Neal B. Hitzig
standards are undergoing revision in the wake of recent, massive
audit failures. Legislative and regulatory bodies are focusing
more critically on auditors than ever before. Yet, contemplated
revisions to auditing standards leave untouched ambiguities
and unresolved issues that have reduced the effectiveness
of the authoritative literature for decades. One of the longest-standing
issues concerns the role and appropriateness of statistical
sampling as a substantive audit testing procedure.
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
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.
tests are intended to detect and estimate misstatement in
accounts and classes of transactions. The authoritative
literature recognizes two types of substantive tests: tests
of details, and analytical procedures. Except in those cases
where complete enumeration of an accounting population is
feasible (as in certain computer-assisted auditing techniques),
the audit sample is a principal approach to performing the
test of details.
auditors apply sampling to test controls, despite concerns
that such applications may not reveal the information that
an auditor seeks. For example, the initialing of documents
does not mean that the documents are correct (if that is
what initialing purports to signify); it means only that
the documents were initialed. Similarly, the fact than an
invoice is correctly priced does not mean that a price-checking
control functioned properly, because the invoice may have
been properly priced in the first place. These examples
demonstrate why testing preventive controls with tests of
details may not inform the auditor that the subject controls
are functioning as intended.
the other hand, evidence of monetary misstatement in a transaction
or account is clear-cut evidence of the absence or malfunction
of a control. This is why many auditors view tests of details
as being most useful when performed as substantive tests.
350 does not provide a definition of nonstatistical sampling.
It states only that “[t]here are two approaches to
audit sampling: nonstatistical and statistical” (AU
350.03). The AICPA’s Audit Guide, Audit Sampling,
provides the following definition:
sampling procedure that does not measure the risk is a
nonstatistical sampling procedure. Even though the auditor
rigorously selects a random sample, the sampling procedure
is a nonstatistical sampling application if the auditor
does not make a statistical evaluation of the sample results.
statement establishes that an auditor may label a sampling
technique “nonstatistical” without regard to
the manner of sample selection. Thus, even though the Audit
Guide acknowledges the well-known ability of statistical
sampling to measure sampling risk, it nevertheless sanctions
an auditor’s decision to ignore available statistical
theory and rely instead on judgment or intuition in interpreting
the results of a sampling procedure. In short, the guide
gives guesswork equal status with measurability. Such a
view is potentially hazardous, because the auditor is permitted
to ignore facts that are readily discernable to any practitioner,
or legal adversary, who is knowledgeable in the application
of statistical methodology.
would an auditor prefer nonstatistical sampling, knowing
of the availability of objective statistical procedures?
Various reasons, restated in the 2001 edition of the Audit
Guide, have been cited as the impediments: the cost of training,
the cost of sample selection, the cost of sample evaluation.
With the passage of time, these reasons have become progressively
weaker. Mandatory continuing professional education is now
a reality, so there should be little reason for auditors
not to advance their skills in sampling techniques. As to
the implementation costs associated with the selection and
evaluation of random samples, the ready availability of
computers and off-the-shelf software has greatly mitigated,
if not eliminated, these factors as relevant considerations.
short, a nonstatistical sample is selected by the exercise
of judgment, and not by chance. Haphazard, judgmental, and
purposive sampling are some of the terms that describe a
350 and the Audit Guide approach statistical sampling in
a roundabout way. The Audit Guide states:
sampling helps the auditor (1) design an efficient sample,
(2) measure the sufficiency of the evidential matter obtained,
and (3) quantitatively evaluate the sample results.
sampling uses the laws of probability to measure sampling
risk. (AAG-SAM 2.17)
the foregoing statements are correct, they do not define
statistical sampling per se.
sampling is probability sampling. In probability sampling,
every item in the population under audit has a known chance
of selection. The decision as to which items in the population
are to be selected is left to the laws of chance, not to
judgment. The most common probability sampling methods in
auditing are equal probability (such as simple random and
systematic sampling) and sampling with probability proportional
to size (such as monetary unit sampling).
prominent feature of statistical sampling is its ability
to measure risk. The measurement instrument is the confidence
interval, which gives a calculated range of values for the
estimated amount of misstatement in a population. The measurability
of statistical sampling distinguishes it from so-called
judgment sampling, where the decision as to the items selected
for examination is left to the judgment of the auditor.
Statistical sampling is a measurement tool. When applied
in a substantive test of details, it measures misstatement
in an account or class of transactions. Its ability to measure
arises from the selection method used, which is probability
sampling. Lawyers, judges, and statisticians have explicitly
recognized these features of statistical sampling. The Special
Committee on Empirical Data in Decision Making, Recommendation
on Pretrial Proceeding in Cases with Voluminous Data, made
the following statement (see Appendix F, in Fienberg, S.E.,
ed., The Evolving Role of Statistical Assessments as
Evidence in the Courts, 1989):
a survey is based on probability sampling, the probabilities
or risks of sampling misstatements of various sizes can
be calculated. This requires the application of appropriate
statistical formulas. Assessments of sampling misstatement
are very often expressed in terms of a standard misstatement.
This is a universally accepted measure of the
margin of error in a survey result that is attributable
illuminating report should serve to alert auditors to the
growing use of statistically based evidence in litigation
and, by implication, to the risks they face should they
ignore the information contained in samples.
implication is clear: Ignore the formulas applicable to
the results of a probability sample and rely instead on
intuition at your own risk.
auditors believe that they must calculate a sample size
beforehand for an audit sample to be statistical. This is
incorrect. Any probability sample can be subjected to evaluation
by application of the laws of probability, however arbitrary
the choice of sample size. Failure to calculate beforehand
usually results in samples that are either too large or
too small for the auditor’s objectives. They are,
and nonstatistical sampling methods are defined in terms
of the method by which a sample is selected, not in terms
of a decision by the auditor not to apply statistical methods,
even to a random sample.
Is Statistical Sampling Appropriate?
sampling is appropriate whenever an auditor wishes to draw
a conclusion about a population without performing an examination
of all the items composing that population. Moreover, statistical
sampling is appropriate when the auditor has no prior knowledge
as to which specific items in a population are misstated.
important concern that affects the sampling decision is
the practicability of selecting a probability sample. If
files are computerized and 100% verification cannot be performed
by computer-assisted audit techniques, then probability
sampling is most likely to be the practical approach. If
files are not computerized and the population is large (as
a rough rule of thumb, a large population has more than
500 items), then probability sampling may still be practicable.
If a population of manual records is maintained in numerical
order, a computer application may be used to select random
numbers that identify the items to be selected, even items
at multiple locations. The items are then located by hand.
If the population is not maintained in numerical order,
then systematic selection (select every kth item after a
random start) may be performed. Systematic selection is
one of the easiest procedures to apply, although proper
application requires counting through the population. Although
many caution that systematic selection is subject to bias
because a key characteristic of the population under examination
may coincide with the selection interval, in more than 30
years of practice, the author has never observed this to
be even a remote practical concern.
sampling is appropriate for both routine and nonroutine
accounting processes. In a test of purchase transactions,
for example, the auditor may employ statistical sampling
to test for misstatement in account distribution. An auditor
may also apply statistical sampling to a population of securities
positions for a large broker-dealer with thousands of positions,
to test valuation and existence assertions.
350 states “[s]ampling risk arises from the possibility
that, when a 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 [population].” (AU 350.10) AU
350 also identified two aspects of sampling risk:
risk of incorrect acceptance is the risk that the
sample supports the conclusion that the recorded account
balance is not materially misstated when it is materially
risk of incorrect rejection is the risk that the
sample supports the conclusion that the recorded balance
is materially misstated when it is not materially misstated.
practice, it is convenient to think of the foregoing in
terms of detection risk and estimation risk, respectively.
risk is the chance that a sample will fail to detect misstatement
that actually exceeds the auditor’s specified maximum
tolerable amount. “Detection”
refers to the decision rule that an auditor applies to decide
whether a misstatement is tolerable under the circumstances.
A commonly employed rule is the comparison of the calculated
upper confidence limit of misstatement with the specified
maximum tolerable amount. In SAS 39 terms, the upper confidence
limit is the projected misstatement plus the allowance for
sampling risk. If the calculated limit is greater than the
maximum tolerable amount, the auditor decides that misstatement
may exceed the tolerable amount. Otherwise, the auditor
decides that misstatement, if it exists, is tolerable. If
a properly designed sample discloses no misstatements, the
auditor may then decide that misstatement in the population
under audit does not exceed the maximum tolerable amount.
risk is principally a planning concept. The auditor specifies
it beforehand and uses it as one of the factors that determines
the appropriate extent of testing reflected in the sample
misstatements are detected, on the other hand, the estimation
risk becomes the key risk under consideration. Estimation
risk is the chance that the actual amount of misstatement
will not be within the calculated confidence interval. SAS
39 is dismissive of this risk, which it labels the risk
of incorrect rejection, as being merely an efficiency issue.
AU 350.12 states:
the auditor’s evaluation leads him to the initial
erroneous conclusion that a balance is materially misstated
when it is not, the application of additional audit procedures
and consideration of other audit evidence would ordinarily
lead the auditor to the correct conclusion.
is misleading. An auditor does not know that his conclusion
is incorrect; only that the evidence suggests that the population
may be materially misstated. Frequently, this is sufficient
for action, and no further audit evidence is needed, even
if it were practicable to extend testing or to apply alternate
procedures. More seriously, AU 350.12 invites the auditor
to disregard the results of an unfavorable sample outcome
and subordinate it to other, contradictory evidence whose
reliability may be less than that of the sample.
if the results of an audit sample are sufficiently precise,
they may provide the basis for the proposal of an adjusting
journal entry by the auditor. In such a case, the appropriate
risk consideration is that the adjustment is materially
correct. The calculated confidence interval provides the
basis for that assessment. Estimation risk is the complement
of the confidence level.
Sampling and Audit Decisions
auditor uses a sample to decide whether misstatement exists
and whether it may exceed the tolerable misstatement. This
is the essence of the detection objective of a substantive
test of details. While is it possible to design a sample
to control for both the detection and estimation risk, audit
samples often are designed only with the detection objective
in mind. Nonetheless, if a properly selected random sample
has disclosed misstatement, that sample can always be used
to obtain a confidence interval on the amount of misstatement,
regardless of the planning decisions and the consequent
convenience, interval estimates may be classified into six
basic categories, each of which is informative in its own
way as to the extent of misstatement in the population.
The possibilities are discussed below in terms of tolerable
misstatement (TM), which is $600,000 in the examples, the
lower confidence limit (LCL) on the estimated misstatement,
and the upper confidence limit (UCL) on the estimated misstatement.
The projected misstatement (that is, point estimate) is
not needed, as the following examples will show. More importantly,
the projected misstatement could be misleading. A projection
(or point estimate) is merely one outcome in a sample space.
Its principal function is to be locator for the confidence
interval. It provides no information as to its margin of
error. For example, 10 missstatements of $100 each will
yield the same point estimate as one $1,000 misstatement,
but the latter’s margin of error is greater.
1. If neither confidence limit exceeds the
tolerable misstatement and $0 is included within the confidence
interval, then the auditor would decide that misstatement,
if present, is no greater than tolerable misstatement. This
case suggests that the amount of misstatement might also
be trivial. (See the Exhibit,
is the most favorable outcome. This outcome can arise even
if misstatements are detected. For example, many misstatements
of very small magnitude might yield such a confidence interval.
The auditor would conclude that net misstatement, if it
exists, does not exceed $200,000 of understatement or $400,000
of overstatement. Because neither amount exceeds $600,000,
the auditor may conclude that misstatement is tolerable.
Because $0 is within the confidence interval, it is possible
that net misstatement may be $0.
for situations where the sample discloses no misstatement,
this case does not apply when the auditor is performing
tests of overstatement, such as for the existence or the
lower of cost or market.
2. If neither confidence limit exceeds the
tolerable misstatement and $0 is outside the confidence
interval, then the auditor would decide that the population
is misstated, but the amount of misstatement is no greater
than the tolerable misstatement. (See the Exhibit,
is similar to Example 1, except that the sample evidence
indicates some misstatement. That is, the auditor may be
confident that the population is overstated by at least
$150,000, but not by more than $400,000.
3. This case is the same as above, except
that one of the confidence limits exceeds the tolerable
misstatement. The auditor would conclude that the population
is misstated and that the total misstatement may be greater
than the tolerable misstatement, but it also may be less.
The auditor cannot accept the population as being fairly
stated on the sample evidence provided. (See the Exhibit,
situation arises when the disclosed misstatements exceed
the auditor’s expectation. This can occur in a sample
even though the actual population misstatement is as expected.
In fact, if the actual population misstatement is equal
to the amount expected by the auditor and used to determine
sample size, then there is roughly a 50% chance that the
sample’s projected misstatement will be greater than
the expected misstatement. In the context of AU 350’s
approach to interpretation of results, this outcome would
imply that the risk of intolerable misstatement is greater
than the level specified by the auditor as the risk of incorrect
is a common outcome of audit samples. It is the outcome
to be expected if the difference between the actual (but
unknown) misstatement and tolerable misstatement is less
than the precision of the sample estimate.
the audit sample in such a circumstance often only confirms
the initial finding, albeit more precisely, because the
range of the confidence interval decreases as the sample
size increases. In this case, an adjusting journal entry
might be proposed. Whether a possible adjustment would be
passed over is a question that would await the completion
of the audit.
4. In this case, just one of the confidence
limits exceeds the tolerable misstatement, but the lower
limit is negative and the upper limit is positive. The results
indicate that the population may be overstated by as much
as $800,000 (greater than the tolerable misstatement) or
it may be understated by as much as $300,000 (less than
the tolerable misstatement). The net misstatement could
also be $0. Nevertheless, because one of the limits exceeds
tolerable misstatement, the auditor may not conclude that
the population is fairly stated. (See the Exhibit,
outcome can be the result of either the projected misstatement
exceeding expectation or the variability of the misstatements
in the sample being larger than planned. This situation
is common to inventory valuation tests, such as price tests,
where large, offsetting misstatements are disclosed. The
result strongly suggests significant weakness in controls.
5. In this case, the confidence limits are
positive and negative and both exceed the tolerable misstatement.
The interval ranges from $800,000 of understatement to $800,000
of overstatement. The misstatement may exceed the tolerable
amount or it may be trivial. In this case, the sample results
are too imprecise for an audit decision at the specified
confidence level. (See the Exhibit,
in Example 4, of which Example 5 is a more extreme example,
this result is not uncommon to tests of inventory valuation,
where misstatements are more numerous than anticipated and
vary greatly as to magnitude and can be both under- and
overstated. While the results are not sufficiently precise
for an audit adjustment (in fact, no adjustment may be needed),
results such as these demonstrate that accounting controls,
if they exist, are ineffective. In addition, the result
questions whether sufficient evidence has been obtained.
6. If both confidence limits are positive
(or both negative) and both exceed the tolerable misstatement,
then the auditor would decide that misstatement indeed exceeds
the tolerable amount. In this case, where the overstatement
may range from $800,000 to $1,600,000, an adjusting journal
entry would be likely. (See the Exhibit,
Sampling and Audit Actions
auditor has three courses of action when a misstatement
Waive the misstatement
Do more work
Propose an adjusting journal entry.
question of whether the sample evidence is sufficient for
an audit conclusion about the population depends upon the
size of the confidence interval and the amount of tolerable
misstatement. If the length of the interval (from LCL to
UCL) is less than twice the tolerable misstatement, then
there is some materially correct value within the interval.
The auditor’s objective is not to estimate the amount
of misstatement with pinpoint precision. If an adjustment
is to be made, the auditor should be able to propose an
amount that will reduce any remaining misstatement to an
amount that is no greater than the tolerable misstatement.
the risk level specified by the auditor when evaluating
the sample, an adjusting journal entry (AJE) can be proposed
that reduces the misstatement in the population to an amount
that is no greater than the tolerable misstatement. Suppose
that a 90% confidence interval yields a lower limit of $800,000
and an upper limit of $1,600,000, and that the tolerable
misstatement is $600,000. The range of the interval ($800,000)
is less than two times the tolerable misstatement. Exhibit
Figure 7 shows that a materially correct AJE can be booked
within a range of values from $1 million to $1,400,000.
In other words, any value within the confidence interval
would be a tolerably correct AJE if both confidence limits
are within the tolerable misstatement of the proposed adjustment.
The risk would be no greater than the specified estimation
of Figure 7 should make it evident why two-sided interval
estimation is important in cases where adjusting journal
entries are being considered. Auditing literature has, in
recent years, focused exclusively on the upper confidence
limit of misstatement (that is, the confidence limit further
from zero). Such a focus does not provide adequate basis
for proposing sufficiently correct adjustments. By looking
at only the upper limit, the auditor could inadvertently
propose too large an adjustment, turning a case that was
intolerably overstated into one that is intolerably understated.
Only by reference to the lower confidence limit can the
auditor avoid such an outcome. The Audit Guide is not clear
regarding the foregoing, providing only a one-sentence approach
to audit adjustments (AAG-SAM 7.36).
Statistical Sampling Undermine Auditor Judgment?
auditors continue to resist applying statistical sampling.
In addition to objections to the cost of training, the cost
of sample selection, and the cost of sample evaluation,
some auditors have expressed concern that statistical sampling
impedes auditor judgment. This assertion is no truer than
the assertion that laboratory biopsy is an impediment to
a physician’s exercise of judgment. Auditor judgment
is essential in several key respects: in deciding tolerable
misstatement, in choosing the method for selecting the sample,
in analyzing and assessing the population’s characteristics
(such as the expected misstatement and variability of misstatement
amounts), in deciding the appropriate risk level, and in
deciding the method of estimation. If the auditor suspects
that some population categories are more likely to contain
misstatement, a sampling plan to accommodate such judgments
can be devised.
is not applied in the random selection process, which is
left to the operation of the laws of chance, and in the
construction of the confidence interval after the sample
results are available.
ASB and the Public Company Accounting Oversight Board should
provide explicit recognition of the superiority of statistical
sampling in situations where the auditor has no specific
knowledge as to the location and amounts of individual misstatements
in an accounting population. The recently published Audit
Guide, which “includes increased coverage of nonstatistical
audit sampling,” is a step in the wrong direction.
It is time for the profession to acknowledge that audit
sampling is a decision tool that calls for the application
of objective, defensible techniques, not guesswork.
B. Hitzig, PhD, CPA, is professor of accounting and
information systems at Queens College (CUNY). He is a member
of the Auditing Standards and Procedures Committee of the
NYSSCPA and a retired partner of Ernst & Young.