........................................................42
VI. Comparative Analysis of Sampling.......................................................................44
1. Sampling in Financial Reporting Processes........................................44
2. Statistical Process Control (SPC)........................................................45
Bibliography......................................................................................................................45

I. Guideline Overview

A. Description

This guideline surveys the concepts underlying the use of sampling techniques to
strengthen the sufficiency, relevance, and reliability of evidence collected to support internal
audit conclusions and managements testing for internal control and financial reporting procedure
effectiveness. Evidence that is derived from effective sampling techniques would be one way of
fulfilling the requirements of Practice Advisory 2310-1: Identifying information, and, since
sampling is based on testing a relatively small number of items, it can be a cost effective
technique. This guideline is intended to provide practical information related to improving
sampling techniques. In addition, this guideline reviews the history of sampling, and provides
examples of erroneous conclusions in auditing caused by intentional sample bias (fraud) or by
unintentional sample bias (incorrect sampling training or techniques). Sampling is viewed in a
comparative manner that provides insights into the use of similar sampling techniques in
industries where sampling is governed by military specifications, and ISO commercial standards.
Sampling, as used in internal auditing, has generally relied on the PCAOB authoritative
guidance contained in AU 350, the AICPA Audit Guide, and the prior AICPA guidance as
provided by SAS-39, which has been amended by SAS-111. These sources are analyzed and
expanded upon to address the practical application of statistical and non-statistical sampling
techniques for internal auditing and management control testing.

B. Scope and Application of the Guideline

Sampling is essentially a process of gathering partial information with an expectation that


the partial information can be used to determine either a statistic (e.g. the mean, or median value)
of a population of interest, or to estimate the percentage of occurrence of an items feature
(attribute) in a population of interest. In addition to using sampling to determine statistics for a
population, sampling can also be used to determine the probability that a lot or batch of
products or transactions have an acceptable percentage of deficiencies. This application of
sampling is generally referred to as Lot Acceptance testing, or, in auditing, as controls
testing. In each case, sampling and examining items for a statistic or the presence or absence of
an attribute is a process, which can be used with great effect by an internal auditor or
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management to acquire an understanding of the population being audited. Examining a sample
provides one basis for reaching a conclusion regarding a populations statistic (mean or
deviation), or of a controls acceptability or effectiveness based on control attributes. Once an
auditor has reached a conclusion regarding the features or statistics of interest for a population,
then the process of sampling and testing can be considered complete. However, the conclusion
reached as a result of sampling and examination still must be presented and accepted by
management in order to provide any practical business value from the effort. Issues related to
sampling procedures and techniques used to reach the conclusion, may be questioned by
management or peers who have a different view of the results.
Once a conclusion has been reached based on a sample, management, (the auditee) can
challenge the credibility and believability of the sample and the auditor may be in a position of
having to prove that their conclusion (and sample) were credible. Of course, if the conclusion is
one favorable to the auditee, then there may not be any questions about the sampling method or
inference; however, if the auditee was Crazy Eddies (See Section III, B, 2), and a sample of
inventory item quantities indicated that many of the inventoried product boxes were empty, or
did not exist, and that the count sheets were overstated, then the auditor would be required to
have used a defendable sampling method to support the unfavorable conclusion.
If an unfavorable result based on sampling is being challenged, a full statistically valid
sampling methodology with a tight confidence level and precision interval should be used to
verify the initial results. This will generally result in a relatively large or larger, sample size. If a
larger sample size is required to provide adequate credibility to support an unpopular, but valid
negative conclusion, the benefit to stakeholders may outweigh any reasonable cost.
Alternatively, if a statistically valid sample is impractical, a nonstatistical sample can still
provide supporting audit evidence by properly considering other elements of the audit risk
structure and taking additional precautions such as narrowing the sample frame, selecting as
large a sample size as is practical, and selecting only the most relevant document(s) to be
sampled.

C. Purpose of the Guideline

The purpose of this guideline is to provide an analysis related to the use of sampling
methods and sample selection techniques for management testing and internal auditing. In
addition, a secondary purpose is to provide a context for using sampling plans in internal
auditing and management testing for compliance programs such as Sarbanes Oxley. The scope
will include researching relevant authoritative auditing guidance, and work by others on using
sampling and probabilities in internal auditing. Also in scope will be a comparison of control-
testing sample plans with similar sample plans as they have been developed and used
commercially in other industries. A focus for this comparison will be on the special application
of attribute sampling referred to as Testing of Controls, or, in manufacturing quality control,
Lot Acceptance sampling. Acceptance sampling plans are widely used in manufacturing for
quality control actions such as sentencing product lots as either accepted or rejected base on
assertions of an acceptable quality level. Also in-scope is basic probability concepts related to
sampling, and inferential statistics. The importance of sample risk as it relates to the selection
of a sample frame is discussed to ensure that the sample frame is representative of the
population, and that sources of potential errors that may be introduced by inadequate sample
sizes are highlighted. A further purpose of this guideline is to move beyond an intuitive

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acceptance of samplings credibility and ease of communication, to acquire an understanding of
the quantitative risks of sampling techniques. This understanding will assist the practitioner to
develop an unbiased and accurate view of the sampling processes and procedures being applied,
and to avoid becoming an unsuspecting victim of excessive sampling risk, or of fraudulent and
erroneous sampled data.

Sections II and III examine, some of the risks associated with sampling, especially
sample bias, that can distort the source of samples (the sample frame), and produce results that
are erroneous. An unknown sample risk from sample bias occurs whenever there is a systemic
bias or preference in selecting the sample that results in drawing items from a population in a
non-random or preferential manner without that being the auditors intention. Examples of
sample bias and its impact on audit conclusions or decision-making are presented. Section III
focuses specifically on sample bias and examines some of the common causes of biased
sampling.

Section IV analyzes the uses of sampling within the auditing profession, and provides an
examination of the history related to the use of statistical sampling and non-statistical sampling.
In addition, this section provides an introduction in to Acceptance sampling which highlights
the sometimes-confusing aspects of using small sample sizes to test internal control
effectiveness. Also examined in this section are some of the limitations of sampling techniques,
including the risks involved in projecting or inferring sample features to a population. Section IV
evaluates both statistical and nonstatistical sampling methodologies and compares them in terms
of their relative strengths and weaknesses. It highlights appropriate ways to apply sampling when
auditing financial transactions and processes. This section also examines the auditing
community's acceptance of statistical sampling,i and the observed recent reluctance for applying
the more reliable and involved statistical methods of sampling in day-to-day audit work (See
Section IV, F). Section IV also explores non inferential sampling and how the Testing of
Controls and the Sarbanes-Oxley Act have impacted the auditors use of sampling in ways other
than to project values and percentages to a population.

Section V develops a background and understanding of the underlying Probability


concepts supporting statistical sampling, as well as examining the various methods of selecting
samples whether they are statistical samples or non-statistical sample plans.

Section VI compares sampling as used in internal auditing with similar attribute based
Acceptance Sampling plans in wide use in the high-tech and other industries, and also briefly
discusses the concepts used in sampling for Statistical Process Control (SPC).

II. Sampling and Risk

Internal auditing employs many methodologies and techniques to provide management


with assurances that assets are being safeguarded, operations are being performed as intended,
and that the organization is in compliance with laws applicable to the company. One of these
techniques consists of sampling a population and testing the sample, and, as a result, increasing
the auditors' knowledge about the population. However, sampling carries with it the risk that
what is selected for the sample is not the same as what is in the population. This is the major risk

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of using samples to form conclusions. This risk that the sample does not represent the population
is referred to as sample risk, or sample bias.
Using a well-designed sample plan provides one source of sufficient evidence to support
an auditors conclusionii, and, using a statistically valid sampling plan provides the strongest
basis for a quantitative measure of sample riskiii. It also provides a sample size and selection
method that is representative of the population. The intuitive nature of sampling enhances the
persuasive power and credibility of auditing or testing by supporting the technique of inferring or
projecting features from the sample to the larger population. Furthermore, because sampling and
projecting features of the sample to a population can also be intuitive, it is a simple method for
communicating auditing results across barriers such as different backgrounds, specializations,
levels of authority, and complex technical specifications. This section introduces the basics of
sampling, the benefits, and the risks.

A. What is sampling?

Sampling is selecting less than 100 percent of items from a population that contains the
complete set of the items of interest, and evaluating only the selected items for a pre-determined
value, characteristic, or attribute. The population is frequently either an account with transactions
that have amounts making up the account balance, or a document that has evidence of the
performance or completion of a control procedure. The Audit Standards define audit sampling as
follows:

Auditsamplingistheapplicationofanauditproceduretolessthan100
percentoftheitemswithinanaccountbalanceorclassoftransactionsforthe
purposeofevaluatingsomecharacteristicofthebalanceorclass.1 Thissection
providesguidanceforplanning,performing,andevaluatingauditsamples.iv

This definition is specific, but is not quite identical to some working definitions used outside of
the audit profession. A definition that may be closer to one used by a business process control
manager, or general business manager could include a reference to inferring or projecting the
measured characteristic of the sample to the population. However, this difference of a reference
requiring projecting results from samples to the population is referenced in different areas of the
audit standards.
Using a sample to infer or project conclusions about a population characteristic is a
technique universally used in many aspects of business, as well as professions and trades. For
example, a criminologist may sample substances obtained during a drug raid to decide if the
entire lot is an illegal substance. The medical profession relies on extensive sampling through
clinical trials in order to determine if new pharmaceutical compounds are safe for human use.
Aircraft engineers sample and test metals and other aircraft and technical components to
determine if they will perform according to design expectations. One definition of sampling that
expresses this purpose of sampling was found in an Internet article related to Six Sigma
sampling, which defines sampling as follows:

Sampling is a method to draw inference about one or more characteristics of a


large group by examining a smaller but representative selection of group items.
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This selection is referred to as the sample. This selection can be probability
driven or judgment/non-probability driven. v

As discussed earlier, the initial difference in definitions (i.e. projecting characteristics


from the sample to the population) is compensated for in the first sentence of a separate
paragraph of the auditing standard, which states: The auditor should project the misstatement
results from the sample to the items from which the sample was selected.vi Thus, on a
conceptual level, the definition and purpose in AU Section 350 of sampling is essentially the
same as the more general commercial definition once the concept of projecting characteristics of
the sample to the population is considered. This is significant, since once it is concluded that
inferring and projecting sample characteristics to a population is an objective that is included in
the auditing standard, then additional considerations must be taken during sampling to ensure the
sample used is valid for inferential applications. This is especially true when selecting a sample
frame and determining the sample size - since these are two areas where the overall sample risks
can be affected by the representativeness of the sample. Also, since projecting or Inferring
characteristics from the sample to the population is part of the standard, it is critical that
practitioners understand the difference between Classical sampling and Acceptance
sampling which is discussed in Section IV, D, Non Inferential Sampling.

B. What is Sampling Risk?

Sampling risk is a significant component of overall audit risk. Audit risk consists of both
sampling risk and other risks, which may be procedural in nature, or related to other factors
involved in the audit. The auditing standards address audit risk as follows:

The uncertainty inherent in applying audit procedures is referred to


as audit risk. Audit risk includes both uncertainties due to sampling and
uncertainties due to factors other than sampling. These aspects of audit risk are
Sampling risk and non-sampling risk, respectively. 3 [As amended, effective
for audits of financial statements for periods beginning on or after December
15, 006, by Statement on Auditing Standards No. 111.]vii

Sampling risk occurs because there is a probability that the items selected as a sample
are not representative of the population. As a result, the sampled items deviations, or their
percent of attribute successes or failures may not be the same in the sample as they are in the
population. Thus, the auditor evaluating the characteristics of the sample may not reach the same
conclusions they would if they examined the entire population.viii Selection of samples that are
not representative of the population can occur as the result of errors made in the sample
procedures such as the determination of the sample frame and/or the sample size. These sampling
errors can come from multiple sources, but the increased sample risk resulting from errors is
usually caused by not including a sufficient representation of the populations variability or
attribute proportions in the sample. A sample may be biased systemically and, as a result, not be
representative of the population. A sample may be sized too small and, as a result, not represent
all dispersions or attributes of items in the population. A sample bias may result from an
intentional or unintentional selection of a stratum, or an incorrect portion of the true population,
or result from a subjective, but inadequate, determination of sample size. Of the potential sample
errors mentioned, sample bias by an incorrect sample frame selection, or by the determination of
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an inadequate sample size, can be a very significant source of sampling risk. The possibility that
an auditor may reach an incorrect conclusion because of a sampling error (sample risk) is
addressed in the audit standard as follow

Sampling risk arises from the possibility that, when a test of controls
or a substantive test is restricted to a sample, the auditor's conclusions may be
different from the conclusions he would reach if the test were applied in the
same way to all items in the account balance or class of transactions. That is, a
particular sample may contain proportionately more or less monetary
misstatements or deviations from prescribed controls than exist in the balance
or class as a whole. For a sample of a specific design, sampling risk varies
inversely with sample size: the smaller the sample size, the greater the
sampling risk.ix

Sampling risk is classified in the audit standards by the potential impact of sampling
errors on the conclusions that an auditor may reach. These risks of potentially incorrect
conclusions are divided into two categories. The categories relate to conclusions effecting either
substantive testing or the testing of controls.

Substantive testing risks are:

a) The risk of incorrect acceptance.


b) The risk of incorrect rejection.

Control testing risks are:

a) The risk of assessing control risk too low.


b) The risk of assessing control risk too high.

Refer to the auditing standards for details.x

It is important to note that, for financial auditors, the impact of assessing control risk either too
low or too high is to affect the determination of the level of substantitive testing required by an
external auditor. Thus, if control risk is assed as being too high, it simply means that more
substantive testing will be applied than may have been needed. However, for control procedures
design, if management testing assesses control risk as either too high or too low, the process
control design can be completely ineffective, or can result in an excessively costly overdesign of
the control procedures. Because of this difference in the end use of the sampling and testing
results, management testing for the purpose of designing and implementing internal control
processes and procedures should be more robust and employ larger sample sizes than would be
adequate for acceptance testing (control testing). The elimination or reduction of sample bias is
so important when the results are to be used for design purposes, that 100% testing, or a
statistically valid sample size should be used wherever possible rather than acceptance sampling
techniques. As a result of the importance of the risks of sample bias, and of the impact sample
risks can have on audit conclusions, the sources and relevance of sample bias are reviewed next.

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III. Sample Bias

A. Risk of Sample Bias

Regardless of the particular techniques employed, all sampling methods base their
efficacy on selecting a representative sample from a larger population of items. The sample must
be selected from a population with the necessary attributes or values of interest. Otherwise, the
sampling results will fail to represent accurately the characteristic values or attributes being
tested for the audit. A sample frame can be misleading whenever it does not include items with
the attribute that needs to be tested, or if it only contains an abnormally small portion of items
with the attribute, or because there is an intentional or unintentional preference in the items
selected to be included in the sample frame. If a sample frame is incorrectly selected, or an
inadequate sample size is used, the entire sample can be flawed and may not be representative of
the population. Even if the sample frame is selected from a relevant population, and the sample
size is adequate, there is still a possible source of sample bias. The potential source of sample
bias is the introduction of any systemic preference when selecting (picking or drawing) the
sample items. All of these sampling variables impact the reliability of the sample when it is used
for inferences about the population.
Whenever a sample frame is selected that is either not as complete as is assumed to be
(e.g. accounts payable vouchers that only include those that were paid by checks, but which
should also have included those that were paid by cash or wire transfers); or is not composed of
the type of items required to test a control attribute (e.g. vouchers as opposed to disbursements),
then the sample frame can introduce an unknown bias, and can be considered inadequate for
projections or inferences related to the controls original intended target population. Also, when
the items available to be selected within a sample frame consist of items with a systemic
departure from the randomness anticipated, or when the method of selecting the samples is
favoring some items over other items in the population, there is a high probability of sample bias.
However, the major risk in biased sampling is that the bias is an unknown bias. Intentional
stratification, however, is a known and purposeful method of sampling bias designed to reduce
sampling risk in a population with a high dispersion (variation of item values), it is not a form of
unknown sampling risk. However, it does redefine the sample frame (population) to a stratum.
Having an unknown or unintended systematic preference when selecting items in the
sample is sample bias, and this is a major risk inherent in the use of sampling. Sample bias can
produce samples, and subsequent testing results, that are not representative of the actual or
intended target population. In addition, if a sample frame is biased by consisting only of a
stratum of population items, or, conversely consisting of a whole mix of different items when a
stratum is expected, this can be considered sample bias. It is a biased presentation of items to be
sampled because it is not what the tester is expecting, (i.e.) it is not the target population or target
sample frame. A sample drawn in a biased manner may represent only the samples features, and
not the intended populations features. Since the sample does not represent the target population,
projections to the population can be incorrect, or, in some way flawed to the extent the sample is
not a mini model of the population. Because sampling bias may be unknown or not quantified,
any inference or projection to the population based on the biased sample may lead to an incorrect
conclusion, as well as to corresponding incorrect management decisions related to the testing
results.

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Occurrences of intentional or unintentional sample bias may create easily communicated
misinformation with high intuitive credibility, resulting in incorrect conclusions and potentially
incorrect management decisions. In some cases, sampling may appear correct intuitively, but not
be representative in the actual environment because of an unknown sample bias created by an
incorrect selection methodology, see section III B, below.
The risk of sampling bias effecting auditing results began as sampling became necessary
as corporations became larger, global, and more complex. An increase in financial transaction
volume, complexity, incompatible processing operations, and asset size of corporations occurred
because of company growth driven by product demand and/or by growth by acquisition (mergers
and acquisitions). Combined companies create their own set of unique sampling problems when
dissimilar workflows or business processes are operating at different levels of control
effectiveness, but are producing a common output product.). In addition to internal growth fueled
by product demand, corporations experienced sudden growth through acquisitions, mergers, or
other combinations. This combination of internal organic growth and the sudden need to
combine different transaction processing systems (absorbed with the acquired businesses)
created both an increase in transactions to be audited and an increase in the workflow differences
related to processing the transactions. Combining workflows and systems disrupted existing
legacy processes and introduced an increased possibility that end transaction sample frames
may be more representative of one workflow than of another. Consequently, as the volume and
complexity of 100% transaction testing became unmanageable, the auditing profession had little
choice but to adopt sampling techniques. Along with the adoption of sampling techniques came
the insidious threat of sample bias, and the need to be on guard against the negative aspect of
bias impacting audit conclusions. In order to minimize the effects of sample bias it is necessary
to understand the origins of sample bias and then to develop a structured method of designing
sampling frames and sampling procedures to ensure that samples selected from a population
accurately represent the population, and contain the features or attributes intended to be tested.
This guideline focuses on sampling methodologies and techniques to be used by the
internal auditor or individuals performing management testing for compliance, and the impact of
sampling methodologies on the reliability and usability of statistical or nonstatistical samples to
support conclusions used in auditing and management testing. This work explores examples of
sampling techniques ranging from intuitive nonstatistical checking of a few items to the design
of a valid statistical sampling plan. Intuitive, subjective, or judgmental selections of samples
(nonstatistical sampling) may be used to gather information, or to support and provide
documentation for an auditors conclusion. The auditors conclusion, when using non-statistical
sampled information as supporting documentation, is generally also based on other analytic
information obtained during the audit. While nonstatistical sampling is an acceptable
documentation methodology, a valid statistical sample can reduce sampling risk by using
probability mathematics to quantify the risk, and to infer characteristics from a sample to the
population.

B. How Sample Bias Arises

1. Bias from Sampling Procedures

Sample bias in classical variable sampling, or attribute sampling can rise from a
judgmental preference in how samples are selected or from the sample frame, or from a lack 0f
consideration of the variability of items in the population. Bias introduced by using an ineffective
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sample size can result from incorrect estimates of the occurrence rate of failures of items in the
population. Since randomness is widely known as a method of selecting samples, when an
inference is planned for a populations average value (mean), or when inference is used to
determine the proportion of an attribute feature in a population, the practitioner frequently
considers the most appropriate method to achieving randomness in the sample selection
procedures. However, there is not always as much effort spent evaluating the variability or
dispersion in the population items, or of evaluating the estimated occurrence rate for an attribute
feature. This is an oversight that can introduce a sample bias caused by an incorrect sample size
not being representative of the population, and, therefore, selecting a sample with too little or too
much of a population trait. The sample size may be incorrect because the population items
variability or proportions is one of the critical variables for sample size calculations. When the
variation or portions are not reasonably estimated, the sample size calculations may produce a
sample size that is too small to consider the actual dispersion or proportion in the population, and
is thereby biased and not representative. Thus, a bias caused by not including enough items to
represent the true population increases the sample risk. Although nonstatistical sampling risk
related to variability in the population can be reduced by approximating or estimating the key
variables and using appropriate statistical sampling tables, or by using formulas to ensure the
sample size is adequate, statistical sample size calculations still require a best estimate of the
standard deviation (sigma) or the expected occurrence rate (percentage) in the population. These
requirements for probability based sample size calculations may be addressed by estimating the
required variables based on an analysis of the population, or, preferably by taking a pilot sample
(possibly 10 to 15 items) to get a level of comfort regarding these variables. Creating this initial
starting point by having a supportable estimate of these parameters is a very important, but often
overlooked part of an effective sampling procedure. However, while a pilot sample is desirable
when sampling for population statistics such as a population mean and precision interval, or the
percentage(s) of attribute feature(s) in the population, it is less critical when there is a previous
years sample history.

However, acceptance-sampling sample sizes are smaller by design since they represent
the number of items to be selected without finding a specified number of deficiencies (c). This is
because acceptance sampling is based on the laws of probability (binomial, or hypergeometric)
and uses smaller sample sizes to determine the chance that a defect will be found in a given
sample. Attribute acceptance sampling plans are used in auditing when performing probabilistic
sampling for tests of controls to determine an estimated level of control risk.xi When acceptance
sampling sample sizes are being used, the results should not be projected as values or
proportions to the population without recalculating a sample size for confidence level and
interval based on the normal probability curve and standard deviation. This will facilitate an
accurate forecast with known statistical limits. Concurrent with the results of the sample size
calculations, an additional source of sampling bias, the what or sample frame to be sampled is
simultaneously designed. The sample frame is sometimes (incorrectly) assumed to be obvious.
The what that is to be sampled is referred to as the sample frame or population, and is the only
population that the sample will be representative of. It is the only population to which evaluation
results can be inferred or projected. Selecting an incorrect sample frame may be one of the less
noticed sample bias threats to effective use of sampling. Sample bias caused by an inadequate
definition of the sample frame usually results from not comparing the what that is being
sampled with the what of the control attribute being tested.

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A simple example illustrates this danger. Consider a set of internal controls in accounts
payable where an auditor is instructed to verify that a control activity requiring all checks over
$5000 to be approved by a second person is operating effectively. Conjecturing that the
recommended sample selected was a minimum of 25 checks out of weekly check runs averaging
1000 checks per week. These checks were selected by dividing the most recent 1000 check
numbers by 25 to obtain a sampling interval of 40. The sample selection process then selected
every 40th check until 25 had been selected. Once the sample was selected they were reviewed to
verify that both a primary and secondary approver had signed all checks over $5000. When
tested, the appropriate two authorizers signed all nine checks over $5000.
However, this test is not as credible as it could be because of its Achilles heel sample bias
caused by a poorly designed sample frame. The sampling technique was biased because what
were sampled (the sample frame) were all checks issued, rather than all issued checks over
$5000. Selecting a sample frame that included many checks that could not be tested for the
second signature biased this sample. The objective of the audit was to determine if a control
activity requiring checks that should have a second signer (checks > $5000.00) was effective.
This is an application of sampling for acceptance testing - not of sampling to determine the
percent of checks over $5000. The business workflows control activity, which is what we are
testing to determine its effectiveness, was applied only to the portion of the check population that
was over $5000.00; correspondingly the sample frame should consist only of these documents
(i.e.) checks over $5000.00. This is because the portion of defects subject to the binomial
distribution testing procedure is the percent of checks that should be signed that were not
(occurrences of failed control). The first sample frame included a population of checks that, by
definition, could not have the defect being tested for acceptance. An unbiased sample frame
could have contained only checks over $5000. This is preferred since the attribute success or
failure to be verified is the dual signatures on all checks over $5000. Thus, the sample frame to
test for dual signatures should be all checks over $5000.
The sample frame selected is the population boundary or set of items that is intended to
be available for selecting samples from. It is also the population about which projected
conclusions will be relevant to. However, in the case of Crazy Eddies Inc., company personnel
were manipulating the sample frame and counts. The sample frame being counted did not
always consist of valuable electronic products, in some cases empty boxes were included in the
counted items in order to increase the quantity of inventory items being valued for financial
reporting of inventories. Manipulation of what is actually in the sample frame is controllable by
company personnel and has been a frequent source of intentional sample bias by Fraud. Crazy
Eddies is reviewed in the next section.

2. "Crazy Eddies, Inc.", an example of fraud

This is an example of a financial fraud based on misstated inventory quantities. Auditing


the quantity of items counted is an important internal control for companies with inventories or
investment based financial assets. Confirming quantities of items that have been used as the basis
for financial reporting of asset values is one of the viable applications of sampling. As such,
sampling can be used as an effective and efficient technique to verify product inventory counts or
investment-certificate counts for financial valuation. An internal auditors verification of
quantities counted is an appropriate use of sampling techniques since quantity counts is an area
historically targeted for fraud and/or unintentional misstatement. Financial reporting based on
item counts is susceptible to misstatement because counting item quantities is labor intensive,
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boring, susceptible to human error, and historically a source of fraudulent reporting. Thus,
although this example focuses on a fraudulent manipulation of inventory quantity counts; it is
also an ideal example of the kinds of counting errors and misstatements that an internal auditor
may encounter in the field that could be detected through the use of sampling procedures to audit
inventory quantities. In this example, both the counted population and the count sheets of
recorded quantities were not representative of the true inventory population. The inventory
population sample frame consisted of empty boxes or previously counted merchandise moved
from other locations, which in many instances, was fraudulently being presented by management
as valuable merchandise. In addition, company personnel altered the quantities recorded on the
manual count sheets when they were left unattended. An effective internal audit sampling
procedure could have selected a target sample frame definition that included verifying that the
boxes sampled at a specific location contained actual merchandise, and then could have
performed sampled recounts to confirm that the original counts recorded were either correct or
were not.
Crazy Eddies, Inc. was an electronics consumer products distributor operating on the
east coast of the United States, which was managed by Eddie Antar (Eddie) and a tight group of
family members. Crazy Eddies financial reporting fraud was perpetrated, in many instances,
by inventory quantity misrepresentations. These misrepresentations were based on both the
quantity counts recorded and on What (the sample frame) was being counted. While sampling
techniques related to inventory count verifications by internal auditors is not specifically referred
to in the referenced legal or commercial documentation related to the trial, it is the type of fraud
or misrepresentation that points out the importance of defining accurately What is being
counted - whether in total or for a sample. This example also highlights the high importance of
audit sampling to confirm that quantities recorder on count sheets are accurate. Rather than
sampling and verifying what was being counted, it was assumed that the items were as
management represented (i.e.) expensive commercial electronics devices in their original boxes.
During its existence as a business Crazy Eddies management and other family
members engaged in multiple examples of financial fraud both as a private business, and, after
its initial public offering (IPO), as a publicly traded company. Sam E. Antar, the CFO of Crazy
Eddies, and now a convicted felon as a result of the fraudulent activities at the business,
produced the 10-k and 10-Qs required during the years Crazy Eddies operated as a public
company. During the time between 1984 and 1987 inventory counts were fabricated, or
modified, and empty boxes were counted posing as boxes that were filled with higher priced
merchandise. Because of this fraud committed in inventory counting as well as in revenue
manipulation, Eddie Antar managed to misstate SEC financial reports to his advantage. The
fraudulent inventory counting (and the apparent lack of effective sampling controls over
counting) allowed the fraud to remain undetected until new management took over the company
in 1987. After his involvement and conviction for SEC violations, Sam Antar has become an
advocate for reducing financial fraud and maintains a web site focusing on improving financial
reporting.xii
Some of the most effective and long running frauds involving financial misstatements are
simple and involve miscounting or misevaluating inventory. If sampling is used as an audit
technique for testing for this type of problem, the Achilles Heel of the sampling procedures
will frequently filter down to the sample frame since the sample frame is the population available
to be sampled. In a similar manner, sampling frames can be fraudulently defined to produce
sampling results that are not representative of the intended or target audit/test population. If the

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intent is to commit a fraud, the distortions in a sample frame may be willfully concealed. For
example, the inventory fraud started soon after Crazy Eddies IPO in September 1984, and
continued undetected until the full impact of the inventory fraud was realized in 1987. The full
amount of the inventory valuation shortfall was not known until after a new executive team
took over management of the company. The inflation of inventory counts began shortly after the
IPO and resulted in an initial two million dollar fraudulent increase in inventory valuation. This
impacted the 1985 fiscal year 10-k, as per the transcript from the trial at which the SEC was the
plaintiff, and indicated a material misstatement of profitability.

For the 1985 fiscal year, Crazy Eddie filed with the SEC an annual report on Form
10-K. In that filing, Crazy Eddie reported that it earned pretax income of $ 12.6
million. This figure, however, was fraudulently inflated by $ 2 million, or almost
twenty percent, as a result of the warehouse inventory inflations. When Eddie sold
the stock on behalf of the Relief Defendants, he was fully aware of the fraudulent
inventory inflation and its effect on Crazy Eddie's pretax income. xiii

This initial two million dollar overvaluation of inventory was achieved by misstating the
inventory counts. However, this initial misstatement was small compared to the cumulative inventory
misstatement discovered in 1987. In 1987, when the new management team valued the inventory,
they discovered a $ 60 million shortfall. This is also mentioned in the Court transcript as follows:

On November 6, 1987, Crazy Eddie's shareholders voted to remove the company's


existing management backed by Eddie. A new management installed by Zinn and
Palmieri took control of the company. n30 Soon thereafter, it discovered a $ 40
million inventory shortfall. This estimate was subsequently increased to $ 60
million. Zinn and Palmieri ultimately disclosed this inventory shortfall to the
public.xiv

This huge shortfall, which was due mainly to counting distortions, has resulted in the auditors
for Crazy Eddies being criticized for not doing their job. The areas of criticism focus on not auditing
all inventory locations simultaneously, and leaving audit count sheets available to be changed
overnight. One of the documented criticisms of the inventory audits is in an article by Joseph T
Wells indicating that there was numerous instances of inventory fraud involving counting that could
have been caught.

Rather than climb over boxes in the warehouse, the auditors asked employees
to assist them. Crooked employees volunteered. An employee would stand on
top of a stack of television sets, for example, and call down the count to the
auditors. If there were 10 sets, the worker would claim there were 25. Repeated
many times, this clever trick helped to greatly increase the inventory count.
The message here is obvious: If you're supposed to verify the inventory count,
then you must observe it. xv

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IV. Use of Sampling in Auditing

Unfortunately, sampling is rarely applied consistently in the auditing or compliance-


testing field. The underlying understanding of sampling principles and concepts often varies
from person to person. Different auditors may draw different conclusions from the same or
similar data. This is due to the fact that the level of understanding and experience in applying
sampling techniques varies greatly from one individual to another.
In addition, the acceptance of nonstatistical sampling as evidentiary documentation in
auditing has complicated the situation.

Comment: The knowledge that, in many instances, sampling did not have to
conform to a valid statistical sampling approach may have removed most of
the corral fences around the use of sampling. In response to the acceptance of
nonstatistical sampling as evidentiary material,xvi some auditors began to
wander from the underlying statistical and probability concepts to an approach
based predominantly on judgment and intuitive risk valuation.

The previous sections II and III focused on sample risk and the element of sample bias.
Bias is a pervasive problem that must be guarded against by the auditor when designing a sample
plan, especially when determining the sample frame and sample size, both of which contribute to
sample risk when unknown or unmanaged. The sample frame should be clearly defined for a
sampling plan, and the sample risk should be quantified and, although not required by the
standards, documented where appropriate.xvii Sampling risk, in many instances can be minimized
as well as quantified by applying probability theory in order to determine a statistically valid
sample size. This capability to quantify sampling risk is not available when relying on a
nonstatistical sample size.
The previous sections also focused on potential and/or actual negative impacts of sample
bias, sample size and sample count misrepresentations on financial reporting, as well as on a
specific example of the misuse of inventory counts to distort financial reporting. In these
examples, sampling methods and procedures could have been an effective internal audit
procedure to detect quantity misstatements or errors. In the next section, sampling methods and
procedures are examined as a method of preventing distortions in results based on sampling.

A. Sampling Methods and Procedures

The effectiveness of the application of sampling techniques can be improved by


instituting a structured and documented process for designing and applying sampling procedures.
The methods and procedures used can also be standardized and improved by appointing a
designated and specially trained auditor to establish and monitor the preferred methods to be
used. A matrix summarizing the primary steps and activities that could be used as a base for
developing an audit department procedure is provided below. This table of components for an
effective sampling process has been developed based on information extracted from Sampling:
A Guide for Internal Auditorsxviii, and modified by this author. This matrix relates to both
variables sampling and attribute sampling.

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Summary of sampling
plan elements Attribute Sampling Variables Sampling

Determine the objectives of Based on a prescribed control Based on a dollar amount in an


the audit. procedure. account balance or class of
transactions and expected risks.
Define the attribute and the Attribute is either present or not, a
deviation condition(s). binary condition. NA
Define the sample unit with Units or items containing amounts
the variable to be evaluated NA (e.g.) invoices with dollar amounts

Define the population (the A specific definition of the pool of all A specific definition of the pool of all
sample frame). items eligible for sampling. For items eligible for sampling. For
example "all customer invoices example "all invoices for customers
processed by the accounting with a bill-to location in the USA".
department located at Boston, MA,
USA".
Determine the sample Alternatives to be considered include Alternatives to be considered include
selection method. Statistical vs. Non-statistical, and Statistical vs. Non-statistical, and
random or judgmental selection. random or judgmental selection.

Determine the sample size. Based on the sample selection Based on the sample selection
method. method.
Perform Audit procedures on Based on audit standards and Based on audit standards and internal
the sample items. internal procedures procedures
Evaluate the sample results Based on audit standards and Based on audit standards and internal
and express a conclusion. internal procedures procedures

A key element of any sampling plan is to Determine the objectives of the sample. as
indicated in the upper left corner of the matrix. While important for variables testing, this is
especially important for internal auditors when performing Attribute Sampling for control
operating effectiveness:

A control objective provides a specific target against which to evaluate the


effectiveness of controls. A control objective for internal control over financial
reporting generally relates to a relevant assertion and states a criterion for
evaluating whether the company's control procedures in a specific area provide
reasonable assurance that a misstatement or omission in that relevant assertion
is prevented or detected by controls on a timely basis. xix

In order to prevent sampling risk from becoming the weak point in an audit and testing
process, it is essential to do a careful review and matching of the items being sampled to the
objective(s) of the control activity, and to the audit purpose. Comparing the attribute features
required to affect the controls risk-mitigating features to the documents can perform this.
A comparison of the audit objectives to the samples needed to test a control is necessary in order
to ensure that the control evidence being sampled does have the attribute feature required to

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reduce the risks as intended by the control. For example, if the objective of a control activity is
to ensure that revenue is not recognized until a product has been shipped and invoiced, and an
auditor is selecting a sample of pick-lists in manufacturing, something is probably wrong, and
the sample frame selection technique may need to be reviewed. While pick-lists are part of the
complete Order to Revenue workflow, it is usually not the point at which revenue recognition
is controlled. The auditor should probably be sampling shipping verification documents such as a
shippers waybill, packing list, or a customers acceptance of delivery. Other possible sources for
samples of control activities effectiveness could be an invoicing document file containing
evidence indicating that a required matching of invoices to shipping documents has occurred.
The preceding has presented a summary of how an organized approach to sampling can
help reduce sampling risk by organizing and using effective sampling procedures. The sample
procedures are the foundation of repeatable and reliable sampling results. The procedures can
facilitate the audit of controls required for compliance by developing uniform sample plans to
audit the controls for financial reporting. However, field effort is still needed to ensure that a
statistically valid sample represents not only the statistically valid confidence levels and
precision, but also that the sample plan is representative of the controls target population. The
next section develops statistical sampling further.

B. Statistical Sampling

1. General considerations

Statistical Sampling is a method of sampling where the number of items required for the
sample (the sample size) is determined by mathematics based on probabilities and characteristics
of the population such as variability and proportion. Both mathematical tablesxx and formulas are
available for use by an auditor to determine a statistically valid sample size. In addition to a
sample size based on probabilities, statistical sampling requires selecting the sample randomly
based on an equal probability that each item in the population might be selected. The
mathematics of probability distributions and algorithms take into consideration either the
variance in the population from the mean (standard deviation, sigma) or the percent of the
expected occurrence (success or failure) of the population attribute when determining a valid
statistical sample size. Using a sample that is statistically valid provides the auditor with the
ability to infer or project sample results directly to the population with a quantifiable sample risk
by establishing a confidence level and range of precision (precision interval). Both are available
as components of the calculation of sample size based on probabilities. The sample frame,
confidence level, and precision interval can be determined by the practitioner based on their
acceptability for the intended end use of the audit testing being performed. The auditor as part of
designing the statistical sampling plan establishes the acceptable precision and confidence levels
initially. A 90% confidence level or 95% confidence levels are common confidence levels for
tables and calculations. Since a statistical sample allows the auditor to define how tightly or
precise an inference from the sample to the population will be (precision interval), and since
these key parameters are determined by the auditor, the sampling assumptions, while not
mandatory, should be defined and documented when performing an audit test based on
sampling.xxi
Valid variable statistical sampling procedures should take into consideration a sampling
frame designed to represent the population, and the dispersion between the population mean and
the items value, also referred to as variability or dispersion of the items in the population. By
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measuring or estimating the variability of items in the population an auditor can determine a
value for the formula variable sigma; the auditor may then calculate a sample size that represents
the desired confidence level and precision using appropriate formulas. The precision interval
is the populations target-range for the estimate. Statistical sampling is used when a statistic of
the sample (e.g. the mean) in the case of variables sampling, or the proportion of successes or
failures in the case of attribute sampling is intended to be projected (inferred) to the population
from the sample. This is the branch of statistics referred to as Inferential Statistics and is based
on a statistically valid sample randomly selected from the population. The sample size is
determined by applying an appropriate formula (or tables). The calculated sample size takes into
consideration the variability of items in the population (standard deviation or ) for variables
sampling, or the expected percent of an attribute (portion) in the case of attribute sampling. The
precision or acceptable margin of error inherent in an estimate of a feature to the population is
frequently expressed as being related to the confidence level selection. The use of statistical
sampling in internal auditing is mentioned on page II-115, Section E: Engagement tools, Part II
of the IIA CIA learning systemxxii which states:

Statistical sampling methods produce a scientifically random sample with test


results that may be quantified in terms of a confidence level and precision. As
an example an auditor might describe the results of testing a random sample of
items this way: We are 95% confident that the error rate of the population is
6%, plus or minus 3%.

At this point in the discussion of statistical sampling, we have established some of the
underlying structure, which leads to the benefits of a statistical sample. This is the linking of
probabilities to a sample size, and to the projection from the sample to the population. It is this
mathematical transformation using a normal probability distribution that determines these
formulas for calculating sample size. The formulas derived from the application of advanced
mathematics allow an auditor to determine a sample size by using input variables including the
probability distribution factor (Z), and a confidence interval or precision of the error rate of the
population. The result of a calculated sample size is expressed as referred to in the above quote,
as We are 95% confident that the error rate of the population is 6%, plus or minus 3%. It is this
ability to quantitatively define the sample-based inference to the populations sample risk in terms
of the confidence level and confidence interval that quantifies the statistical credibility of the
projection from the sample to the population. The formulas for determining sample size and
precision include the affect of the normal probability distribution including a Z factor (standard
deviation factor for the probability distribution) in the calculation.
There are two related but different applications for determining a statistical sample size
that have been coved thus far in this guideline. These are determining a sample size for an
average value and its precision range, and a formula for determining the sample size for an
attribute-sampling plan to estimate the percent of an attribute feature and its range or standard
error percent. The latter is also referred to as population percents for a dummy variablexxiii.
Determining the sample size for an attribute sample depends on what the sample will be used to
conclude. Specifically, the sample size for evaluating a populations average and both the upper
and lower limits of the normal curve is frequently larger than a sample intended to determine the
probability that the percent of the feature in the population falls outside an upper or lower one
sided limit.xxiv Thus, there are three basic approaches of interest to determining sample sizes for

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statistical sampling that are effective for making inferences to a population, and these are as
follows:

1. Sample size for variable sampling to infer a mean value and the range of variance
from the mean (two sided test).
2. Sample size for attribute sampling to infer a percent for a success or failure of
an attribute and the range of variance or estimated error from the percentage (two
sided test).
3. Sample size to infer whether an attributes percent of success or failure is
probably greater than or less than a selected percent (one sided limit test).

There is also a special application of attribute sampling for testing of controls, which
should not be used for inferring to a population, will be addressed later in this manuscript in a
section on Tests of Controls. However, the first two methods of determining a sample size can
be used to infer two different features of a population. These features are (1) determining a
sample size to infer or project a dollar value or mean of a sample to the relevant population -
which is usually an account balance or an account misstatement; or (2) determining a sample size
to infer or project an attributes population proportion or percentage for success or failure
which can be a control attribute such as the dual sign off of checks over some specific dollar
amount. The latter is binomial in that it either exists or does not exist, (I.E. each trial has the
same specific probability of occurrence) thus, the use of the term success or failure of a control
attribute.

The formulas for determining a valid statistical sample size are the simplified result of
more complex calculations, which rely, among other advanced techniques, upon determining the
maximum error of the estimates. There is a structured mathematical methodology supporting
both the sample size and the inference precision when a valid statistical sample is used. This is
not so when a nonstatistical sample is used. Before moving on to a comparison of statistical and
nonstatistical sampling it is important to clarify that there are some other sampling techniques
that may be confused with valid statistical sampling. Statistical sampling is frequently confused
with Random sampling, or, in some cases with Haphazard sampling selection. Statistical
sampling requires a sample size that is calculated based on probabilities and has incorporated
population variability or proportions into its calculation. Thus, even when an auditor goes
through very rigorous procedures to ensure that sampling was done on a random basis, it is not
necessarily a valid statistical sample, see the below reference:

Any sampling procedure that does not measure the sampling risk is a
nonstatistical sampling procedure. Even though the auditor rigorously selects a
random sample, the sampling procedure is a nonstatistical procedure if the
auditor does not make a statistical evaluation of the sample results xxv

Thus, randomness alone does not produce a valid statistical sample that can be used for
projecting from the sample to the population. Random sampling is a method of drawing or
selecting the sample, but it is not a method of valid statistical sampling, nor is it a method of
quantifying the sample risk. Although it is true that valid statistical samples must be selected or
drawn randomly from the population to benefit from a normal probability distribution, not all

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samples that are drawn randomly are valid statistical samples. Additional variables are needed in
order to produce a random sample that may be used to statistically infer features of the sample to
the population. To be a valid statistical sample, the sample size is calculated using a Z factor
for probability confidence levels, and the variable, sigma as well as the expected error rate. The
size of a valid statistical sample can be determined using appropriate statistical tables, or by an
appropriate formula, and, it is this calculation of a sample size based on probabilities that is a
major factor separating a nonstatistical sample from a statistical sample. The difference in
classifying sampling for auditing as statistically valid as opposed to random, haphazard, or
judgmental is demonstrated by the following excerpt from the auditing section of the operating
manual from the department of the Treasury:

Random sampling is a method in which each member of the population


has an equal chance of being selected. This method ensures no bias is used in
the sample selection. However, a random sample, without additional
attributes, does not imply a statistical sample
Statistically valid sampling is a method that combines the use of a
random sample method with additional criteria including confidence level,
expected error rate, and precision. This method is used when the auditors want
to make a statement about the population from which the sample was selected.
Using this method, outcome measures may be projected to the population.xxvi

It is clear from the above excerpt that the Operations Manual recognizes statistically
valid sampling as the accepted method to use when the auditors want to make a statement
about the population from which the sample was selected xxvii
Simply stated, statistical sampling is a credible sampling method based on probability
mathematics for projecting features from a sample to the population with a quantifiably defined
sampling risk. When using a valid statistical sample, the statistical risks of making a projection
can be quantified and stated in a formal manner. This is not the case for a nonstatistical sample
method where projections from the sample to the population are based on an auditors judgment.
However, as mentioned earlier in this manuscript, nonstatistical sampling has its applications and
value, but they should not be confused with the inferential capability and value of statistical
sampling.

2. Specific Considerations for Auditing

This section focuses on the operational use of statistical sampling for auditing. Auditors
can use classical variable statistical sampling to estimate the dollar amount in an account or class
of accounts, or to estimate the difference in dollar amounts between the transaction book
amounts, and the transactions audited amounts for an account or class of accounts. This is an
application suitable for classical variables sampling, which can be used to project a population
mean or average, and which requires an estimate of variability in the population in order to
calculate a valid statistical sample size. Examples of this application of variables sampling are as
follows:

What is the average selling price for a product

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What is the average error amount in payable processing
What is the average invoice amount
What is the average check amount
What are average discounts taken by a major customer

In addition to variables sampling to determine an average value for a target population,


auditors can use attribute sampling to determine the percentage of a population that has a feature
they are interested in. Examples of this application of attribute statistical sampling are as follows:

What percent of invoices are over $5000.00


What percent of inventory items have a zero standard cost
What percent of purchase orders for fixed assets are signed
What percent of cash disbursements are over $50,000
What percent of checks over $5000.00 have duplicate signatures

If an auditor decides to use statistical sampling, the sample size should be calculated
using a formula or a statistical table designed for that purpose (or auditing software with the
capability). Variables sampling can be used whenever the objective of the audit is to verify that
an expected amount or other variable such as an average price, cost, or days-outstanding is in the
appropriate value range required by management or required for operation of an internal
control. It is also used to evaluate the significance or materiality of errors made when recording
financial transactions into a journal or general ledger. In this instance, the amounts recorded in a
general ledger account would be compared to sample transactions drawn from a sample frame
containing all the transactions making up the account balances. The average mean of the
misstatements can then be inferred to the account balance and a conclusion made regarding the
significance of the errors.
However, it is not always errors that constitute the risk for a misstatement. The risk may
be that a corporate pricing policy is not being followed. Valid statistical sampling can provide a
basis for testing the reasonableness of an account such as revenue or accounts receivable
balances that are based on pricing standards. While it cannot verify that all transactions adhered
to the policy, it can provide some confidence to an auditor that the account balances are
reasonable or unreasonable when compared to what would be expected if the pricing policies
were being followed.
3. Valid Statistical Sampling Examples

The application of statistical sampling concepts and techniques can be demonstrated


through a review of the concepts involved in sample size determination for both a classical
variable sample and an attribute sample. The discussion will focus on determining a sampling
size for two sided testing which includes determining a range in which the true mean or deviation
percent may reside, rather than a one sided (also referred to as one tailed) test. Two sided testing
generally requires larger sample sizes since the analytic application requires that the sample must
be sufficient to determine a specific value or percent as well as a range for the population
inference as opposed to determining if the value is greater than or less than a tail percent. The
confidence interval provides a precision or range that the true value or percent lies within. This is
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also referred to as a precision interval or standard error. The decision regarding the level of
confidence required should be made at the beginning of the sample plan design process.
Although the plan can always be redesigned using a higher or lower confidence level, the
confidence level for this example sample plan will be 95%.
The strength of the two-sided evaluation is that a projection of a value or percent can be
made to the population directly from the sample. However, the strength of a one sided test is to
provide a probability based estimate of the risk that a deviation rate exceeds a pre determined
tolerable or acceptable rate. One-sided testing is primarily interested in the probability that the
true mean or deviation percent may be greater than or less than an upper or lower limit. The
decision regarding the testing method and the confidence level that will be used should be made
before the sample plan is determined in order to ensure the techniques are appropriate for a
calculated statistical sample. This emphasis on deciding between two sided or one sided testing is
reinforced in Montgomerys Auditing, 12th Edition:

When designing an attributes test, the auditor should decide if it is necessary to


estimate the range within which the true deviation rate lies (i.e. whether upper
and lower deviation limits are relevant) or if it is sufficient to test whether the
true deviation rate either exceeds or falls below a certain tolerable level.xxviii

Thus, the objective of these examples is to demonstrate the relative sensitivity of the
variables used in calculating a sample size used to support an inference (projection) of average
values, or percentages of an attribute feature, with a two-sided precision interval. Although tables
and software are available to determine the appropriate sample size more quickly, and allow
more iterations or modeling of the variables to select your sample than Example 1, Example 1
allows insight into the variables used to calculate sample sizes. See Exhibit 1 for a calculation of
sample sizes at the 95% confidence level.

Sample Size; Example 1A

In the first calculation of a statistically valid variable sample size, based on a normal
distribution, the Z value of 1.96 is selected from column on the far right at Seq.# 4 and placed
in the input cell located at SEQ # 1; "Z" Std deviation factor. The next step is to input a value for
the precision interval, which in this case is selected as .1 or 10%. The final value that is input for
this formula is the value of sigma, which can be determined by a separate calculation based on a
pilot sample or determined judgmentally by the practitioner. This value is important to auditors
since a large sigma, such as is found in financial transactions, will increase the required sample
size substantially. To demonstrate this, a larger sigma based on a greater population unit
variation, will be used for the calculation of Example 1B. However, as can be seen from
Example 1A, the unadjusted sample size for the population of 3000 is 96 items (Seq. # 17), and
the adjusted sample size is 93 (Seq. # 25). These results are for a relatively small sigma of .5.

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Exhibit 1A

Seq. Sample size calculation - Formula


# Variables Sampling Calculations Z factors
CL Z

1 "Z" Std deviation factor 1.96 80% 1.28


2 "A" Precision interval ("L") 0.1 85% 1.44
3 "s" Std deviation (Sigma) 0.5 90% 1.65
4 95% 1.96
5 99% 2.58
6
7 Formula
8
9 n= (Z^2)(S^2)/A^2
10
11 Numerator 1.0
12
13 Denominator 0.01
14
15
n = Unadjusted Sample
16 size 96
17
18 "N" Population 3000
19
20 na = n/[1+(n/(N)]
21 Numerator 96
22
23 Denominator 1.032
24
25 "na" Adjusted Sample size 93

Sample Size; Example 1B

In the second calculation of a statistically valid variable sample size, based on a normal
distribution, the input values are the same as in Example 1A, However, the final value that is
input for this formula is the value of sigma, which has been increased from .5 to 1.5. This value
is important to auditors since this larger value of sigma, as may be found in financial
transactions, will increase the required sample size substantially. See Example 1B the unadjusted
sample size for the population of 3000 items is 864 (Seq.# 17), and the adjusted sample size is
671 (Seq.# 25). In this instance, the adjustment for population size also has a greater impact on
the adjusted sample size, since the sample size is a larger portion of the total population.

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Exhibit 1B

Seq. Sample size calculation - Formula


# Variables Sampling Calculations Z factors
CL Z

1 "Z" Std deviation factor 1.96 80% 1.28


2 "A" Precision interval ("L") 0.1 85% 1.44
3 "s" Std deviation (Sigma) 1.5 90% 1.65
4 95% 1.96
5 99% 2.58
6
7 Formula
8
9 n= (Z^2)(S^2)/A^2
10
11 Numerator 8.6
12
13 Denominator 0.01
14
15
n = Unadjusted Sample
16 size 864
17
18 "N" Population 3000
19
20 na = n/[1+(n/(N)]
21 Numerator 864
22
23 Denominator 1.288
24
25 "na" Adjusted Sample size 671

Sample Size; Example 2A

In this first calculation of a statistically valid Attribute sample size, based on a normal
distribution, that could be used to evaluate and infer a percent or portion of a population that has
failed a control attribute, the Z value of 1.96 is selected from column on the far right at Seq. #
4 and placed in the input cell located at SEQ # 1; "Z" Std deviation factor. The next step is to
input a value for the precision interval, which in this case is selected as .1 or 10%. The final
value that is input for this formula is the value of P, the probability of occurrence (which is a
difference from the variable sigma used for variable sampling), and can be determined by a
separate calculation based on a pilot sample or determined judgmentally by the practitioner.
However, the value used in the sample example is 50% since this will result in the largest sample
size if the other parameters remain the same. The most sensitive and important value for
determining the sample size in this example is the desired Precision Interval which is the
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accuracy or range of precision that can be estimated. This value is important to auditors since too
large a Precision Interval can lead to uncertainty where high-risk financial controls exceed the
estimated or acceptable probability of occurrence for failures. To demonstrate this, a larger value
based on a smaller (tighter) precision interval, will be used for the calculation of Example 2B.
However, as can be seen from the first Example 2A, the unadjusted sample size for this
population of 3000 is 96 items (Seq.# 17), and the adjusted sample size is 93 (Seq.# 25).

Exhibit 2A
Seq. Formula
# Sample size calculation, for Attributes Calculation "Z" factors
Attribute Sample CL Z

1 "Z" Std deviation factor 1.96 80% 1.28


"p" Probability of occurrence
2 (f) 50% 85% 1.44
3 "A" Precision interval ("L") 0.1 90% 1.65
4 95% 1.96
5 99% 2.58
6
7
8
9 Formula
10
11 n=Z^2(p)(1-P)/A^2
12
13 Numerator 0.9604
14
15 Denominator 0.01
16

17 n = Unadjusted Sample size 96


18
19 "N" Population 3000
20
21 Numerator 96
22
23 Denominator 1.032013333
24
25 N = Adjusted Sample size 93

Sample Size; Example 2B

In this second calculation of a statistically valid Attribute sample size, based on a normal
distribution, the Z value of 1.96 is selected from the column on the far right at Seq.# 4 and

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placed in the input cell located at SEQ # 1; "Z" Std deviation factor. The next step is to input a
value for the precision interval, which in this case is selected as .05 or 5%. The final value that is
input for this formula is the value of P, the probability of occurrence (which is a difference
from the variable sigma used for variable sampling). The value used in this sample example is
50% since this will result in the largest sample size if the other parameters remain the same.
However, the most important value for determining the sample size in this example is the desired
Precision Interval which is the accuracy or range of precision that can be estimated. This value
is important to auditors since too large of a Precision Interval can lead to uncertainty where
high-risk financial controls exceed the estimated or acceptable probability of occurrence for
failures. To demonstrate this, the smaller value based on a (tighter) precision interval, is used for
the calculation of Example 2B. As can be seen from this Example 2B, the unadjusted sample
size for this population of 3000 is 384 items (Seq.# 17), and the adjusted sample size is 341
(Seq.# 25). This is a significant increase in sample sizes over Example 2A, and indicates the cost
of increasing the precision tightness achievable by the sample.

Exhibit 2B
Seq. Formula
# Sample size calculation, for Attributes Calculation "Z" factors
Attribute Sample CL Z

1 "Z" Std deviation factor 1.96 80% 1.28


2 "p" Probability of occurrence (f) 50% 85% 1.44
3 "A" Precision interval ("L") 0.05 90% 1.65
4 95% 1.96
5 99% 2.58
6
7
8
9 Formula
10
n=Z^2(p)(1-
11 P)/A^2
12
13 Numerator 0.9604
14
15 Denominator 0.0025
16

17 n = Unadjusted Sample size 384


18
19 "N" Population 3000
20
21 Numerator 384
22
23 Denominator 1.128053333
24
25 N = Adjusted Sample size 341
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Acceptance Sampling:
Binomial Distribution;

While manual or spreadsheet calculations can be complex if the auditor wishes to


calculate a complete attribute acceptance sampling plan with multiple values of C, which is the
critical number of defects allowed in the sample (given a specified probability that there are
fewer than XX % deficient controls in the population) it is possible to create an Example that
indicates the concept of the decreasing probability of selecting a sample size and getting zero
defects given assumptions about population size and the population defect quantity or percent.
Below is a sample calculation based on binomial distribution calculations that clearly shows the
decreasing probability of selecting items without getting a defective control. It is important to
realize that these calculations indicate the probabilities without replacement.

Sample
Size Defects 300 Prob. C=0 Reliability
Population 3000

5 Prob of 0 or less defects 0.588 0.412


10 Prob of 0 or less defects 0.343 0.657
15 Prob of 0 or less defects 0.198 0.802
20 Prob of 0 or less defects 0.113 0.887
25 Prob of 0 or less defects 0.064 0.936

30 Prob of 0 or less defects 0.036 0.964

35 Prob of 0 or less defects 0.020 0.980


40 Prob of 0 or less defects 0.011 0.989
45 Prob of 0 or less defects 0.006 0.994
50 Prob of 0 or less defects 0.003 0.997
55 Prob of 0 or less defects 0.002 0.998
60 Prob of 0 or less defects 0.001 0.999

65 Prob of 0 or less defects 0.000 1.000

C. Nonstatistical Sampling

1. General Considerations:

Previous analysis have focused on an internal auditors need to collect sufficient


information by sampling, and then make projections or inferences about account balances,
potential misstatements, or the percent of a control feature in the target population. These
projected values or proportions can be used to assure management that the expected values or
proportions are operating within intended policy guidelines and policies. Inferential statistics is
the field of study dedicated to understanding and performing the task of projecting (inferring)
sample characteristics (statistics) to the population that was sampled based on the mathematics of
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probabilities. Inferential statistics require statistically valid samples in order to quantify the
sample risk and support the inferences (projections). Nonstatistical sampling however, does not
have a quantified sample risk, and projections are justified based on the auditors judgment. An
exception can occur when a nonstatistical sample is statistically analyzed after being performed,
and its usefulness and sample risk, as a statistical sample for projecting values or features to a
population is determined.

Nonstatistical sampling, also referred to as judgmental sampling, involves a


determination of sample size based on the practitioners judgment. The judgmental determination
of a sample size is based on parameters considered relevant by the individual performing the
sampling. In general, there are no specific rules limiting nonstatistical sampling, however, there
are guidelines provided by auditing standards that are designed to consider elements of sampling
risk as part of the process for determining the sample size. However, the bottom line is that
regardless of what guidelines are followed, it is still non-statistical in that it is not based on, or
bound by, the rules or axioms of probability mathematics. Nor is it a substitute for inferential
statistical techniques, which requires a valid statistical sample in order to provide a measure of
the sampling risk associated with a projection or inference.

2. Specific Considerations for auditing

Nonstatistical sampling is an option available to the auditor in which the sample size, in
addition to other sampling considerations, is determined based on the auditors judgment. The
audit standards are clear that AU Section 350, Audit Sampling, applies to both statistical
sampling and nonstatistical sampling:

There are two general approaches to audit sampling: nonstatistical and


statistical. Both approaches require that the auditor use professional judgment
in planning, performing, and evaluating a sample and in relating the audit
evidence produced by the sample to other audit evidence when forming a
conclusion about the related account balance or class of transactions. The
guidance in this section applies equally to nonstatistical and statistical
sampling. [Revised, March 2006, to reflect conforming changes necessary due
to the issuance of Statement on Auditing Standards No. 105.]xxix

If elements of designing a reliable sample are fulfilled, and a non-statistical sample size is
large enough to include sufficient population variations to be representative of the target
population, then non-statistical sampling could produce results that are similar to the results
obtained by statistical sampling. This is discussed in the auditing standard AU 350:

The sufficiency of audit evidence is related to the design and size of an audit
sample, among other factors. The size of a sample necessary to provide
sufficient audit evidence depends on both the objectives and the efficiency of
the sample. For a given objective, the efficiency of the sample relates to its
design; one sample is more efficient than another if it can achieve the same
objectives with a smaller sample size. In general, careful design can produce
more efficient samples. [Revised, March 2006, to reflect conforming changes
necessary due to the issuance of Statement on Auditing Standards No. 105.]xxx
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The Sample Frame for a non-statistical sample may be designed to be similar or even
identical to that used for a statistical sample. A sample frame defines the items in the population
that are available for sampling, and can be similar or the same for either nonstatistical sampling
(judgmental sampling), or statistical sampling. An effort to properly select the items in the
population in a random manner to minimize sample bias can be performed with the same
diligence for either a statistically valid sample or a nonstatistical sample. Either a nonstatistical
sample or a statistical sample may be used to provide sufficient audit evidence. See AU 350
Audit Sampling:

Either approach to audit sampling, when properly applied, can provide


sufficient audit evidence. [Revised, March 2006, to reflect conforming changes
necessary due to the issuance of Statement on Auditing Standards No. 105.]xxxi

The difference between the two sampling techniques is that the sample risk related to
inferring values or characteristics to the population when using a nonstatistical sample cannot be
quantitatively defined as it can be for a statistically valid sample. The AICPA recognizes both the
potential benefits of nonstatistical sampling and the risks involved when a target population has a
large variation or deviation of items in the population. See on Page 42 of the Audit Guide for
Audit Sampling:

The characteristics (such as the amounts) of individual items in a population


often vary significantly. The auditor subjectively considers this variation when
determining the appropriate sample size for a substantive test. The appropriate
sample size generally decreases as the variations become smaller.xxxii

However, considering the variation of items in a large population is difficult unless the
variation is measured and quantified. This variation in value(s) of individual items in the
population or Standard deviation is frequently calculated and referred to as sigma () when
calculating a classical variable statistical sample. Knowing and understanding the implications of
this value is valuable if an auditor is to infer an account balance from a sample, or is to infer an
error in an account balance based on a sample. Since the nonstatistical sampling method is not a
probabilistically application of sampling, the technique of inferring account amounts (balances or
misstatements) has an element of subjectivity that can be relevant and can contribute to audit
risk. In fact, it is not possible to statistically infer or project an account balance with confidence
using a nonstatistical sample without recognizing these uncertainties related to having an
undefined sampling risk, and a high dependence on subjective judgment.
Using a stratification technique to strengthen the application of a nonstatistical sample is
highlighted in the following paragraph from the AICPA Audit Guide - Audit Sampling, page 42

By separating a population into relatively homogeneous groups, the auditor can


minimize the effect of variation of amounts for items in the population and
thereby reduce the sample size. Common basis for stratification of
substantitive tests are, for example, the recorded amounts of the items, the
nature of controls related to processing the items, and special considerations
associated with certain items (for example portions of the population that

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might be more likely to contain misstatements). The auditor selects separate
samples from each group and combines the results for all groups in reaching an
overall conclusion about the population.xxxiii

The effort to separate a population by stratum for sampling improves the data from which
a projection is being developed for the population, and is effective for both statistical sampling
and nonstatistical sampling. However, it still does not ensure a statistically valid sample, and
does not have a quantifiable confidence level or precision interval. This reality is noted in the
AICPA Audit Guide to Audit Sampling, PAR 2.18.

Any sampling procedure that does not measure the sampling risk is a
nonstatistical sampling procedure. Even though the auditor rigorously selects a
random sample, the sampling procedure is a non-statistical application if the
auditor does not make a statistical evaluation of the audit results.xxxiv

Thus, regardless of other methods used to determine sample size, a sample size is still not
based on probability theory unless a statistical analysis is performed on the sample plan. A
nonstatistical sample size is still determined based on subjectivity or Judgment.

A focus on attribute sampling is intended to assist internal auditors to improve the testing
of internal financial controls and workflow processes controls related (primarily) to transaction
processing, and to controls where the number of times a control is applied is too high to allow
100% testing of the control attributes. While the need for the application of control attribute
sampling is clear in high volume transaction applications such as disbursements, it may also
apply to areas such as capitalizing Fixed Asset acquisitions, and the movement and valuation of
Inventories as well as controls related to the iterative process of developing standard costs for
inventory valuations. The dividing line between 100% testing and sampling is a practical
consideration (cost vs. benefit) determined by the frequency at which the control is being applied
to the transactions, the availability of documentation needed for testing, and the amount of time
required to test each item. If a control is being applied weekly (a frequency of 52) and the
required documents for testing are in one folder and it takes a minute to test each document, then
100% of the items could be tested. If, however, the required documents are co-mingled in
separate files with other unrelated documents and require sequential sorting and the folders are
filed at different locations, then selecting a nonstatistical sample and applying professional
judgment to determine the testing results may be a viable option. How many to select for a
nonstatistical sample is based on the auditors experience and judgment.

The use of control attribute testing to determine whether or not specific process controls
are being performed effectively has a wide range of application, but it can be confused and used
in place of variable testing, especially when an attempt is made to apply the results of a sample
plan designed for acceptance testing to infer a dollar balance or to extrapolate a dollar
discrepancy that was found during acceptance testing. This may result in a serious testing error,
especially if the sample size was nonstatistical, and determined based on a Lot Acceptance
Sampling approach, but is assumed by the auditor to be usable as a Variables Sample for
determining dollar values or, more frequently, percents of defects in population controls or
inventory counts. Nonstatistical sampling is prone to this error in usage because the confidence

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level calculations inherent in statistical sample size calculations are not available as
guidelines. Normally, in statistical sampling the use of a Margin of Error, or a Standard
Deviation vs. a percent of occurrence would separate the two sample selection size calculations
and provide a guideline as to their appropriate end use.
Attribute sampling, when applied properly, is a very powerful application of statistical
sampling in internal auditing. The use of attribute sampling for operational effectiveness testing
of financial processing controls is well accepted and extremely valuable to the accurate testing
and auditing of Internal Controls of Financial Reporting (ICFR). A reference to this application
of attribute sampling is available in the AICPA Audit Guide to Audit Sampling on Page 12 in
the section Types of Statistical Sampling Plans which states:

2.28 Some examples of tests of controls in which attributes sampling is


typically used include tests of the following:
Voucher Processing
Billing Systems
Payroll and related personnel-policy systems

Although this reference from the AICPA Audit Guide to Sampling is in the section for
Types of Statistical Sampling Plans, attribute sampling can be performed with both statistical
sampling and nonstatistical sampling plans. The same chapter in the AICPA Audit Guide covers
nonstatistical sampling some what in a previous paragraph in the section Nonstatistical
Sampling and Statistical Sampling with the following statement;

2.19 A properly designed nonstatistical sampling application can provide


results that are as effective as those from a properly designed statistical
sampling application. However, there is one difference: Statistical sampling
explicitly measures the sampling risk associated with the sampling
procedure.xxxv

The application of statistical sampling to control attribute measurement and acceptance


could become a dominant and pervasive control feature for the Internal Control of Financial
Reporting (ICFR) if attribute sampling is widely accepted. Without measuring and knowing the
sampling risk associated with the sampling procedure, the results of testing a sample are almost
always subjective in nature rather than being based on a statistical and probabilistic structure. An
additional consideration is that nonstatistical samples are frequently not random as is required for
statistical inference. By their nature they are biased in that some units are more likely to be
selected because of human nature and preferences than are other units in the total population. In
financial transaction processing where there is a wide variance of dollar amount per transaction,
a non-statistical sample may not consider a wide enough distribution of items when samples are
selected, thus eliminating the ability to probabilistically infer a sample characteristic to the
population. This limitation exists regardless of the sophistication of the methods used in selecting
the sample.
Even though some of the available guidelines for nonstatistical sampling recommend a
thorough and comprehensive analysis of the population, and qualitative risk factors, there is no
way to assess whether or not such analysis was done, or how the analysis was performed unless
it is documented. The thoroughness and quality of an analysis of the population may itself
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depend on a sample to determine whether or not the results of the sample testing should be
useable to any extent other than to support an auditors judgment regarding the sample itself. The
only way to qualify a sample is to evaluate its randomness and appropriateness to be
representative of the population being tested while considering the end use of the results of the
sample. If an auditor is untrained or not supervised properly in sampling techniques, the selection
of a sample may be the equivalent of Got a hunch, pick a bunch. Also, management may
request a dollar amount be place on an ineffective control or financial reporting process in
order to rank needed remediation in some dollar priority order. The team doing the audit
complying with this requirement by using the same sampled items (which were nonstatistical,
non random, and intended to be used for attribute testing of controls) by pulling the dollar
amounts off the existing sampled documents, and then using a ratio methodology to extrapolate a
dollar amount of risk to the ineffective control should first perform a statistical validation of the
sample and the results before responding.
Doing a second sample that is a statistically valid variable sample focused on the high
dollar strata transactions that could be misstated would be the first step, and then extrapolate the
average misstatement (sample mean) to the population. This method of projection of dollar risk
may at least be qualified by a sampling risk as defined by the confidence level, precision and
some measures of variation from a mean ().

Comment: In practice, I believe that this extra effort is imperative if the


inference is to have any credibility, and to prevent the audit client from
investing substantial sums of money to fix something that may be deficient but
still immaterial for financial reporting.

D. Testing of Controls, Non Inferential sampling

1. Intended End Use of a Sample (inferential vs. non inferential)

When the intended use of the sample is to project significant and relevant characteristics
of the sample to the population the sample should be an inferential type sample. An inferential
sample is a valid statistical sample, and should be required in all instances where the sample size
is not cost prohibitive. In order to determine the percent or proportion of defective controls in a
process, attribute sampling can be used to infer the percent of deficient controls by calculating a
statistically valid sample size either by using tables, the appropriate formulas, or statistical
auditing software. If the intended use of the sample is to determine what percent of checks over a
set dollar amount have effective duplicate signatures (the control), assuming a deviation rate
greater than 30% will usually result in a sufficient sample size for evaluation based on a normal
distribution. However, if a maximum sample size is desired, it can be calculated by assuming a
50% deviation rate in the population. This is the maximum sample size because it is the
maximum deviation rate for a binomial distribution. However, if one only wants to know -
what are the chances that the control is only defective 10% of the time or less then an
acceptance sampling methodology and corresponding sample size can be used. Thus, the
intended end use of the sample, which can be either to determine a confident estimate of a
controls specific percent defective, or merely to determine the chances that the deviant controls
are probably in an acceptable range, can be the major factor in the final decision of what

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sampling method to use. However, as with many other decisions, the cost vs. benefit
considerations also weigh-in on the final decision.

Certainly if 100% of an item is accessible with very little incremental effort over
drawing a sample, this is preferred to either sampling method. However, when an internal auditor
is auditing a transaction-based population with items in the hundreds, thousands, or even
hundreds of thousands of items, 100% manual testing becomes impractical (if not impossible),
and a portion of the population must be selected using sampling. This is where the intended end
use of the sample can become a major factor in deciding between statistical sampling and
nonstatistical sampling, and between one sided and two sided testing, and between classical
sampling or acceptance sampling. If the intended use of the samples test result is to support a
conclusion where projected sampling results will be the primary audit evidence, then valid
statistical sampling is preferred in order to provide confidence levels and statistical inferential
credibility to the conclusions. On the other hand, if the intended end use of the samples test
results is to be just one minor consideration among many other stronger arguments, then a
nonstatistical or acceptance sample could be adequate.

As can be seen in the previous paragraph an underlying reason for selecting between
statistical or nonstatistical sampling there is whether the auditor intends to use sampling for an
inferential application, or to use sampling to determine the level of risk or probabilities involved
in accepting or rejecting an internal controls assertion of effectiveness. The latter is a typical end
use of internal audit sampling that is used specifically to evaluate the risk inherent in accepting
internal controls as being effective. Evaluating risks that controls may not be effective, or,
alternatively, of not accepting (rejecting) internal controls that are effective is an objective of
testing of controls.xxxvi This special application of attribute sampling (actually it can also used for
variable sampling, but that is of no concern here) is referred to in authoritative audit guidance as
Sampling in tests of Controls. xxxvii Chapter three in the AICPA Audit Guide on Audit Sampling
discusses this application further.

In other industries similar sampling methodologies are generally referred to as Lot


Acceptance Sampling, and are used in quality control to sentence lots as either accepted or
rejected manufactured products. Sampling in tests of controls (where probabilities of deviations
are less than 20%) is usually based on hypergeometric or binomial probability distributions, as
opposed to the normal distribution that we previously discussed. In the previous examples,
formulas and calculations for samples size and statistics were based on the normal distributions,
and were either two-sided tests, or. If they were one-tailed tests, they would have used a t test
for significance. However, an acceptance or rejection of risk based on probabilities using the
special application of attribute sample plans can be efficient with smaller sample sizes than are
required for the two sided testing method, and is referenced in Montgomerys Auditing, 12th
Edition in the section on Statistical Tests of Controls.xxxviii Sampling for tests of controls is
especially valuable early in an audit since it can be a major factor in determining the level of
substantive testing that may be necessary, and in what areas the testing should be most intense.
An efficient audit would require substantive testing only as necessary for the audit to be effective
in determining the auditees reliability and fairness of financial reporting. However, while
efficiency is desirable, a primary consideration is that the auditors conclusions from sampling
are not biased in such a way as to result in the acceptance of ineffective controls as being

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effective. The importance of testing for internal controls effectiveness, and the risk related to the
auditor of accepting controls as being effective when they are not, is discussed in the AICPA
Audit Guide on Audit Sampling as indicated below.

The risk of assessing control risk too high relates to the efficiency of the audit.
The auditors assessed level of control risk based on a sample may lead him or
her to increase the scope of substantive tests unnecessarily to compensate for
the higher level of perceived risk. Although the audit may be less efficient in
this example, it is nevertheless effective. However, the second aspect of
sampling risk in performing tests of controls the risk of assessing control risk
too low relates to the effectiveness of the audit. If the auditor assesses control
risk too low, he or she inappropriately reduces the evidence obtained from
substantive tests. Therefore, the discussion of sampling risk in the following
paragraphs relates primarily to the risk of assessing control risk too low.xxxix

Because this testing for the effectiveness of internal controls is a significant factor in
determining the course and development of the subsequent substantive testing, the design of a
sample plan must be as reliable as is practical. The testing for the effectiveness of internal
controls is the foundation for determining the remaining levels and types of testing. However, it
should be clear that the testing of internal controls is not necessarily the major component for an
auditor to form their opinion regarding the quality of the financial reports themselves. The testing
of controls provides evidence related to the overall internal control environment, not the quality
of the financial reports. For this reason, valid statistical sample sizes and inferential techniques
are frequently not used. Rather, testing techniques based on acceptance sampling concepts are
preferred. This is discussed in the audit-sampling guide as follows:

Samples taken for tests of controls are intended to provide evidence about the
operating effectiveness of the controls. Because a test of controls is the primary
source of evidence about whether the controls are operating effectively, the
auditor generally wishes to obtain a high degree of assurance that the
conclusion from the sample would not differ from the conclusion that would be
reached if the test were applied to all transactions. Therefore, in these
circumstances the auditor should allow for a low level of risk for assessing the
control risk too low. Although consideration of risk is implicit in all audit
sampling applications, it is explicit in statistical sampling.xl

If the testing of internal controls indicates a high risk of control ineffectiveness, then a
greater amount of substantive testing may be necessary. However, since this method of
acceptance testing for internal control effectiveness is based on finding either more or less
deviations then the critical value c in the sample than has been calculated as acceptable based
on probabilities, it has the advantage of generally requiring smaller sample sizes than would be
needed for two sided testing inferential testing. It is important to understand that the acceptance
method of sampling and evaluation allows sentencing a lot as either good or bad, but does not
tell you anything about the process creating the items in the lot. The effectiveness of smaller
sample sizes allows an auditor to evaluate the risks of accepting an auditees internal controls as
being effective in a fast and efficient manner, however, the sample size and the cutoff number

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(critical value c), is determined by two simultaneous equations that are non linear, and it is not
intended to be used as a statistically valid sample size for inferring or projecting deficiency rates
or item values to the population. When determining the sample size (n) and the cutoff defective
quantity (c) two points are required. These two values are the tolerable percent defective in the
population, and the percent defective that will result in rejecting the assertion that the control is
effective. In industry applications these points are referred to as Alpha and Beta probability
levels.
The calculations for the sample plan values of n and c are usually performed by a
computer and are based on a binomial distribution, a hypergeometric distribution, or a Poisson
formula. In addition to being calculated using formulas and a computer, a Larson Diagram or
published tables is sometimes used. However, the important take away from this discussion is
that, in acceptance testing, an operating characteristics curve is calculated for the two risk points
(acceptance percents and rejection percents), which integrate the sample size (n) and the number
of allowed defects for the sample plan. Because of the mutual dependency of all elements of the
sampling plan, the sampling size (n) and the number of defects acceptable (c) are mathematically
bound together. For this reason, the sampling plan is referred to in some industries as a npc
sample plan. For example, if an auditor selects a sample plan from appropriate tablesxli of 93
items (n sample size) with a critical value of 1 (c = 1), and exceeds the critical value by
finding 20 deficient control attributes; it is certainly appropriate to conclude the internal controls
are probably ineffective, however, it is not appropriate to extrapolate the 20% deviation rate to
the population without testing the statistical validity of the sample size, confidence level, and
precision interval using formulas similar to the ones used in the attribute sample size example. A
sample, originally used for testing control effectiveness, can be used as a pilot sample to
determine a statistically valid attribute sample size using the previous formulas. One result of the
statistically valid sample size calculation is that a sample size over 200 items could be required
to infer a 20% deviation rate in the population, given the preferred confidence levels and
precision intervals indicated in Example 3 below.

Exhibit 3

Sample size calculation - Attribute: Z factors


CL Z

"Z" Std deviation factor 1.96 80% 1.28


"p" Probability of occurrence
(f) 0.2 85% 1.44
"A" Precision interval ("L") 0.05 90% 1.65
"s" Std deviation 0.400 95% 1.96
99% 2.58

Formula A1 Formula A2

n=Z^2(p)(1-
P)/A^2 n=16s^2/L2

Numerator 0.614656 Numerator 2.56


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Denominator 0.0025 Denominator 0.01

n=
Unadjusted
n = Unadjusted Sample size 246 Sample size 256

"N" Population 3000

Numerator 246

1.08195413
Denominator 3

N = Adjusted Sample size 227

Even less appropriate than projecting a control deficiency rate to the population, is to
take a value amount such as the mean or deviation of dollar amounts found in the acceptance
samples, and project that statistic to the account balance or class of transactions without
determining the effectiveness of the sample size. The acceptability of a sample for projections
can be determined by using formulas similar to the ones used in the variables sampling exercise
for confidence level and precision interval. A recalculated valid statistical sample size for
Classical Variables sampling could be calculated based on using the acceptance samples standard
deviation (sigma) as a pilot sample.

In order to perform a test for control effectiveness using this reduced sample size
sampling method, the following steps could be followed.

2. Sampling Steps for tests of Controls

When designing a sample plan for tests of controls, the steps required are the same as
other methods of attribute sampling described in the table included at section IV, A; however, the
method of determining the sample size is the part of the sampling method that is different. The
sample size and critical value can be determined using a binomial nomograph, or special
applications of statistical software, however, appropriate combinations of sample sizes and
critical values can also be determined using tables provided by the AICPAxlii.

In order to use these tables, the auditor must determine the factors needed to pick the
correct sample plan. These factors include a judgmental estimate of the expected population
deviation rate, the tolerable population deviation rate, and the acceptable risk of assessing control
risk too low. Because these factors can be specific to the particular circumstances the factors are
determined by the auditor using their experience and judgment and may initially be expressed in
a relative and qualitative manner. The general effect of these factors is discussed in the AICPA
Audit Guidexliii. Once the magnitude of these factors has been determined, it is necessary to view
them quantitatively when using the tables.
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The auditor must first quantify the probability of assessing the Control Risk too low in
order to select an appropriate level table of sample sizes. The two most frequent tables used are
those published in the audit guide as tables A1, and A2.These are 95% risk Table A1), and 90%
risk (Table A2). Once the desired table has been selected, it is then necessary to quantify the
Expected population deviation rate and the Tolerable Rate in order to select sample plans from
the tables. An example of this process to select a sample plan is as follows.

Based on the audit environment, a 5% risk of Assessing Control Risk Too Low is
considered appropriate. This results in using the Table A.1.xliv
Based on previous audits, the Expected Population Deviation Rate is considered
to be low so a rate of 1% is selected as the row in the table.
The control being tested is the approval of purchase orders, so the tolerable rate
cannot be too high. A tolerable rate of 5% is selected as the column in the table.

The result of this process is to select a sample size of 93 items, and a critical value of (1) defect.
If subsequent testing of the items sampled results in finding 1 or fewer deviations, the auditor
can conclude that the desired risk of assessing control risk too low is not more than the tolerable
ratexlv. Additional interpretations of the results of sampling are also included in the Audit
Sampling Guidexlvi

E. Practical Limitations on Sampling

When comparing and deciding whether to use statistical sampling or nonstatistical


sampling for population means or attribute percents, the decision will be influenced by physical
and economic realities. The auditor must be able to access and select the required items within
the sample frame, given the time allowed, and the resources available. Thus, nonstatistical
sampling may be preferred when resources and documented evidence are scarce since smaller
sample sizes are easier to perform with these constraints. However, this concession to cost or
time limitations may restrict the auditor from inferring statistically valid conclusions about the
population. This is especially true when testing high volume transaction based systems such as
accounts payable processes, customer invoicing, and payroll processing. These accounting
processes may have small but significant control deficiencies that may require a large sample
size to measure. Stratifying the population into subgroups could reduce the size of the sample;
however each subgroup will still need an adequate sample size of its own.

Nonstatistical sampling may assist an auditor to determine that a portion of transactions


in a sample have a deficient characteristic, alternatively, they could find that there are not any
failure characteristics or deficiencies. In either case, the non statistical sampling methodology
does not support inferring that the population either has the same proportion or percent of the
failure characteristic, or that the population does not have any failure characteristics or
deficiencies. The nonstatistical sample based information does not support a probability based
direct projection since the sampling risks are not quantified. Any projection must be based on the
auditors judgment. This is not true if a statistically valid sampling plan is used.

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An internal auditor could have an intentional and documented basis for selecting a
nonstatistical sample over a statistical sample, in order to support their judgment. A preference
for using a nonstatistical sample when a statistical sample would result in minimal additional
costs, and provide better support for the audit conclusions, should require sufficient
documentation. This preference may be caused by the lack of understanding that the
nonstatistical sample may not fill their need to infer or project the results. Or non statistical
sampling may be selected based on knowing from prior experience that deviations are extremely
small or that the results will are highly predictable. However, as indicated previously, statistical
sample sizes are generally less risky although they are large when compared to nonstatistical
samples.

F. Statistical Inference and Sample Size

Even when an auditor uses a valid statistical sample, the relevance of a projection of the
sample results to the population must be understood and evaluated based on sound judgment. A
projection may be inadequate because of the selection of variables involved in determining the
sample plan. The internal auditor must review and determine the adequacy of the confidence
level assumption i.e. is 90 % or 95% really sufficient or is the population being audited sensitive
enough to require a 99% confidence level. The variables involved for calculating sample size are
different for variable sampling, attribute sampling, and the special form of attribute sampling
acceptance or npc sampling. Variable sampling plans are applied most frequently to confirm
account balances, or misstatement amounts in dollars, and are therefore most concerned with
values and variability in the population or sigma. Whereas, acceptance-sampling plans are
applied most frequently to determine whether a control attribute is operating effectively, and, are
therefore most concerned with the binomial distribution, or binary conditions such as whether
reconciliation exists or doesnt exist. Variable sampling plan formulas require the input of a value
for the variance or of the population (usually an estimate or result of a pilot sample) since the
inference will be in the form of a population mean and the variance around that mean. These
components of sample size determination must be evaluated knowledgably, and taken into
consideration when performing a projection from samples to populations

This analysis focus on attribute sampling plans since they are the essence of sampling
plans for determining either the proportion of successes or failures of controls in the
population. These are the most comprehensive sampling plans by internal auditors or process
managers to test a control attributes success or failure percent in a population. In attribute
sampling plans two of the critical input variables are the expected occurrence rate or probability
of occurrence, and the desired Precision, or acceptable range of probable inference. The
usability of attribute sampling plans and the resulting statistical inference is calculated by the
variables mentioned previously and a selection of the related Confidence Level or tolerable
deviation rate.

The reliability of a statistical inference from a sample is dependent on the selection of


confidence levels and population parameters. If an auditor selects a 90% confidence level with
an expected occurrence rate of 10% and a desired precision of 10 % the sample size will be quite
low because it is a loose set of specifications for the projection or inference. If the statistical
sample size for this set of variables (population of 500) is approximately 25, this is a small but
easily managed sample size for most audit situations. It is convenient to find this many items in
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most filing systems, and, it is a statistically valid calculated sample size. However, what the
projected results may be saying is not that valuable. The sampling results may not be useful
information even though it is a statistically valid Sampling plan because the quantity selected
may not be representative of the population. However, if we were to go to the other extreme and
design an attribute sampling plan based on detecting even a small percentage of attribute failures
in the population we could use a sample based on a 99% confidence level with an expected
occurrence rate of .1% and a desired precision of .1 %. With those sample plan specifications the
sample size calculation results in a much larger sample of 465 for a population of 500 items.
Again this sample size is a statistically valid sample, but it is almost as useless as the prior
example because, in this case, the sample size is impractical and saves almost no cost or time as
compared to testing a 100% selection of the population.

G. The Rise and fall of Statistical Sampling in Auditing

Many external auditing firms focused on Statistical (probabilistic) sampling for the
period of time up to and immediately after the issuance of SAS 39; however, that focus has
changed during the decade of the 1990s to a preference for the use of nonstatistical sampling to
base a judgmental projection of values or control deviation ratings. The use of sampling plans in
Internal Audit and Sarbanes-Oxley testing of internal controls that are not statistically valid for
inference, has become an acceptable methodology because of its simplicity, acceptability, and
cost effectiveness not because of its inferential statistical reliability. Sarbanes-Oxley
acceptance testing for the risk of control effectiveness has became a popular auditing procedure,
however, the results, in some instances, were projected to the population without verifying the
statistical validity of the sample size. The result can be similar to inferring from a non-statistical
sample. The basis for a projection to a population from a sample that is not statistically valid for
inferential statistics should be defined as such by the auditor. In some instances, the application
of non-statistical sampling is also referred to as Judgmental Sampling or Haphazard
Sampling.
The emergent use of nonstatistical sampling techniques has been criticized by one of the
authors of SAS No. 39xlvii, the auditing standard that supported nonstatistical samplings
acceptability as evidence in auditing.

Throughout the 1960s and 70s, the largest accounting firms devoted extensive
resources to the development and implementation of statistical sampling
procedures. The firms wrote new policies and guidance, developed time-
sharing and batch computer programs, and trained specialized staff. Monetary
unit sampling was developed and became a widespread audit tool. The AICPA
issued Statement on Auditing Procedure (SAP) 54 and published Statistical
Auditing, by Donald M. Roberts. Then, in 1980, the Auditing Standards Board
(ASB) issued SAS 39, Audit Sampling (AU 350). Members of the Statistical
Sampling Subcommittee that wrote SAS 39, which included this author,
expected that the imposition of risk, materiality, and selection requirements
would further establish statistical sampling as a principal audit testing
procedure. In fact, the opposite has occurred, largely because the ASB gave
nonstatistical sampling equal evidentiary weight.xlviii

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Thus, statistical sampling held a preferred position in auditing for a few decades, but then
appears to have gone out of favor. My conjecture on why this occurred is that the effective use of
valid statistical sampling can be demanding on an auditor as well as costly for the client.
However, these negative factors may not have discouraged the use of statistical sampling if a
credible argument could be put forward to justify its use. I believe that a credible argument can
be made to justify the cost of training internal auditors on the detail theory and application of
valid statistical sampling based on the conceptual view that a financial transaction processing
and control system is, in fact, a process that can be statistically controlled rather than a collection
of individual tasks. Effective cost reductions can be achieved by organizing the volume of
activities into predictable and controllable processes and using statistical sampling to ensure the
process is operating effectively. This would be an end objective in applying statistically valid
sampling plans to an internal audit, or as part of the design of internal financial controls and
procedures.

V. Effective Statistical Sampling

A. Probability Theory

Much of the credibility of inferential statistical projections and believability of


conclusions about attributes of a population is founded on sampling that is based on the
application of probability theory. Consequently, the more thoroughly an internal auditor
understands probability concepts, history, and principles, the better equipped they are in
determining when to use statistical sampling as opposed to nonstatistical sampling. Also, even in
those instances where the auditor is not the person determining the sampling methodology, the
auditor will be better prepared to summarize the audit conclusion and explain the test results. The
credibility of probability theory and probability axioms has a long and rich history supporting the
current body of theoretical and applied principles.xlix Although the first recorded publication of a
correct method of calculating probabilities for gaming was in the 16th century, the undocumented
application of probabilities in the form of gaming probably took place in ancient Greece and
Rome. Over time, many of the observations and experiments related to probability theories were
formalized. The end result of this process of analysis and mathematical proofs has been a
formalized and specialized set of axioms that constitute 20th century probability theory. As a
result of this extensive vetting, the leverage of increased credibility is added to an internal
auditors evaluation by applying statistically valid sample sizes is well worth the cost, especially
in those instances where the effectiveness of a critical internal process or control activity is being
tested in a highly visible environment.

Even at a very basic level, the selection of a population to be tested, or the effectiveness
of selecting a sample at all (versus inquiry or observation) can be improved by applying
quantitative probability concepts. However, regardless of where the term is used, the usage of the
term probability has a wide range of interpretations. One of the interpretations of probabilities
include measuring the percent of an attribute based on the frequency of occurrence (see page 2,l)
to a completely subjective evaluation of entity controls based purely on an educated opinion.
The percentage probabilities based on a frequency of occurrence are the quantitative assessments
of specific control attributes such as date, amount, signature, and existence of a filed document,
whereas a subjective attribute may be sufficient support, or adequate review. Even
determining what the population to be sampled should be, can be a point of disagreement or
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uncertainty. However selecting a population and a sample frame can be thought out in a clearer
manner by applying the logic of sets (see page 5 footnotes 19). An example of an application
of logical sets would be in the area of AP transaction sampling. There is a large universe of
different types of AP transactions, but if the specific attribute to be tested is whether a receiver
for a document is properly verified prior to vouching a vendor invoice, the auditor actually
wants to select only that set of transactions that require a receiver to be created. This is
frequently manufacturing materials, capitalized purchases, and manufacturing MRO items. This
is a subset of the total AP transaction universe, and would constitute the appropriate population
for the sample frame. This is not a small or unimportant problem. Quality assurance evaluations
on previously tested controls specified verifying the receiver was matched to the PO, and yet the
population for selecting the sample frame was defined simply as AP vouchers; however
vouchers also included approved documents that did not require or have receivers.
Thus, the take away recommendation on the issue of probability theory for sample
selection is that an internal auditor, who has a solid understanding of probabilities and how they
impact sample sizes and sampling in general, is much more likely to be an effective
communicator of the credibility of sampled test results even under client pressure. I dont think
management - without a statistically valid sample would have believed a negative conclusion by
the auditors at Crazy Eddies.

B. Sampling Method vs. Sample Selection Methods

Analysis up to this point has focused on dividing sampling methodologies into major
classifications or methods. All sampling methods can be categorized into one of two categories.
These categories are: 1.) Statistically valid sampling; or 2.) Nonstatistical sampling. In a
statistically valid method of sampling the sample size is based on calculations or algorithms
relying on probability theory and rigorous mathematical proofs which provide quantitative
values for measures of confidence level, variability, occurrence rates, and precision for the range
of inferred values. Nonstatistical sampling does not provide these mathematical links to
probability distributions. However, while previous discussions were intended to reduce
confusion regarding the usage of statistical and nonstatistical sampling, there is also another
aspect of sampling where there may be significant confusion in both auditors and clients. This
confusion occurs when they are determining or discussing a sample selection method. The
sample selection method relates to how the samples are physically acquired or drawn from the
population rather than to the category of either statistical or non-statistical sampling plan
determination.

The sample selection method is mandated when using statistical sampling to a method
that provides an equal probability to each population item of being selected (i.e.) a simple
random sample. Generally, the most effective technique for achieving this randomness is to use
random number sample selection, or interval sampling beginning with a random starting point.
In addition to these two methods, cluster sampling may be accepted in some instances where
there is a multi stage sample selection procedure being used. A multistage selection usually first
selects clusters (or locations) at random, and then samples 100% of all items within the selected
cluster(s), or alternatively, calculates a statistically valid sample size within the random cluster.
Test results are determined for the selected clusters, which are then inferred to all other clusters.
However, the use of cluster sampling for statistically valid sampling programs may not be
acceptable to some testing programs unless there is sufficient reason to believe that all clusters
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have an identical distribution of attributes. In the treatment of cluster sampling, the IRS Treasury
Departments internal audit program does not accept applying the results of one branch to all
branches, in the respect that the results from statistically valid samples selected at one field office
are not acceptable as the basis of conclusions at other field offices.

1. Techniques for selecting samples

Statistical sampling requires a truly random sample selection method nonstatistical


sampling does not. In order to achieve an acceptable random sample it is necessary to use a truly
random method of selecting the sample not a potentially human biased method such as
haphazard selection by a person. Selecting a truly random sample is frequently done using
software to generate random numbers within the sample frames range of reference numbers.
However, using a structured method to select a truly random sample does not, by itself, create a
statistically valid sample. While a truly random sample selection method is required for a valid
statistical sample, it is only one factor in creating a statistically valid sample. A statistically valid
sample requires the calculation of a sample size based on a suitable confidence level and
precision range and the consideration of either the proportion or variability in the population
being sampled.

Nonstatistical sampling, however, has any number of available sample selection methods
that can be applied based on the circumstances or the professional judgment of an auditor.
However, the conclusions related to the sample can only be applied to the sample. Any projection
to the population is actually based on a subjective evaluation by the auditor. In fact, as mentioned
above, a structured random sample selection method may actually be used to select the samples,
even though the end result is still a nonstatistical sample size selection methodology. Other
popular sample selection methods, their appropriate use, and brief definitions are as follows:
a. Haphazard:

This is a method that approximates the effect of random sampling by selecting samples
without any intended bias and with no discernable pattern. Examples of this method
include selecting document files from a filing cabinet in an unbiased or haphazard
manner, or selecting purchase orders from a listing of all purchase orders with no
apparent bias or preference. When using this sample selection method, the auditors intent
is to select items that are chosen without intentional bias. However, even when an auditor
applies a haphazard sample selection method based on Excel to generate selection
numbers, or a random number generator pick the items for selection, they are using a
random sample selection method, but may be applying it to a nonstatistical sampling plan
as discussed in the previous paragraph.

b. Interval:

This is a method that can be accepted as a random sample if the beginning point
for the interval is chosen at random and there are no periodic or cyclic recurrences
expected in the population. However, this method may be biased if a listing that is used
for the representative sample frame has a built in cyclic variation or recurrence. An
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example of this problem occurs when the auditor is testing checks over a specific dollar
amount, and the only listing available is a check register that includes all checks over the
specified dollar amount in which the first 5 checks for each weekly check run are for the
same items over the dollar amount such as rent, insurance, employee benefits or other
cyclic payment. As a result of this periodicity, those checks, which are run every check
run, have a higher probability of being selected thus; there is a bias in the selection. When
using this sample selection method, the practitioners intent is to select items that are
chosen without a known bias, as a result, it can be applied to statistical sampling, but it is
also frequently used for nonstatistical sampling. In any case, it is best used if the auditors
judgment is that periodicity is an acceptable bias, or is non-existent. Finally, even though
the auditor may be comfortable applying it to a nonstatistical sampling plan, it may not be
appropriate for all statistically valid sample plans because of the possible bias caused by a
periodic or cyclic re-occurrence.

c. Judgmental:

This is a method of selecting samples (or actually multiple methods of selecting


samples) that is based on a deliberate sample bias being either created or accepted by the
auditor. The previous comments regarding interval sampling could be interpreted as
creating a judgmental sample based on the fact that the auditor accepted a known cyclical
bias based on their judgment. However, usually the bias is more specific and intentional.
An example of a judgmental sample selection may be one based on sampling only
purchase orders from a specific buyer, over a specified dollar amount, or from a specific
vendor. Even a haphazard sample selection could fall under the umbrella of a judgmental
sample if the samples are selected haphazardly from a one month period that was
determined judgmentally, or from a specific filing cabinet that is determined by the
auditors judgment (probably an unlocked, conveniently located cabinet).

d. Block:

This is a method of sample selection where a sequential group of items is selected


from a list, or a group of physically contiguous folders or documents are selected from a
file. I do not see anything unique about this method other than that it is quick and
convenient as long as there is a list or a filing repository. I have only used this method of
sample selection where I expected there to be no differences in the test results regardless
of where, on a list, I selected the samples. An example would be when testing a Pos-Pay
electronic approved check listing by agreeing the check number and amounts to the
corresponding check register. A block of sequential transactions could be a one-week
check run, and, since it is an automated control, if that block of transactions is
appropriate, then I can be reasonably certain that all other blocks produced by the same
process are also appropriate.

e. Probability Proportional to Size

Probability Proportional to Size (PPS) sampling is a method of sampling based on


attribute sampling in which the attribute is dollars rather than a physical attribute. This method of
selecting the sample creates an intentional systemic bias toward the selection of high dollar
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items. This intentional selection of a stratum consisting of high dollar items is indicated in the
sampling guide for internal auditors as follows:

The sampling technique is named for the manner in which the accounts are
selected to be audited. The probability of an account being included in the
sample is proportional to its size. As a result, large accounts have a higher
probability of being audited. Thus the technique automatically provides audit
evidence to large accounts in a population.li

This method of sampling requires using a set of tables and methods of evaluation that are
specific to the methodology. Details for using this methodology can be found in the sampling
guide for internal auditorslii

f. Computer Assisted Auditing Techniques (CAAT)

The number of transactions being processed in todays financial payments systems and
financial reporting systems make it almost impossible to manually select and audit 100% of the
transactions for control attributes or dollar amounts. This has provided an impetus for Computer
Assisted Auditing Techniques (CAAT). CAAT software, with well-designed cost effective
sampling programs, is some of the most economically feasible methods to sample transactions
(up to 100%), for control acceptance testing, or account Summing assurance. For these
reasons, the technique can be the cornerstones for gathering auditable information on automated
transaction-based processes, and for systems utilizing large database management systems. For
organizations with consolidated subsidiaries, the value of CAAT sampling and testing of
transactions from the subsidiary for accuracy and correctness can be a significant time saver, and
there is audit software available for this purpose. One of the more effective ways to accomplish
an audit of all transactions is to have the transaction details safely copied from the consolidating
closing process to an auditors Sandbox and use CAAT techniques to verify and sample the
detail transactions. This eliminates the risk of changing transactions in the actual Production
database.

As food for thought, consider that in modern high transaction-volume, computer based
accounting systems 100% of the auditable transactions are in the IT systems databases or files at
one point or another. Given that consideration, Computer Assisted Auditing Techniques that can
apply 100% testing capability for stored transactions makes a lot of sense.

VI. Comparative Analysis of Sampling

1. Sampling in Financial Reporting Processes

Once a financial reporting process has been described, the reporting and operational risks
analyzed, and the workflow documented, preferably as a flowchart with a supporting
walkthrough narrative, the internal auditor can evaluate the effectiveness of specific control
attributes by sampling transactions that flow through the complete process, or through complete
branches of the reporting process. Generally, the sampling can be done by selecting documents
that evidence whether or not the control activity or attribute is being performed. This may be
basic, but it is critical if one is basing an audit conclusion related to the process on a sampling
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plan. There must be adequate documentation that all steps in the process have been performed.
Generally a valid statistical sampling plan can verify the operational effectiveness of this
complete workflow. If a financial process is organized as a sequence of specific activities
performed in a stable and controllable process, the auditor should be able to sample process flow
documents rather than the individual transaction documents and verify whether or not the entire
process is performing as designed. This could require the process itself to be designed with the
capability to collect the necessary information needed (process flow documents), and to provide
documented evidence that the attributes and process activities were being performed and
recorded in a controlled manner. A possible equivalent of this would be monitoring a
manufacturing process using statistical charts to continuously inform the auditor and the process
manager if the transaction processing steps were functioning in a stable and controlled manner.
This would be a form of statistical process control.

2. Statistical Process Control (SPC)

Statistical process control (SPC) is a technique of relying on a monitoring process to


produce predictable quality and quantity production results rather than performing one extensive
inspection at the end of a manufacturing line. Although it is predominantly used in
manufacturing to produce standard products, it can also be applied to processing transactions for
financial reporting. The focus of statistical process control is to design an effective method of
processing items, and then to measure and control any deviations or variations in the items being
processed or produced. If a process is properly designed and resourced to produce a desired
product and level of quality, it will do so consistently and reliably if there are no deviations from
the process activities. The purpose of SPC is to ensure that the process is performing reliably and
consistently. Statistical sampling of activities and process quality is an essential component of
SPC, as well as is continuous monitoring of the process for any deviations. Samples of the
process and product are drawn and converted to charts and other graphical representations of the
quality of the process. Variations in the process are discovered quickly, and the root cause of
the deviation is determined and corrected. In this feedback loop manner, the process is
statistically controlled, and the products or transactions are processed properly.

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AAG-SAM APP A, A-1
xlii
AAG-SAM APP A, Table A1, A2
xliii
Id. Exhibit A. 1
xliv
Id. page 85
xlv
Id. at A.4
xlvi
Id. at P 84, A5, A.6, A.7
xlvii
SAS 39 has been amended by SAS 111
xlviii
Neal B. Hitzig, Statistical Sampling Revisited, CPA Journal, May 2004/Vol. LXXIV No. 5.
xlix
Dimitri P. Bertsekas, John N. Tsitsikilis, Introduction to Probability, MIT, Athena Scientific,
Belmont Massachusetts P 17
l
Id.
li
Barbara Apostolou, Sampling: A Guide for Internal Auditors, (Copyright 2004, IIARF) P 45
lii
Id. At P 47

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