Oral explanations as documentation in a review under SSARS 19

SSARS 19 places some limits on how oral explanations can be used as documentation in a review.  It says an oral explanation just by itself is not sufficient support for the work performed during a review.  Oral explanations can be used to clarify or explain information that is already in the documentation.

What does that mean?  If there is nothing in your workpapers to support a particular procedure, analytical, or inquiry, then you cannot provide an oral explanation that you really did the procedure or reached the conclusion or got an acceptable response to the inquiry.  On the other hand, if what is already documented in your workpapers is unclear, incomplete, or just a little fuzzy, then you could provide an oral explanation to fill in the details.

What you can’t do is be in a situation where there is nothing in the workpapers and then come back and say you really did such-and-such procedure.

The ironic thing is that you would be in far better position for a confused, fuzzy, or illogical comment in the workpaper than for there to be nothing.  If there is anything in the workpapers, then an oral explanation would be allowed.

This could cause you problems in a peer review or internal inspection situation.  If there is nothing in the workpapers to address a particular inquiry, odd analytical or obviously odd relationship in the financials,  then the peer reviewer can not entertain your oral explanation to address the issue.  Not good.

Even worse.  Imagine being in a deposition and getting shut down by opposing counsel about some significant inquiry or analytical with you sputtering, “but I got a good answer to the question”.  Not a good place to be.

Far better to have something, anything in the workpapers.

Other posts on documentation for a compilation are here, for a review start here.

Leave a Comment

Your email address will not be published.