7 - FIAR Spt TO 0003 E C FINAL PWS.docx
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- Air Force Financial Improvement and Audit Readiness (FIAR) Support Federal contract opportunity
- Solicitation number
- FA4890-12-R-0006
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Solicitation No. FA4890-10-R-0001 AF FIAR Support Task Order 0003-E&C of Mission Critical Assets Audit Readiness PWS Solicitation No. FA4890-12-R-0006
PERFORMANCE WORK STATEMENT
FOR
AIR FORCE
FINANCIAL IMPROVEMENT & AUDIT READINESS (FIAR)
SUPPORT
TASK ORDER 0003
EXISTENCE & COMPLETENESS OF MISSION CRITICAL ASSETS
(CURRENT) AUDIT READINESS (ASSERTION & SUSTAINMENT)
Contract No. FA4890-12-D-000X-0003
TABLE OF CONTENTS
| 1.0 BACKGROUND……………………………………………………………………….. | 3 | |
| 1.1 | Mission……………………………………………………………………………... | 3 |
| 1.2 | Scope………………………………………………………………………………. | 3 |
| 1.3 | Reference………………………………………………………………………….. | 3 |
| 2.0 TASK ORDER REQUIREMENTS…………………………………………………… | 3 | |
| 2.1 | Objectives…………………………………………………………………………... | 3 |
| 2.2 | Performance Schedule……………………………………………………………… | 4 |
| 2.3 | Performance Locations……………………………………………………………... | 4 |
| 2.4 | Travel.……………………………………………………………………………… | 4 |
| 2.5 | Key Positions………………………………………………………………………. | 4 |
| 2.6 | Meetings……………………………………………………………………………. | 4 |
| 2.7 | Kick-Off Meeting………………………………………………………………….. | 4 |
| 2.8 | General Audit Readiness and Sustainment Requirements.………………………… | 4 |
| 2.9 | Existence & Completion of Mission Critical Assets Assertion Packages..................7 | |
| 2.10 Sustainment………………………………………………………………………… | 7 |
| 3.0 OTHER APPLICABLE DATA……………………………………………………….. | 8 | |
| 3.1 | Travel………………………………………………………………………………. | 8 |
| 3.2 | Administrative Considerations…………………………………………………….. | 8 |
| 3.3 | Environmental, Safety and Health…………………………………………………. | 8 |
| 3.4 | Security…………………………………………………………………………….. | 8 |
| 3.5 | Government Furnished Items……………………………………………………… | 8 |
| 4.0 PERFORMANCE EVALUATION……………………………………………………. | 8 | |
| 4.1 | Deliverables………………………………………………………………………… | 8 |
| 4.2 | Services Summary………………………………………………………………….. | 9 |
APPENDICES
| Appendix A | Acronyms…………………………………………………………………. | 11 |
| Appendix B | Mandatory Supplemental Documentation………………………………… | 12 |
TABLES
| Table 1 | Journal Voucher (JV) Historical Data……………………………………………….. | 5 |
| Table 2 | Contract Deliverables………………………………………………………………… | 9 |
| Table 3 | Services Summary…………………………………………………………………… | 10 |
| Table 4 | Contract Acronyms………………………………………………………………....... | 11 |
| Table 5 | Mandatory Supplemental Documentation ……………...…………………………… | 12 |
1.0 BACKGROUND.
1.1 Mission. The Financial Improvement and Audit Readiness (FIAR) requirement is owned by the Assistant Secretary of the Air Force (Financial Management and Comptroller) (SAF/FM), and managed by Air Combat Command (ACC) Acquisition Management and Integration Center (AMIC). SAF/FM has the responsibility for providing the financial management and analytical services necessary for the effective and efficient use of Air Force (AF) resources, to include more than 650,000 military and civilian personnel and a budget of more than $160 billion. SAF/FM serves as the Secretary of the AF's trusted advisor by providing high-quality support to decision makers on budgetary, financial, cost and economic issues while continuously improving the quality, efficiency and customer-focus of AF financial services and operations. SAF/FMP is responsible at the executive level for ensuring the AF complies with legislative and executive financial management mandates leading to the effective and efficient use of AF resources.
1.2 Scope.
1.2.1 SAF/FM produces AF financial statements to assist financial managers in their decision-making processes by providing relevant and reliable financial information to help the AF meet the requirements of the FIAR. A major objective of SAF/FM is for these financial statements to achieve an unqualified or “clean” audit opinion for each AF financial statement. The conduit developed to assist in obtaining audit readiness is through Financial Improvement Plans (FIP). In response to the FIP, each AF organization is responsible for identifying measureable steps to ensure that each financial End to End business process is auditable, resulting in resolution of all major accounting and reporting deficiencies, and determination of dates when approved areas will be ready for validation and audit by independent external auditors.
1.2.2 The FIP process requires developed assertion packages that fully describe “audit trail” information for each assertion package/assessable unit and statement, and provide compliance information for each primary and feeder system involved in the development of these financial statements and are in compliance with Office of Secretary of Defense (Comptroller) (OUSD (C)) guidance. This information is compiled and incorporated into each management assertion package and maintained as part of an ongoing sustainment effort.
1.3 Reference. Air Combat Command (ACC) Performance Work Statement (PWS) for the AF FIAR Support contract.
2.0 TASK ORDER REQUIREMENTS.
2.1 Objectives. The objective of this task order is to provide Advisory and Assistance (A&AS) support to:
· Achieve audit readiness for the 12 currently identified assertion packages/assessable units with developed FIPs under the Existence and Completeness (E&C) of Mission Critical Assets in time to achieve assertion by 30 September 2015;
· Sustain the 12 assessable units in an audit ready state through 29 July 2017.
2.2 Performance Schedule. The Contractor shall perform the tasks detailed in this task order from 30 July 2012 (or award date) to 29 July 2017.
2.3 Performance Locations. Ongoing performance under this contract will be required at:
· National Capital Region (NCR)
· Wright Patterson Air Force Base (AFB), OH
2.4 Travel. Travel may be required as detailed in ID/IQ PWS paragraphs 1.2.7, 1.2.8 and 2.6.4 and subparagraphs, to include:
· Air Force Accounting and Finance Office (AFAFO), Denver, CO
· Defense Finance and Accounting Service (DFAS)-Columbus, OH
2.5 Key Positions. Any positions proposed as key for this task as part of the Indefinite Delivery/Indefinite Quantity (ID/IQ) proposal will be considered binding key positions for the life of this task order.
2.6 Meetings. The Contractor shall support, attend, and participate in Statement of Budgetary Resources (SBR)-related meetings convened at the direction of the applicable Contracting Officer Representative (COR). The Contractor shall provide information in support of meetings and briefings in the format requested by the Government. Below is a list of regular meetings for SBR:
· Monthly Integrated Project Team (IPT)/Executive Steering Committee (ESC) Meetings (The IPT and ESC are each held every other month, on a rotating basis, with one of these meetings held each month)
· Monthly In-Progress Reviews (IPR) for each assertion package/assessable unit
· Weekly Team Update Meeting (TUM) for each SBR assertion package/assessable unit with SAF/FMPA COR
· Support only typically required for the following
· Weekly Management Update with SAF/FMPA
· Bi-monthly meeting with Air Force Under Secretary of Management (SAF/USM)
· Monthly FIAR Committee Meeting
· Monthly FIAR Sub-committee Meeting
· Quarterly FIAR Governance Board
2.7 Kick-Off Meeting. The Contractor shall attend a kick-off meeting in the NCR, within 10 business days of contract award, as part of the scheduled ID/IQ Kick-Off meeting, with the members of the Government Program Management Office (PMO), the Contacting Officer Representative(s) (COR), SAF/FMP leadership, and other officials as designated by the Government. See Table 2 – Contract Deliverables for details.
2.8 General Audit Readiness and Sustainment Requirements. For both assertion (pre-OUSD(C) approval) and sustainment (post OUSD(C) approval), the Contractor shall:
2.8.1 Utilize AF Acceleration Plan to determine stage of assertion/sustainment required. Then, reference applicable FIP to determine progress toward completion.
2.8.2 Obtain, collect and evaluate audit evidence to support Key Control Objectives (KCO) and overall readiness IAW FIPs, FIAR Guidance and AF Acceleration Plan so that the Government can provide evidence that all KCOs are met.
2.8.2.1 Assist the Government in performance of the Discovery, Corrective Action, Evaluation and Assertion Phases identified in FIAR Guidance for each FIP (Assertion Phase not required for Sustainment). Each FIP will be in various Phases of progress at performance start (see PWS Appendix B, Table 5 - Mandatory Supplemental Documentation). The Contractor shall provide audit liaison support for the Validation and Audit Phases identified in FIAR Guidance and each FIP. The Government will track the status of assertion packages/assessable units to/from OUSD(C) and DoD Inspector General (DoDIG).
2.8.2.2 The Government has identified Deal Breakers within each FIP that have historically resulted in material weaknesses or misstatements. Assertion package documentation and processes shall specifically address the Deal Breakers; however, separate Deal Breaker documentation is not required.
2.8.3 Recommend, obtain, and analyze ad hoc queries, miscellaneous reports or documentation to applicable COR/Team Lead to capture data to support development and sustainment of assertion packages/assessable units. Recommend actions based on analysis.
2.8.4 Review Journal Voucher (JV) transactions (currently a total of approximately 10,000 Air Force JVs in various stages of validation), validate appropriateness, and recommend corrective action for unsupportable JV transactions, as well as recommendations to ensure only valid use of JVs across the AF.
Table 1 – JV Historical Data
| FY |
| JV’s performed for the Air Force |
| 2010 |
| 9,265 (3,801 system generated; 5,464 manual) |
| 2011 |
| 9,004 (3,709 system generated; 5,295 manual) |
Note: These are total JVs performed by DFAS on behalf of the AF each fiscal year. At the start of each year, as JVs are validated, follow-on action is not required for those JVs; therefore, the totals do not represent the workload throughout the year.
2.8.5 Maintain consistent format and organization of all assertion and sustainment documentation across all assertion packages/assessable units.
2.8.5.1 Assertion and sustainment documentation include system and process flow documentation, risk analysis, control analysis, internal control testing, and evaluation of testing, and Corrective Action Plan (CAP) including documentation of manual workarounds and compensating controls involved in the development of these packages.
2.8.5.2 All documents shall be in editable and searchable versions of Microsoft Office, Microsoft Project, Microsoft Visio 2007 or 2010, Portable Document Format (PDF) using Acrobat Adobe 8.0 or 9.0 (or the latest Government versions).
2.8.5.3 Upload all documentation applicable to an assertion package/assessable unit or statement to the Contracting Officer Representative (COR)-designated location upon Government acceptance.
2.8.6 Financial Improvement Plan (FIP) Management.
2.8.6.1 FIP Management may require use of Microsoft Project.
2.8.6.2 Submit FIPs for update in the FIAR Planning Tool (FIAR-PT) with actual start and completion dates and status of each line item.
2.8.6.3 Once Contractor management review is complete and the Contractor has updated a deliverable (work product) based on applicable Government and Contractor management reviews, the Contractor shall provide the final deliverable (work product) to the applicable COR for acceptance and validation that deliverables are 100% complete.
2.8.6.4 Upon completion of all work products in an assertion package, the Contractor shall present the executive summary/statement of assertion to the applicable COR for acceptance and validation that 100% complete.
2.8.7 Assist in any oral or written presentation required in the review and approval process for each assertion package (see AF FIAR Support ID/IQ PWS paragraph 1.2 and subparagraphs).
2.8.8 Attain and sustain audit readiness once an audit ready state is achieved.
2.8.9 Update assertion packages for any systems changes to include current ‘as is’ and ‘to be’ environments per FIAR Guidance once the Defense Enterprise Accounting and Management System (DEAMS) (developed under a separate contract) is implemented and utilized within the applicable assessable unit.
2.8.10 Where deficiencies (see subparagraphs) exist, the Contractor shall work with applicable Government personnel to recommend executable corrective actions to meet assertion milestones. In those cases where executable corrective action is not deemed possible, notify the Functional Owner/COR of any actions that may delay/preclude assertion, with recommended resource/timeline requirements. Deficiencies may take the form of, but are not limited to:
2.8.10.1 Material weakness or misstatement;
2.8.10.2 Transactions that are not captured under one of the assertion packages/assessable units;
2.8.10.3 Unidentified assertion packages/assessable unit(s).
2.8.10.4 Lack of required data or lack of access to required data to support efforts.
2.8.11 Comply with Financial Improvement Systems Controls Audit Manual (FISCAM) requirements (see AF FIAR Support ID/IQ PWS Appendix B, Table 7 - Mandatory Supplemental Documentation).
2.8.12 Contracting Officer Representative (COR). The COR for this portion of the effort is located in the SAF/FMPS office in the NCR.
2.9 Existence and Completion (E&C) of Mission Critical Assets Assertion Packages.
2.9.1 The Contractor shall achieve audit readiness for assertion and sustain an audit ready state (per progress indicated in FIPs) of each assertion package/assessable unit. Current documentation reflects 12 assertion packages/assessable units, each of which has a developed FIP (in order of assertion completion date):
· Military Equipment
· Cruise Missiles
· Aerial Target Drones
· Spare Engines
· Uninstalled Missile Motors
· Medical Equipment
· Real Property
· Munitions
· General Equipment
· Government Furnished Equipment
· Weapon System Spares Contractor Managed/AF Possessed
· Weapon System Spares Contractor Managed/Contractor Possessed
2.9.2 There may be areas not covered within previous assessable units or assessable unit package documentation; therefore, the Contractor shall identify these areas to the Government and recommend solutions for incorporation. If the Government determines the workload warrants additional FIP(s), the Government will develop a new FIP. Once FIPs are developed, the Government will issue a separate task order(s) for new assertion packages/assessable units.
2.9.3 No overarching consolidated E&C of Mission Critical Assets assertion required.
2.9.4 Complete assertion of all E&C of Mission Critical Assets assessable units required by 30 September 2015.
2.9.5 Contracting Officer Representative (COR). The COR for this portion of the effort is located in the SAF/FMPA office in the NCR.
2.10 Sustainment.
2.10.1 The Contractor shall update assertion packages identified in this PWS to maintain audit readiness.
2.10.1.1 Complete by 31 March of each year, effective 30 September of previous FY, to maintain audit readiness, for duration of contract.
2.10.1.2 OUSD(C) approval not required.
2.10.2 The Contractor shall perform risk and/or materiality based sustainment testing for each assertion package/assessable unit.
2.10.3 COR located in SAF/FMPA office at Wright Patterson Air Force Base, OH.
3.0 OTHER APPLICABLE DATA. The Contractor shall abide by all parameters set forth in Air Force FIAR Support ID/IQ Contract, as follows:
3.1 Travel. Paragraph 2.6.4 and subparagraphs.
3.2 Administrative Considerations. Paragraph 2.7 and subparagraphs unless otherwise specified in this task order.
3.3 Environmental, Safety and Health. Paragraphs 3.0 and 4.0.
3.4 Security.
3.4.1 Paragraphs 5.0, 5.1, 5.2, 5.3, 5.5, 5.6 and 5.7 and subparagraphs (ID/IQ 5.4 applies at the ID/IQ level).
3.4.2 Paragraph 5.3.3 if a subcontractor is contracted to perform the work on a task order requirement.
3.5 Government Furnished Items. Paragraph 8.0 and subparagraphs. In addition to the Supplemental Documentation listed in the ID/IQ contract, Appendix B, this task order is subject to the additional documentation listed in this PWS at Appendix B, Table 5 – Mandatory Supplemental Documentation.
4.0 PERFORMANCE EVALUATION. The Contractor shall abide by all parameters set forth in AF FIAR Support ID/IQ Contract paragraph 7.0 and subparagraphs.
4.1 Deliverables.
4.1.1 If a deliverable due date falls on a weekend or holiday, the Contractor shall submit the deliverable on the last work day prior to the due date.
4.1.2 The Contractor shall develop and provide thorough and detailed deliverables that shall be in editable and searchable versions of Microsoft Office 2007 or 2010, PDF using Acrobat Adobe 8.0 or 9.0 (or the latest Government versions). Deliverable requirements are as follows:
Table 2 – Contract Deliverables
| Deliverable |
| Details |
| Assertion Package deliverables (work products outlined in Figures 14 through 24 of paragraph 3.A.5 of the FIAR Guidance dated December 2011 (or applicable updates)). |
| Reference: PWS paragraphs 2.8, 2.9 and 2.10 and subparagraphs |
Due Date: As specified in each FIP Details: As part of each Test Plan deliverable, the Contractor shall populate “Population and Sample Size” and “Test Results” rows of Test Plan with confidence and assurance levels required to achieve a minimally acceptable level of confidence/assurance (see AF FIAR Support ID/IQ PWS paragraph 6.2.1.1 and sub-bullets).
| Kick-off Meeting |
| Reference: PWS paragraph 2.7 |
Due Date: Attend within 10 calendar days of contract award Details: Government PMO responsible for setting up meeting.
| Contractor-identified concern that impacts the Contractor’s ability to meet FIP and AF Acceleration Plan milestones/ timelines |
| Reference: PWS paragraph 4.1.4 and AF FIAR Support ID/IQ PWS paragraph 7.3 |
Due Date/Details:
· Verbal and electronic notification identifying the nature of the issue to the COR within three (3) business hours of identification.
· Written recommendations and corrective actions required to meet FIP and AF Acceleration Plan milestones/timelines within eight (8) business hours of identification, unless otherwise approved in writing by the applicable COR.
4.1.3 Meeting the contract performance schedule is critical to the success of this requirement. Thus the contractor shall notify in writing the applicable COR, Quality Assurance Manager (QAM), and CO at any point during contract performance if they believe the Government has not provided requested information in a reasonable amount of time or if the information provided does not meet accuracy or completeness needs for continued successful performance. Appropriate Government personnel will then work to resolve the situation and final resolution and dispensation will be documented for the record by the CO.
4.2 Services Summary. This Services Summary identifies critical success factors for the contract. The Services Summary:
4.2.1 Lists performance objectives for the required service that the government will surveil. The government reserves the right to surveil all services called for in this PWS to determine whether the performance objectives and goals were met. The absence of any contract requirement from the Services Summary shall not detract from its enforceability nor limit the rights or remedies of the Government under any other provision of the contract.
4.2.2 States the performance objective, standard, and threshold (accept/reject point) for each critical success factor.
4.2.3 Will be used as the baseline to develop a Quality Assurance Surveillance Plan (QASP). The QASP will identify the audit methods/procedures the Government will use to evaluate the contractor's performance.
Table 3 – Services Summary
| OBJECTIVE |
| STANDARD |
| THRESHOLD |
Provide and retain qualified key personnel
Key personnel possess qualifications, certifications and experience as identified in Management/Staffing Plan Performance is acceptable when: a) Qualified key personnel are on the job at contract start, unless previously negotiated by the CO.
b) Vacancies are filled with qualified key personnel within 14 days of vacancy, unless approved in writing or otherwise directed in advance by the CO
AND
c) There is no mission impact due to position vacancies or unqualified personnel.
| Provide qualified people at task order start |
| See Paragraph 2.0 and applicable subparagraphs |
| Performance is acceptable when qualified personnel are on the job at task order start, unless previously negotiated by the CO |
| Develop Assertion Packages |
| Fully documented assertion packages |
delivered on or before FIP due date No major nonconformance is allowed.
| FIP Status Management |
| Maintain accurate FIPs |
| Performance is acceptable when: |
a) 100% of major FIP work product deliverables (bolded items) are submitted for update in the FIAR Planning Tool (FIAR-PT), when any changes occur, daily on contractually required work days; AND
b) 90% of lower level line items are submitted for update in the FIAR-PT, when any changes occur, daily on contractually required work days; remaining 10% are submitted for update in the FIAR-PT, when any changes occur, within two days on contractually required work days.
Deliverables Management
Develop and submit all required deliverables
Performance is acceptable when:
a) 100% of deliverable requirements are met and received on time AND
b) Critical information is accurate.
Initial Contract Performance Review (see AFI 63-101)
| Successfully started performance, and fully operational (proposal promises delivered) within 30 calendar days of task order start. |
| Performance is acceptable when there are no contractor-caused adverse impacts to cost, schedule, or performance. |
APPENDICES
APPENDIX A ACRONYMS
See AF Acceleration Plan, pages 70-76 and FIAR Guidance, Appendix F
Table 4 – Contract Acronyms
| A&AS |
| Advisory and Assistance Services |
| ACC |
| Air Combat Command |
| ADPE |
| Automatic Data Processing Equipment |
| AETC |
| Air Education and Training Command |
| AF |
| Air Force |
| AFB |
| Air Force Base |
| AFDW |
| Air Force District of Washington |
| AFGSC |
| Air Force Global Strike Command |
| AFI |
| Air Force Instruction |
| AFMC |
| Air Force Material Command |
| AFRC |
| Air Force Reserve Command |
| AFSOC |
| Air Force Special Operations Command |
| AFSPC |
| Air Force Space Command |
| AMC |
| Air Mobility Command |
| AMIC |
| Acquisition Management & Integration Ctr |
| ANG |
| Air National Guard |
| CAR |
| Corrective Action Request |
| CDFM |
| Certified Defense Financial Manager |
| CFO |
| Chief Financial Officer |
| CGFM |
| Certified Government Financial Manager |
| CIA |
| Certified Internal Auditor |
| CISA |
| Certified Information Systems Auditor |
| CLIN |
| Contact Line Item Number |
| CO |
| Contracting Officer |
| COMSEC |
| Communications Security |
| CONUS |
| Continental United States |
| COR |
| Contracting Officer Representative |
| CPA |
| Certified Public Accountant |
| DoD |
| Department of Defense |
| DRU |
| Direct Reporting Unit |
| E&C |
| Existence and Completeness |
| ESC |
| Executive Steering Committee |
| FAR |
| Federal Acquisition Regulation |
| FASAB |
| Federal Accounting Standards Advisory Board |
| FFP |
| Firm Fixed Price |
| FFP LOE |
| Firm Fixed Price Level of Effort |
| FIAR |
| Financial Improvement & Audit Readiness |
| FIP |
| Financial Improvement Plan |
| FISCAM |
| Federal Information Systems Controls Audit Manual |
| FOIA |
| Freedom of Information Act |
| FOUO |
| For Official Use Only |
| GAAP |
| Generally Accepted Accounting Principles |
| GAGAS |
| Generally Accepted Government Auditing Standards |
| HQ |
| Headquarters |
| IAW |
| In Accordance With |
| ICOFR |
| Internal Control over Financial Reporting |
| ID/IQ |
| Indefinite Delivery/Indefinite Quantity |
| IPA |
| Independent Public Accounting |
| IPR |
| In-Progress Review |
| IPT |
| Independent Project Team |
| JAFAN |
| Joint Air Force-Army-Navy |
| JPAS |
| Joint Personnel Adjudication System |
| KSA |
| Knowledge, Skills and Abilities |
| LAN |
| Local Area Network |
| MAJCOM |
| Major Command |
| MPR |
| Monthly Progress Report |
| NCR |
| National Capital Region |
| NLT |
| No Later Than |
| OCONUS |
| Outside the Continental United States |
| OMB |
| Office of Management and Budget |
| OUSD(C) |
| Office of Under Secretary of Defense (Comptroller) |
| PACAF |
| Pacific Air Forces |
| PM |
| Program Manager |
| PMO |
| Program Management Office |
| PWS |
| Performance Work Statement |
| QAM |
| Quality Assurance Manager |
| QAPC |
| Quality Assurance Program Coordinator |
| QASP |
| Quality Assurance Surveillance Plan |
| QCP |
| Quality Control Plan |
| R&D |
| Research and Development |
| SAF/FM |
| Assistant Secretary of the Air Force (Financial Management and Comptroller) |
| SBR |
| Statement of Budgetary Resources |
| SFFAC |
| Statements of Federal Financial Accounting Concepts |
| SFAS |
| Statements of Federal Financial Accounting Standards |
| TS/SCI |
| Top Secret/Sensitive Compartmented Information |
| TUM |
| Team Update Meeting |
| USAFA |
| United States Air Force Academy |
| USAFE |
| United States Air Forces Europe |
| VGSA |
| Visitor Group Security Agreement |
| WAR |
| Weekly Activity Report |
| WAWF |
| Wide Area Work Flow |
APPENDIX B MANDATORY SUPPLEMENTAL DOCUMENTATION
Table 5 – Mandatory Supplemental Documentation Financial Improvement Plans (FIP) – includes status of assertions
Military Equipment (currently under examination; will be in sustainment at task order start)
See all Mandatory Supplemental Documentation listed in the AF FIAR Support ID/IQ PWS
AF FIAR Support E&C PWS image2.emf
UNINST~1.XML
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2012-03-19T14:23:22Z 2012-03-19T13:51:33Z 12.00
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Project Details: Uninstalled Missile Motors
ID
WBS
Task Name Start Finish Baseline Start Baseline Finish % Complete Task Predecessors KCO Weakness Control Objective Test Status Primary FS Assertions Secondary FS Assertions FIAR Milestone A-123, Appendix A Other Milestone Type Responsible Person
FIE
Process L0 Process L1 Lead Org Support Org Resource Names LoE to Complete LoE Committed Task Notes Text 17 Text 18 Text 19 Text 20 Text 21 Text 22 Text 23 Text 24 Text 25 Financial Improvement Deliverable Financial Improvement Phase FR Review Item Work Product Milestone Execution View
Evaluation & Discovery 8/1/2011 2/3/2012 8/1/2011 2/3/2012 0%
No
1.1000000000000001 Statement to Process Analysis 1/3/2012 1/6/2012 1/3/2012 1/6/2012
1.1.1 Using the Financial Statement, prepare a process and systems drill down detailing accounts/transaction classes, underlying processes and associated systems--depicting "as-is" and "audit-ready" integrated environments 1/3/2012 1/6/2012 1/3/2012
SAF/FMPA
AF/A4LX
SMALSKAS; ROBERT
1.1.2 Using the mapping in step 1.1.1, compile quantitative drill down - levels 1 and 2 by transaction class by business process and supporting systems and feeder systems, including dollar activity and number of transactions for each assessable and sub-assessab 1/3/2012 1/6/2012 1/3/2012
1.2 Prioritization 1/3/2012 1/6/2012 1/3/2012
1.2.1 For each assessable unit listed in the matrix prepared in step 1.1, rank in order of quantitative materiality (largest dollar activity is highest priority) 1/3/2012 1/6/2012 1/3/2012
1.2.2 Identify and document a comprehensive list of significant qualitative risk associated with the assessable units (e.g., budgetary restriction over representation allowance) 1/3/2012 1/6/2012 1/3/2012
1.2.3 Identify all legacy processes/systems planned to be replaced by "audit-ready" integrated environment systems/processes before readiness assertion 1/3/2012 1/6/2012 1/3/2012
1.2.4 Document prioritization of assessable units using quantitative prioritization (step 1.2.1), adjusted for significant qualitative risks (step 1.2.2) and potentially scoping-out legacy processes that will not endure until assertion (step 1.2.3) 1/3/2012 1/6/2012 1/3/2012
1.3 Assess & Test Controls 12/5/2011 1/31/2012 12/5/2011 1/31/2012
1.3.1 For each assessable unit plan, identify all relevant Key Control Objectives and document in Section 2 of the plan 12/5/2011 1/31/2012 12/5/2011
1.3.2 Start with highest priority assessable units (step 1.2.4), to prepare process narratives, flowcharts, and worksheets documenting processes, risks, control activities (manual and automated) and IT general computer controls for significant systems 12/5/2011 1/31/2012 12/5/2011
1.3.3 Prepare Controls Assessment for each assessable unit, summarizing key control activities and noting deficiencies for missing control activities or control activities that are not designed effectively 12/5/2011 1/31/2012 12/5/2011
1.3.4 Execute tests of controls 12/5/2011 1/31/2012 12/5/2011
1.3.5 Summarize testing results on Controls Assessment 12/5/2011 1/31/2012 12/5/2011
1.3.6 Identify any deficiencies in the operation or documentation of control activities 12/5/2011 1/31/2012 12/5/2011
1.4 Evaluate Supporting Documentation 12/2/2011 2/3/2012 12/5/2011
1.4.1 Prepare/extract a population of transaction-level detail (or balance-level as appropriate) that agrees in total to the trial balance and document on account leadsheets 12/2/2011 12/5/2011 12/5/2011 12/5/2011
1.4.2 Perform initial data mining to identify and address old or stale transactions, and search for and correct abnormal balances (negative obligations, etc.)
1/3/2012 1/27/2012 1/3/2012 1/27/2012
1.4.3 For each fin. Stmt. Assertion, identify and document specific supporting documentation from FIAR Guidance Key Supporting Documentation needed to adequately support individual transactions or balances (e.g., vendor invoice supports valuation of a disbursem 12/30/2011 2/3/2012 12/30/2011
1.4.4 Determine how many years of data/documentation are needed to support assertion 12/19/2011 12/19/2011
NA
NA
1.4.5 Select a sample from the population and test to confirm the existence and quality of supporting documentation for all relevant financial statement assertions for the population. As part of the supporting documentation validation, assess the location/sour 12/5/2011 1/11/2012 12/5/2011 1/11/2012
1.4.6 Summarize results of testing and deficiencies in documentation using the Evaluation of Test Results template 1/27/2012 2/3/2012 1/27/2012
1.5 Define Audit-Ready Environment 8/1/2011 1/31/2012 8/1/2011
1.5.1 Define requirements for control activities, documentation, processes, and/or systems needed to address all deficiencies noted in steps 1.3.3, 1.3.6, 1.4.2 and 1.4.6 8/1/2011 1/31/2012 8/1/2011
1.6 DealBreakers 12/19/2011 1/27/2012 1/3/2012
1.6.1 Does the FIP have a milestone included that reflects the reconciliation of financial statement to general ledger to transaction detail?
1/3/2012 1/27/2012 1/3/2012
1.6.2 Does the FIP indicate that substantive sample tests to source documents will cover all material transaction types, sub-processes, and locations?
1/17/2012 1/27/2012 1/17/2012
1.6.3 Does the FIP demonstrate that substantive testing procedures on supporting documentation is extensive enough to draw conclusions consistent with the effectiveness of controls?
1/17/2012 1/27/2012 1/17/2012
1.6.4 Does the FIP conclude whether sufficient substantive testing can be performed to overcome ineffective or missing ITGC and Application controls when transaction evidence is electronic and only maintained within a system, or the key supporting evidence are 12/19/2011 12/19/2011
NA
1.6.5 Does the FIP include steps to evaluate the supporting documents for all material journal vouchers related to the assessable unit?
12/19/2011 12/19/2011
NA
1.6.6 Are there steps within the FIP to ensure all financial statement assertions and relevant risks are addressed either through control or substantive testing?
12/19/2011 12/19/2011
NA
1.6.7 Does the FIP have a step related to the consideration of timely delivery upon audit request of Key Supporting Documentation (e.g. reconciliations, transaction populations controls documentation)? This could be achieved through a SOP or Document Retention 12/19/2011 12/19/2011
NA
1.6.8 Does the FIP indicate effective controls are required for audit readiness for areas of high transaction volume (e.g. supply, contracts, FBWT, Inventory, OM&S, GE, etc.)?
12/19/2011 12/19/2011
NA
Key Control Objectives and Capabilities 3/31/2010 3/30/2012 3/31/2010 3/30/2012
2.1 Ensure Operating Materials and Supplies (OM&S) balances and related footnote disclosures contain all information needed for fair presentation in accordance with GAAP. (FAM 395B: 15, 16, and 17) 3/31/2010 3/30/2012 3/31/2010
Unassessed Presentation and Disclosure
2.1.1 Ability to classify OM&S assets as Held for Use; Held for Repair; and Excess, Obsolete and Unserviceable, as required by GAAP for Note 9.
3/31/2010 3/30/2012 3/31/2010
Presentation and Disclosure
2.2000000000000002 Ensure recorded OM&S transactions represent economic events that actually occurred and are properly classified and recorded in the proper period. (FAM 395B:1c, and 2) 3/31/2010 3/30/2012 3/31/2010
Existence or Occurrence
2.2.1 Ability to record dispositions of OM&S assets in logistics systems and General Ledgers to include dispositions such as sales.
3/31/2010 3/30/2012 3/31/2010
2.2.2 Ability to recognize when title passes or when OM&S assets are produced or delivered to the purchasing entity. (SFFAS 3, par. 19 and par. 38) 3/31/2010 3/30/2012 3/31/2010
Rights and Obligations Completeness
2.2999999999999998 Ensure recorded OM&S exists at a given date. (FAM 395B: 4a) 3/31/2010 3/30/2012 3/31/2010
2.3.1 Ability to perform physical inventories in accordance with GAGAS and a formal Physical Inventory Strategy and Plan from General Ledger to individually identified physical assets.
3/31/2010 3/30/2012 3/31/2010
2.4 Ensure recorded OM&S at a given date, are supported by appropriate detailed records that are accurately summarized and reconciled to the account balance. (FAM 395B: 4b) 3/31/2010 3/30/2012 3/31/2010
Valuation or Allocation
2.4.1 Ability to support baseline/opening balances with acceptable documents or alternative methods when supporting documents are not available.
3/31/2010 3/30/2012 3/31/2010
Valuation or Allocation
2.5 Ensure recorded OM&S are owned by the entity. The entity has rights to the recorded asset at a given date. (FAM 395B: 12) 3/31/2010 3/30/2012 3/31/2010
2.5.1 Ability to identify and distinguish separately OM&S assets held by one entity but owned by another.
3/31/2010 3/30/2012 3/31/2010
2.6 Ensure all existing OM&S, as of the reporting date, including property in the custody of third parties, are included in the general ledger. (FAM 395B: 8) 3/31/2010 3/30/2012 3/31/2010
Completeness Valuation or Allocation
2.6.1 Ability to capture the existence and value of OM&S assets held by third parties, such as GFM in the possession of contractors.
3/31/2010 3/30/2012 3/31/2010
Valuation or Allocation
2.6.2 Ability to perform physical inventory in accordance with GAGAS and a formal Physical Inventory Strategy and Plan from individually identified physical assets to general ledger (Floor to Record).
3/31/2010 3/30/2012 3/31/2010
2.7 Ensure all OM&S are recorded at full cost in the general ledger. (FAM 395B: 9 and 10) 12/19/2011 12/19/2011
NA
Valuation or Allocation
2.7.1 Ability to value OM&S assets at moving average cost (DoD FMR, Volume 1, Chapter 4), or when required by the DoD FMR, at historical cost, latest acquisition cost, or net realizable value. (SFFAS 3, par. 20 & 26) 12/19/2011 12/19/2011
NA
2.7.2 Ability to capture the full cost of OM&S assets valued at historical cost to include all other costs, such as transportation and production costs, incurred to bring the items into its current condition and location. (SFFAS 3, par. 21) 12/19/2011 12/19/2011
NA
2.7.3 Ability to charge to operations for the period any abnormal costs, such as excessive handling or rework costs. (SFFAS 3, par. 21) 12/19/2011 12/19/2011
NA
2.7.4 Ability of logistics systems to value OM&S assets using Moving Average Cost (MAC) or other acceptable method such as FIFO. (DoD FMR Volume 1, Chapter 4) 12/19/2011 12/19/2011
NA
2.8 Ensure transferred, excess, unusable, or idle OM&S are timely and properly recorded. (FAM 395B: 2, 9, 10) 12/19/2011 12/19/2011
NA
Existence or Occurrence
2.8.1 Ability to capture the existence and value of OM&S assets in-transit between organizations and/or systems.
12/19/2011 12/19/2011
NA
Existence or Occurrence
2.8.2 Ability to value excess, obsolete, and unserviceable OM&S assets at their estimated net realizable value (NRV), and to recognize as a gain or loss the difference between MAC and NRV. (SFFAS 3, par. 30 and 48) 12/19/2011 12/19/2011
NA
Corrective Actions 1/1/1997 3/30/2012 1/1/1997
98%
3.1 Design Audit-Ready Environment 12/1/2011 2/22/2012 12/1/2011 2/22/2012
3.1.1 Design solution to mitigate deficiencies for control activities, processes and/or systems that meet the objectives defined using process flows and narratives, CONOPS, systems requirements, and policies and procedures 12/1/2011 1/13/2012 12/1/2011 1/13/2012
3.1.2 Design solution to mitigate deficiencies in supporting documentation that meet the objectives defined 1/31/2012 2/22/2012 1/31/2012 2/22/2012
3.2 Develop Corrective Action Plan 1/20/2012 3/30/2012 1/20/2012
3.2.1 Develop implementation plan to execute designed "to-be" solution, including updating policies and procedures, preparing system design documents, and drafting documentation templates 3/29/2012 3/30/2012 3/30/2012
3.2.2 Update Financial Improvement Plan with Specific Corrective Actions 1/20/2012 1/27/2012 1/20/2012
3.3 Resourcing 3/29/2012 3/30/2012 3/30/2012
3.3.1 Develop budget estimates of required resources to execute implementation plans, including FTEs and funds for contractor assistance 3/29/2012 3/30/2012 3/30/2012
3.3.2 Prepare budget justification materials and Program Budget Decision (PBD) documents 3/29/2012 3/30/2012 3/30/2012
3.4 Execute 1/1/1997 3/30/2012 1/1/1997
99%
3.4.1 Categorize operating materials and supplies (Military Equipment) (1) held for use, (2) excess, obsolete and unserviceable or (3) held for repair (SFFAS # 3, par. 37) - IMDB 9/30/2003 9/29/2004 9/30/2003 9/29/2004 100%
3.4.10 Create and validate report data format to put data into required format 3/1/2004 9/15/2004 3/1/2004 9/15/2004
3.4.11 Generate financial transactional data and forward to the accounting system - OM&S - IMDB 9/30/2003 9/28/2004 9/30/2003 9/28/2004
3.4.12 Interface MRISF/IMDB with DFAS-DE accounting systems 10/1/2003 8/30/2004 10/1/2003 8/30/2004
3.4.13 Reconcile subsidiary data to accounting system - OM&S - Military Equipment Items- -IMDB 6/30/2004 9/28/2004 6/30/2004 9/28/2004
3.4.14 Ensure Missile Readiness Integrated Support Facility/Integrated Missile Database (MRISF/IMDB) is CFO compliant 1/1/2003 9/29/2008 1/1/2003 9/29/2008
3.4.15 DCEM: Test internal controls to ensure that corrective actions have been effectively implemented.
8/31/2010 9/1/2010 9/1/2010 9/1/2010
Yes
3.4.16 DCEM: Complete assertion package for uninstalled missile motors, as reported by the Integrated Missile Data Base (IMDB) 3/31/2010 3/30/2012 3/31/2010
80%
3.4.2 Establish condition codes in IMDB 1/1/1997 4/28/2004 1/1/1997 4/28/2004
3.4.3 Recognize and report operating materials and supplies (Military Equipment) as assets when produced or purchased (SFFAS # 3, par. 38) - IMDB 9/30/2003 9/29/2004 9/30/2003
3.4.4 Apply the consumption method of accounting for the recognition of expenses for operating materials and supplies (Military Equipment) (Audit Opinion 2002) - IMDB 3/1/2004 6/29/2006 3/1/2004 6/29/2006
3.4.5 Identify all financial events that can affect the baseline balance - OM&S - Military Equipment Items - IMDB 9/30/2003 9/29/2004 9/30/2003
3.4.6 Determine the cost flow assumption method (MAC applies) used to determine historical cost of ending OM&S (Military Equipment) and cost of goods consumed (SFFAS # 3, par. 44). - IMDB 9/29/2003 9/30/2003 9/30/2003 9/30/2003
3.4.7 DCEM: Baseline values were established for un-installed Intercontinental Ballistic Missile (ICBM) missile motors tracked in the accountability system Integrated Missile Data Base (IMDB).
9/1/2004 9/29/2004 9/1/2004
3.4.8 Determine Requirements to establish automated application to feed ICBM motor data into GAF- Rehost 1/1/1997 4/28/2004 1/1/1997 4/28/2004
3.4.9 Develop IMDB development module to facilitate the inventory of ICBM Missile Motors to be auto-fed into the GAFS-Rehost System 1/1/1997 10/28/2004 1/1/1997 10/28/2004
Evaluation 12/5/2011 3/30/2012 12/5/2011
4.0999999999999996 Testing 12/5/2011 1/31/2012 12/5/2011
4.1.1 Once corrective actions have been fully implemented, perform update testing to confirm corrective actions (processes, controls, documentation or systems) have successfully mitigated the deficiencies previously identified.
12/5/2011 1/31/2012 12/5/2011
4.1.2 Update testing results for control activities using the Controls Assessment (from step 1.3.3) and testing results for documentation using the Evaluation of Test Results template (from step 1.4.6) 12/5/2011 1/31/2012 12/5/2011
4.2 Decision 2/1/2012 3/30/2012 2/1/2012
4.2.1 If Testing indicates corrective actions were successful, proceed to Assertion Phase 2/1/2012 3/30/2012 2/1/2012
4.2.2 If update testing indicates material deficiencies are not fully addressed, return to step 1.5.1 under Evaluation and Discovery to redefine objectives of "to-be" solution and then initiate corrective action 2/1/2012 3/30/2012 2/1/2012
Assertion 3/29/2012 3/30/2012 3/30/2012
5.0999999999999996 Compile process, control, and system documentation 3/29/2012 3/30/2012 3/30/2012
5.1.1 Compile final, "audit-ready" process documentation that reflects the current, integrated process environment, including process narratives, flow charts, and control assessment forms 3/29/2012 3/30/2012 3/30/2012
5.2 Compile supporting documentation 3/29/2012 3/30/2012 3/30/2012
5.2.1 Compile Evaluations of Test Results, demonstrating sufficient and appropriate supporting documentation exists to assert audit readiness 3/29/2012 3/30/2012 3/30/2012
Sustainment 10/1/2012 9/29/2017 10/1/2012 9/29/2017
6.1
FY13
10/1/2012 9/30/2013 10/1/2012 9/30/2013
6.1.1 Ongoing Testing as part of ICOFR activities 10/1/2012 9/30/2013 10/1/2012
6.1.1.1 Prepare process flows, narratives, control worksheets, test plans, control assessments, with test results, and statement of assurance 10/1/2012 9/30/2013 10/1/2012
6.1.2 Ongoing Remediation for deficiencies noted during ICOFR activities 10/1/2012 9/30/2013 10/1/2012
6.1.3 Ongoing Implementation of corrective action in response to deficiencies noted during ICOFR activities 10/1/2012 9/30/2013 10/1/2012
6.1.3.1 Update Financial Improvement Plan in FIAR tool 10/1/2012 9/30/2013 10/1/2012
6.2
FY14
10/1/2013 9/30/2014 10/1/2013 9/30/2014
6.2.1 Ongoing Testing as part of ICOFR activities 10/1/2013 9/30/2014 10/1/2013
6.2.1.1 Prepare process flows, narratives, control worksheets, test plans, control assessments, with test results, and statement of assurance 10/1/2013 9/30/2014 10/1/2013
6.2.2 Ongoing Remediation for deficiencies noted during ICOFR activities 10/1/2013 9/30/2014 10/1/2013
6.2.3 Ongoing Implementation of corrective action in response to deficiencies noted during ICOFR activities 10/1/2013 9/30/2014 10/1/2013
6.2.3.1 Update Financial Improvement Plan in FIAR tool 10/1/2013 9/30/2014 10/1/2013
6.3
FY15
10/1/2014 9/30/2015 10/1/2014 9/30/2015
6.3.1 Ongoing Testing as part of ICOFR activities 10/1/2014 9/30/2015 10/1/2014
6.3.1.1 Prepare process flows, narratives, control worksheets, test plans, control assessments, with test results, and statement of assurance 10/1/2014 9/30/2015 10/1/2014
6.3.2 Ongoing Remediation for deficiencies noted during ICOFR activities 10/1/2014 9/30/2015 10/1/2014
6.3.3 Ongoing Implementation of corrective action in response to deficiencies noted during ICOFR activities 10/1/2014 9/30/2015 10/1/2014
6.3.3.1 Update Financial Improvement Plan in FIAR tool 10/1/2014 9/30/2015 10/1/2014
6.4
FY16
10/1/2015 9/30/2016 10/1/2015 9/30/2016
6.4.1 Ongoing Testing as part of ICOFR activities 10/1/2015 9/30/2016 10/1/2015
6.4.1.1 Prepare process flows, narratives, control worksheets, test plans, control assessments, with test results, and statement of assurance 10/1/2015 9/30/2016 10/1/2015
6.4.2 Ongoing Remediation for deficiencies noted during ICOFR activities 10/1/2015 9/30/2016 10/1/2015
6.4.3 Ongoing Implementation of corrective action in response to deficiencies noted during ICOFR activities 10/1/2015 9/30/2016 10/1/2015
6.4.3.1 Update Financial Improvement Plan in FIAR tool 10/1/2015 9/30/2016 10/1/2015
6.5
FY17
10/3/2016 9/29/2017 10/3/2016
6.5.1 Ongoing Testing as part of ICOFR activities 10/3/2016 9/29/2017 10/3/2016
6.5.1.1 Prepare process flows, narratives, control worksheets, test plans, control assessments, with test results, and statement of assurance 10/3/2016 9/29/2017 10/3/2016
6.5.2 Ongoing Remediation for deficiencies noted during ICOFR activities 10/3/2016 9/29/2017 10/3/2016
6.5.3 Ongoing Implementation of corrective action in response to deficiencies noted during ICOFR activities 10/3/2016 9/29/2017 10/3/2016
6.5.3.1 Update Financial Improvement Plan in FIAR tool 10/3/2016 9/29/2017 10/3/2016
Validation 4/2/2012 6/29/2012 4/2/2012 6/29/2012
7.1 Assertion Documentation Review 4/2/2012 6/29/2012 4/2/2012
7.1.1 A review of assertion documentation to ensure that all required documents have been completed; all required management testing has been performed, and management testing results indicate audit readiness 4/2/2012 6/29/2012 4/2/2012
7.2 Assertion Examination 4/2/2012 6/29/2012 4/2/2012
7.3 For Appropriations Received and Balance Sheet Assessable Units: DoD OIG (with IPA assistance, if necessary) perform examination of management's audit readiness assertion. This includes examination of latest fiscal year end balances in accordance with AIC 4/2/2012 6/29/2012 4/2/2012
Audit 7/2/2012 6/28/2013 7/2/2012 6/28/2013
8.1 Engage Auditor 7/2/2012 6/28/2013 7/2/2012
8.1.1 Issue RFP and award contract to IPA (via the DoD OIG) to assist with/perform the annual financial statement audit 7/2/2012 6/28/2013 7/2/2012
8.1999999999999993 Support Audit 7/2/2012 6/28/2013 7/2/2012
8.2.1 Perform audit coordination activities, participating in meetings to provide background information 7/2/2012 6/28/2013 7/2/2012
8.2.2 Collect and provide documentation for all auditor requests within established time requirements 7/2/2012 6/28/2013 7/2/2012
8.2.3 Managing issues and respond to findings, working through issues and concerns raised by the auditor that could impede the audit's progress and developing responses to audit findings (including planned corrective actions) 7/2/2012 6/28/2013 7/2/2012
8.3000000000000007 Auditor Issues Audit Opinion 7/2/2012 6/28/2013 7/2/2012 image3.emf
SPAREE~1.XML
2012-03-19T14:15:24Z 2012-03-19T13:45:26Z 12.00
Project Details: Spare Engines
ID
WBS
Task Name Start Finish Baseline Start Baseline Finish % Complete Task Predecessors KCO Weakness Control Objective Test Status Primary FS Assertions Secondary FS Assertions FIAR Milestone A-123, Appendix A Other Milestone Type Responsible Person
FIE
Process L0 Process L1 Lead Org Support Org Resource Names LoE to Complete LoE Committed Task Notes Text 17 Text 18 Text 19 Text 20 Text 21 Text 22 Text 23 Text 24 Text 25 Financial Improvement Deliverable Financial Improvement Phase FR Review Item Work Product Milestone Execution View
Evaluation & Discovery 6/1/2011 4/27/2012
NA
99%
1.1000000000000001 Statement to Process Analysis 10/3/2011 10/11/2011
NA
1.1.1 Initial Process and System Drill Down Analysis (Assertion Work Product 1.1.1) 10/3/2011 10/10/2011
NA
1.1.1.1 Using the Financial Statement, prepare a process and systems drill down detailing accounts/transaction classes, underlying processes and associated systems--depicting "as-is" and "audit-ready" integrated environments 10/3/2011 10/10/2011
NA
1.1.2 Quantitative Drill Down Level 1 (Assertion Work Product 1.1.2a) 10/4/2011 10/11/2011
NA
1.1.2.1 Using the mapping in step 1.1.1, compile quantitative drill down - levels 1 and 2 by transaction class by business process and supporting systems and feeder systems, including dollar activity and number of transactions for each assessable and sub-assessab 10/4/2011 10/11/2011
NA
1.1.3 Quantitative Drill Down Level 2 (Assertion Work Product 1.1.2a) 10/4/2011 10/11/2011
NA
1.1.3.1 Using the mapping in step 1.1.1, compile quantitative drill down - levels 1 and 2 by transaction class by business process and supporting systems and feeder systems, including dollar activity and number of transactions for each assessable and sub-assessab 10/4/2011 10/11/2011
NA
1.2 Prioritization 10/10/2011 10/27/2011
NA
1.2.1 Sub-Assessable Unit Prioritization Document (Assertion Work Product 1.2.4) 10/10/2011 10/27/2011
NA
1.2.1.1 For each assessable unit listed in the matrix prepared in step 1.1, rank in order of quantitative materiality (largest dollar activity is highest priority) 10/10/2011 10/24/2011
NA
1.2.1.2 Identify and document a comprehensive list of significant qualitative risk associated with the assessable units
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