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Audit of Complex Estimates As Verification of Management Number, How Institutional Pressures Shape Practice
Audit of Complex Estimates As Verification of Management Number, How Institutional Pressures Shape Practice
1. Introduction
Accounting estimates are items included in financial statements for which “the measure-
ment of some amounts or the valuation of some accounts is uncertain” (Public Com-
pany Accounting Oversight Board [PCAOB] 2003a, ¶1).1 Complex estimates—those
involving multiple assumptions and/or computationally difficult models—are increasingly
important to the financial statements. For example, U.S. and international standards
require estimation of postretirement benefits and annual computations of goodwill
impairments, and they allow use of model-based fair values. Meanwhile, economic pres-
sures have further increased the importance of valuation allowances and impairments
while simultaneously increasing the difficulty of assessing fair values. The uncertainty
inherent in estimates allows room for management bias (Lundholm 1999), and as esti-
mates become less reliable they become less useful to capital market participants (e.g.,
Richardson, Sloan, Soliman, and Tuna 2005; Lev, Li, and Sougiannis 2010). Collec-
tively these factors create an “urgent need to enhance the reliability of accounting esti-
mates” (Lev et al. 2010, 805).
Auditors are the arbiters of the reliability of financial reports. The increasing impor-
tance of complex estimates and the opportunity for management bias that estimates pro-
vide jointly imply that audit quality in this area is critical to the reliability of financial
reports. However, accounting estimates are, by their nature, difficult to audit, requiring
subjective forecasts of future events rather than a tally of past events. The auditor’s task is
to accumulate sufficient appropriate evidence regarding management’s assertions (PCAOB
* Accepted by Yves Gendron. Prior versions of this paper were titled “Auditing complex estimates: Under-
standing the process used and problems encountered.” We are grateful to John Fogarty for helpful discus-
sions about this project. We also thank Yves Gendron, two anonymous reviewers, Wendy Bailey, Michael
Bamber, Jean Bedard, Andy Call, Jeff Cohen, Jon Grenier, Stacie Laplante, Roger Martin, Dan Stone, Ar-
nie Wright, Hal Zeidman, and workshop and conference participants at Notre Dame, Kentucky, Arizona
State, South Florida, Florida State, Georgia, the Northeast Behavioral Accounting Research Seminar, the
2011 International Symposium on Audit Research, the 2011 ABO Section Research Conference, and the
2012 Auditing Section Mid-Year Meeting for comments on prior drafts of this paper. Additionally, we
thank the auditors who have given their time assisting with the interviews, their firms, and Sydney Traub
for her able research assistance. Jackie Hammersley is grateful for the support provided by a Terry Sanford
Research Award.
1. See PCAOB Interim Standards AU 342, entitled “Auditing accounting estimates,” which incorporates State-
ment on Auditing Standards (SAS) No. 57 (American Institute of Certified Public Accountants [AICPA]
1988). The PCAOB adopted the existing standard on auditing estimates (i.e., AICPA 1988) as part of its
Interim Standards in 2003 and made minor modifications in 2007 and 2010 to properly reference PCAOB
Auditing Standards adopted subsequent to 2003. However, PCAOB Interim Standards AU 342 on auditing
estimates remains in effect substantively as it was originally written in 1988.
Contemporary Accounting Research Vol. XX No. XX (XX XX) pp. 1–31 © CAAA
doi:10.1111/1911-3846.12104
2 Contemporary Accounting Research
2010d, ¶3; International Federation of Accountants [IFAC] 2008a, ¶6).2 For accounts
based on historical cost this means auditors verify the accuracy of those historical num-
bers; however, for estimates, the auditor’s task is to evaluate the reasonableness of the esti-
mate (see PCAOB 2003a, ¶7.b; PCAOB 2010d, ¶13; IFAC 2008b, ¶6.a).
Auditors have well-established procedures for verifying the accuracy of transactions
and balances valued at historical cost, but these procedures are of little use in evaluating
estimates, which include “subjective as well as objective factors” (PCAOB 2003a, ¶4; see
also IFAC 2008b, ¶18). For example, assumptions used to develop estimates (such as man-
agement’s future plans for a division, sales forecasts, etc.) cannot be verified in the same
manner as objective factors. In addition, the complex finance-based modeling underlying
some estimates may be beyond an auditor’s expertise (Power 2010). Thus, the complexity
of many estimates and their judgment-based nature creates difficulties for auditors who
attest to their reasonableness (Copeland 2005), and these difficulties cause problems for
auditor judgment that have captured regulators’ attention (e.g., PCAOB 2010e).
This paper has three goals that together will contribute to a better understanding of
key decisions auditors make and the persistent problems that auditors have with respect
to estimates. The first goal is to understand the process of auditing complex estimates and
the problems that auditors encounter along the way. The differences identified above in
task goals and structure between auditing estimates and auditing other accounts presum-
ably influence how the task is performed, yet the literature has not examined how esti-
mates are audited in a systematic way. In addition, standards allow a variety of
approaches. We contribute to the literature by providing an understanding of how audi-
tors make key judgments and decisions in this area. Our second goal is to interpret the
process used to audit estimates using institutional theory. Further, given that there are
problems with these processes and that auditors are aware of the problems, we examine
whether theory suggests impediments to change in this process. The third goal is to iden-
tify root causes of the decision problems that auditors face in auditing estimates. Our
description and theory-based analysis provide insight into how current practices in audit-
ing estimates arose and inform researchers’ efforts to improve audit quality in this impor-
tant task.
Considerable research investigates auditor judgments about estimates, including fair
values (see Bratten, Gaynor, McDaniel, Montague, and Sierra 2013 for a recent review).
Much of that research focuses on judgment outcomes. While prior studies are informative
about conditions under which auditors allow management bias to survive the audit (Hack-
enbrack and Nelson 1996; Johnstone, Sutton, and Warfield 2001; Kadous, Kennedy, and
Peecher 2003), they do not provide a cohesive framework for understanding the process of
auditing estimates or which steps in the process are most vulnerable to the effects of man-
agement incentives.3 Our look into the backstage of the audit process will allow research-
ers to better understand this process and to move beyond merely acknowledging that
auditors are susceptible to management influence (Power 2003). The insights from our
analysis allow readers to understand how and where in the process the influence is applied,
why that influence is likely to be successful, what institutional features allow the influence
to thrive, and how it might be mitigated. These insights can inform future research aimed
2. The financial statement assertions include existence or occurrence, completeness, valuation or allocation,
rights and obligations, and presentation and disclosure (PCAOB 2007, ¶28).
3. For example, Hackenbrack and Nelson (1996) show that auditors permit more aggressive reporting when
engagement risk is lower. Johnstone et al. (2001) hypothesize that direct incentives (i.e., financial, employ-
ment, contingent fees) and indirect incentives (i.e., interpersonal relationships, auditing the firms’ work) can
impair auditor independence, especially in tasks requiring significant auditor judgment. Kadous et al. (2003)
show that auditors who are more committed to a goal of supporting the client evaluate the client’s aggres-
sive accounting method as more appropriate.
at improving audit quality in this critical area. This paper answers Martin, Rich, and
Wilks’s (2006) call for more research on the audit steps and procedures used to audit fair
values and other estimates, as well as Nelson and Tan’s (2005, 47) call for researchers “to
shed insights on the tasks that auditors perform and on emerging audit practices” to bet-
ter address problems in specific areas such as auditing estimates.
We interviewed 24 very experienced U.S. auditors who regularly deal with complex
estimates. The interviews allow us to understand how the task is actually performed in
practice (Hirst and Koonce 1996). Interviews also provide us with auditors’ unique
insights into the problems that they experience and the underlying causes of these prob-
lems. We use auditing standards as a framework for our description of the process fol-
lowed by our interviewees when auditing complex estimates, and we analyze the content
of the interviews and recent PCAOB inspection reports to understand the most critical dif-
ficulties in auditing estimates. We then apply institutional theory to provide insight into
the underlying causes of these difficulties and impediments to changes that could resolve
the difficulties.
Auditing standards allow a variety of approaches to evaluating the reasonableness of
an estimate. Our main finding with respect to the process is that auditors overwhelmingly
reported testing management’s process for generating complex estimates rather than using
an approach that relies less on management’s assertions (i.e., developing independent
expectations or reviewing subsequent events data). Additionally, auditors reported per-
forming few of the recommended steps to audit management’s process, and, in particular,
none described considering whether additional factors beyond the assumptions made by
management should be included in the management’s model. Auditors’ language in
describing these steps focused on confirmation or verification of elements of the manage-
ment’s model. These issues raise concerns that management may be able to lead auditors
“down the garden path” because auditors do not tend to generate independent estimates
or consider what management has neglected to include in its estimation model. Instead
they appear to accept management’s model as a starting point and verify aspects of that
model. That is, auditors appear to be trying to fit the task of auditing estimates into the
verification model that applies to accounts that are based on historical cost.
Consistent with this observation, the problems that our auditor interviewees identify
indicate an overreliance on management assertions, and such overreliance is corroborated
by our analysis of PCAOB inspection reports. That is, auditors sometimes fail to ade-
quately test assumptions and data underlying the estimation model, fail to consider con-
trols over management’s process and the data, and fail to fully understand the model.
Auditors and the PCAOB both also indicated a failure to notice and reconcile conflicting
evidence (e.g., external evidence about default rates that contradicts management’s
assumptions). Finally, auditors noted significant problems in coordination with and over-
reliance on the work of audit-firm specialists.
We view these problems as arising from two root causes, both of which are consistent
with the legitimation propositions of institutional theory. First, audit firm policies and
professional standards emphasize verifying aspects of management’s model rather than
critically evaluating the reasonableness of the estimate. Second, audit firms’ chosen divi-
sion of knowledge among auditors and valuation specialists results in auditors having
insufficient knowledge of valuation to engage in the necessary critical analysis of manage-
ment or specialist models. We conclude that auditors, informed by the findings in the
PCAOB inspection reports, are aware of these problems, suggesting that this area is ripe
for change; however, the area lacks direction for how to change. Because the root causes
of the problems are inherent in the method auditors use, it is likely that the institutional
change necessary to improve the audit of complex estimates will not occur unless compel-
ling evidence supports a new method and that method is supported by standard setters.
Institutional theory further suggests that firms apply the verification frame to audits
of estimates, even though it is not optimal for this task, because it has been legitimated in
other audit tasks. Framing the task of auditing estimates as one of verification rather than
evaluation results in auditors overlooking evidence that conflicts with management’s model
or is outside of that model. Insufficient valuation knowledge is problematic in that rela-
tively inexperienced auditors, who also likely lack knowledge of how their work fits into
the bigger picture, perform many audit steps, even difficult ones such as preparation of
independent estimates. Moreover, auditors typically enlist audit-firm specialists in auditing
estimates because they do not have valuation expertise, but they may overrely on special-
ists because of coordination issues and lack of a common vocabulary. Overall, these insti-
tutionalized conventions suggest that the problems we identified with audits of estimates
will persist until a superior approach is identified and supported by firms and regulators.
In the next section of the paper, we describe institutional theory, which we use to
interpret our interview and PCAOB inspection report data. Section 3 describes our inter-
view methodology. Sections 4 and 5 describe how estimates are audited and the problems
that occur during the audit of estimates, respectively. Section 6 analyzes the evidence from
the interviews and PCAOB inspection reports through the lens of institutional theory. Sec-
tion 7 provides conclusions and their implications for research.
the organization adopts elsewhere. This occurs because novel practices are at risk of being
viewed less favorably because they diverge from already institutionalized (and thus,
accepted) practices (Zucker 1987).
Second, the practices developed by different organizations within an environment tend
to converge to the extent that the organizations adopt increasingly similar practices in
their pursuit of legitimacy through processes known as mimetic, coercive, and normative
isomorphism (DiMaggio and Powell 1983). Mimetic isomorphism occurs in response to
uncertainty about the right course of action and results in organizations modeling their
actions or processes on those of other similar organizations (Mizruchi and Fein 1999).
Coercive isomorphism occurs because of formal and informal pressure from another orga-
nization, such as a government agency or regulator, to act in a certain manner. Normative
isomorphism occurs when the training and interaction that is common across members of
an industry or profession result in commonly used practices (DiMaggio and Powell 1983).
However, as both DiMaggio and Powell (1983) and Mizruchi and Fein (1999) note, it is
often impossible to distinguish among the three types of isomorphism. As convergence
within and across organizations continues, the legitimated practices become more
entrenched in organizational and societal perceptions of appropriate or best practices.
While much of the institutional theory literature focuses on how organizations converge
on common institutionalized practices, this theory also describes how and why organizations
change (or do not change) established practices (Greenwood et al. 2002). Practices change
when their legitimacy is seriously called into question as a result of functional, political or
social pressures (Oliver 1992). That is, change occurs in response to events or “jolts” that
destabilize the acceptability of current practices (Greenwood et al. 2002). Jolts prompt the
introduction of new ideas and the consideration of the need to change, which leads organiza-
tions to innovate, seeking solutions to identified problems (Greenwood and Suddaby 2006).
The process of moving from idea generation to acceptance of new practices is not well under-
stood; however, researchers believe that the new practices must be “theorized” (Strang and
Meyer 1993). Theorization requires specification of a problem that can be fixed with a
change in procedure and justification of the change (Tolbert and Zucker 1999). The change
becomes accepted as social consensus about its value develops (Suchman 1995) and it
becomes fully institutionalized when widespread adoption of the method occurs.
Greenwood and Suddaby (2006) note that a difficulty with institutional theory lies in
explaining how and why people within institutions become motivated to change. They
examine the conditions that affect this change process for consulting units of public
accounting firms. They conclude that since these units bridge organizational fields, they
are more open to change than other units because they come into contact with alternative
examples on a regular basis. We examine auditing practices that are central to the function
of the firm and are subject to regulatory oversight (increasing the need for perceived legiti-
macy) and that do not bridge other fields. Consequently, it is an open question how moti-
vation for change develops within the auditing practices of these firms.
In this paper, we examine two questions that flow from institutional theory. Our primary
concern is whether auditors have adapted the legitimated procedures used to verify historical
account balances to the audit of complex estimates. We also examine whether the PCAOB,
through the use of mimetic and coercive isomorphism, creates pressure for continuity or
change in the procedures used to audit estimates. Addressing these questions will help us to
understand the causes of the persistent problems with audit quality around estimates.
3. Interview method
We use interviews to collect data relevant to the propositions of institutional theory in the
context of auditing estimates. We interviewed 24 partners and senior managers from six
large audit firms during October and November 2010. We chose the interview method
because we are interested in how auditors actually perform audits of estimates, rather than
how standards describe that process. In addition, auditing standards in this area are vague
and allow substantial flexibility in approach. Auditors are in the best position to tell us
what they do to audit estimates and how they apply the vague standards. In addition,
interviews can provide insight into the problems that auditors experience during the pro-
cess of auditing estimates. Understanding this process and the associated problems is a
precondition to identifying underlying causes of the problems and improving auditor per-
formance in this area (Gibbins and Qu 2005). Thus, we asked interviewees to describe the
major steps in the process of auditing complex estimates and the difficulties they com-
monly encounter throughout this process.
We developed a semi-structured interview script with open-ended, neutral questions
because this format is designed for “complete and consistent coverage in each interview of
themes under study [while] minimizing researcher intrusion” (Lillis 1999, 84). We developed
the interview script in consultation with the national director of assurance policies of a Big 4
auditing firm. We initially drafted the script after discussions with this partner, the partner
provided feedback on the content and terminology of the questions, and then we revised the
script considering those suggestions. After completing three interviews, we revised the script
again to ensure that we could capture the data of interest in a straightforward way.
We sought very experienced auditors as interviewees because they are likely to provide
the most useful insights into the process of auditing estimates and the associated problems.
Very experienced auditors have access to the entire process of auditing estimates in their
roles as reviewers and past preparers, while staff members and seniors know the details of
only a few steps in the process. They also have experience with a greater number and vari-
ety of clients, which increases the generalizability of their interview responses (Cohen,
Krishnamoorthy, and Wright 2002). Because of their enhanced perspective and higher lev-
els of experience, we also expect these auditors best understand the problems that arise in
auditing estimates and their underlying causes.
We identified interviewees by asking contacts at each of the large firms that operates
in our region to provide us with contact information for one or two senior managers,
partners, and technical consultation directors for the office or region who would be willing
to talk to us about auditing complex estimates. The firms we contacted are BDO Seidman,
Deloitte, Ernst & Young, Grant Thornton, KPMG, and PricewaterhouseCoopers. Partici-
pating auditors were from offices in five cities, and their audit experience ranged from 8 to
41 years, with an average of 19 years. To provide context about the backgrounds of the
auditors describing the audit process, Table 1 reports demographic information for each
auditor interviewed, including rank, years of experience, responsibility for technical con-
sultation, and any estimate accounts mentioned during the interviews.
All of our interviewees indicated that they regularly dealt with audits of complex esti-
mates and 11 had current national, regional or office level responsibility for consultation
on technical accounting and auditing issues. Thus, our interviewees have significant experi-
ence with diverse accounts containing estimates and with their firms’ methodology for
auditing these accounts. They are therefore able to provide us with meaningful insights
into their processes. Regarding sample size, we followed recommendations for qualitative
research to continue interviewing until redundancy in responses is achieved such that no
new information is collected with additional interviews (Morse 1995, 2000; Lincoln and
Guba 1985).4
4. Our sample size of 24 interviewees from six firms is within the range of sample sizes in other qualitative
interview studies in auditing. These studies used 22–36 interviewees from one to six firms (Cohen et al.
2010; Trompeter and Wright 2010; Gendron and Bedard 2006; Gendron, Bedard, and Gosselin 2004; Cohen
et al. 2002; Hirst and Koonce 1996).
TABLE 1
Interview participant demographics
P1 Partner 24 Yes
P2 Partner 16 No
P3 Partner 13 No
P4 Partner 41 Yes Impairments, revenue
P5 Partner 19 Yes Impairments
P6 Partner 25 Yes Fair value
P7 Partner 21 Yes Impairments, fair value
P8 Partner 19 Yes Impairments
P9 Partner 20 Yes
P10 Partner 35 No Fair value
P11 Partner 34 Yes
P12 Partner 35 Yes
P13 Partner 23 No
Mean: 25.5 Total: 9
M1 Senior Manager 13 No
M2 Senior Manager 11 No
M3 Manager 8 Yes Other unspecified complex estimate
M4 Senior Manager 9 Yes Fair value, derivatives, pensions,
self-insurance
M5 Senior Manager 8 No Impairments
M6 Senior Manager 10 No Fair value, revenue
M7 Manager 14 No Impairments
M8 Senior Manager 10 No Impairments, revenue
M9 Senior Manager 10 No Other unspecified complex estimate
M10 Senior Manager 11 No
M11 Senior Manager 20 No Impairments, fair value
Mean: 11.3 Total: 2
Two authors conducted phone interviews.5 We asked questions in the order they
appear in the script, but we allowed interviewees to elaborate as they wished. We docu-
mented the interviews by taking notes on a copy of the script during the interview, and we
completed our documentation of all responses before concluding each interview.6 In order
to avoid introducing our own structure on responses, during the interviews we asked for
clarification of responses when questions arose. For example, when an interviewee was
providing steps involved in auditing estimates, if it was not perfectly clear whether the
interviewee considered an item to be a new (separate) step or part of the prior step, we
asked the interviewee to clarify. Interviewees were free to refer to any materials they
wished, but we did not ask them to do so. Interviews ranged from 50 to 120 minutes in
length, with an average time of 69 minutes.
5. Given our desire to attain the views of very experienced auditors from several firms and locations, it was
not feasible to conduct face-to-face interviews. To compensate for the lack of face-to-face interaction, the
interviewers opened each call with introductions and a brief conversation about the purpose of the study to
build rapport. We promised the interviewees anonymity to encourage them to be candid.
6. In order to obtain frank responses from interviewees, we opted not to record the interviews. We believed
this was critical, given our focus on problems encountered and U.S. audit firms’ wariness of litigation. We
took various measures (described above) to minimize the risk of losing crucial details.
We began our interviews by asking auditors to think about the process of auditing a
complex estimate such as a fair value or impairment analysis. We asked them to walk us
through the key steps in the process and to describe what level auditor typically performs
the steps and the order in which they usually take place.7 We prompted auditors by asking
whether identifying accounts with significant estimates or impairments was the first step in
the process, and all 21 agreed that it was. For the remaining steps in the process, we asked
interviewees to identify the steps they believe are important when auditing estimates, but
we did not prompt them with any additional steps. We did not prompt them further
because we were interested in learning which steps very experienced auditors believe are
most important and are commonly performed when auditing complex estimates, and in
what order they are performed. Additional prompts could interfere with the auditors’
thought processes or could have communicated to the auditors that we considered certain
steps to be important. We did not ask auditors to focus on a particular audit as we sought
information about how auditors generally audit estimates and the problems they generally
encounter, as opposed to how they perform on cases that are particularly salient (e.g.,
because they are particularly risky or occurred very recently).
An author who did not participate in the interviews and a research assistant indepen-
dently coded the process steps the interviewees described. Following Miles and Huberman’s
(1994) recommended method, the noninterviewing author developed the coding scheme by
creating a “start list” based on the conceptual framework underlying the study prior to delv-
ing into the data and refining the coding scheme. Specifically, the author used the steps in the
process mandated by PCAOB Interim Auditing Standards AU 342 and 328 as a starting
point and added categories as needed based on the content of the interviews. The final coding
scheme includes categories for the 10 steps identified in the auditing standards plus five addi-
tional steps not identified in the standards. Initial interrater agreement on the coding of inter-
view responses about the process was 85.8 percent; the coders met to resolve differences and
the reconciled data are reported here. Cohen’s j, a measure of interrater agreement beyond
that predicted by random chance, was 0.84 (p < 0.01). Our discussion of auditors’ process in
the following section is based on these results.
Next, we asked auditors to think about the steps in which problems frequently arise
when auditing complex estimates.8 The noninterviewing author and research assistant fol-
lowed the same procedures described above to develop the coding scheme, code the inter-
view responses, and resolve differences in coding responses about problems with auditing
estimates. Initial interrater agreement on problems data was 79.7 percent (Cohen’s
j = 0.78, p < 0.01). Our discussion of auditors’ problems in Section 5 is based on the
reconciled data.
4. How are estimates currently audited?
Standards about auditing estimates
We use PCAOB Interim Standards AU 342 and 328 as a framework for describing the
process used to audit accounting estimates (PCAOB 2003a, b).9,10 We rely primarily on
7. We added this topic to the script after conducting three interviews; therefore, only 21 auditors answered
this item.
8. All 24 auditors answered this item.
9. In addition to adopting AU 342 (see footnote 1), the PCAOB also adopted the preexisting standard on
auditing fair values, AU 328 (which incorporates SAS No. 101 [AICPA 2003]), “Auditing fair value mea-
surements and disclosures” as part of its Interim Standards in 2003. Like AU 342, AU 328 remains in
effect substantively as it was originally written in 2003.
10. International Standards on Auditing No. 540, “Auditing accounting estimates, including fair value
accounting estimates and related disclosures,” essentially combines the guidance provided by AU 342 and
AU 328 into one standard, without substantively different requirements (IFAC 2008b).
AU 342, as this standard encompasses all complex estimates, including but not limited to
fair values. Although general standards provide guidance relevant to auditing all accounts
including estimates, we focus on standards specific to estimates because these standards set
forth the procedures that auditors are required to follow when auditing estimates (e.g.,
Goelzer 2010).
When evaluating estimates, AU 342 first requires auditors to identify all material
accounting estimates made by management (PCAOB 2003a, ¶8). Next, auditors must
obtain an understanding of how management developed the estimates (PCAOB 2003a,
¶10). While AU 342 does not elaborate on how to obtain this understanding, AU 328 indi-
cates that for fair value measurements, auditors must understand the method or model as
well as management’s reasons for using it (PCAOB 2003b, ¶18). Based on their understand-
ing of management’s process, auditors then use one or more of three possible approaches
to evaluate the reasonableness of management’s estimates. Auditors may: (i) review and test
management’s process for generating estimates, (ii) develop an independent expectation for
the estimate, and/or (iii) review subsequent events or transactions that are related to the
estimates (PCAOB 2003a, ¶10; PCAOB 2003b, ¶23). While neither standard advocates one
method over any other, we note that AU 328 provides 14 paragraphs of detailed guidance
on reviewing and testing management’s process, one paragraph on developing an indepen-
dent expectation, and two paragraphs on reviewing subsequent events.
If auditors decide to review and test management’s process, AU 342 allows them to
select any combination of the following steps to provide sufficient evidence about the esti-
mate: test controls over preparation of the estimates; test the relevance, reliability and suf-
ficiency of the data used in the model; test the accuracy of the computations made in
using the model; evaluate the appropriateness of the assumptions used; and, finally, con-
sider whether any relevant factors are missing from the model (PCAOB 2003a, ¶11).
Alternatively, AU 342 and 328 both allow auditors to develop an independent expec-
tation for the estimate using their own model and assumptions (PCAOB 2003a, ¶12). For
fair values, AU 328 explicitly requires that the auditor “takes into consideration all signifi-
cant variables” (PCAOB 2003b, ¶40), while AU 342 provides minimal direction about
how to develop an independent expectation (PCAOB 2003a, ¶12). Finally, in addition to
or instead of the other two approaches, auditors may consider whether there are any sub-
sequent events that provide evidence about the reasonableness of estimates (PCAOB
2003a, ¶13; PCAOB 2003b, ¶41). The final step in auditing estimates requires auditors to
consider whether there is a misstatement of the estimate that requires adjustment, given its
materiality relative to the financial statements taken as a whole (PCAOB 2003a, ¶14;
PCAOB 2003b, ¶47).
11. Please see supporting information, “Appendix S1: Details of Auditors’ Process and Problems when Audit-
ing Complex Estimates” as an addition to the online article.
tance to the auditor. Thus, it seems fair to assume that steps that are omitted by most audi-
tors receive less attention during audits of estimates than do other steps.
We find that auditors described a process for auditing estimates that is broadly consis-
tent with auditing standards; however, the specific steps identified and the order of perfor-
mance of steps varies across auditors. All auditors began as prompted by identifying
accounts with significant estimates, which they identify by considering “the client’s busi-
ness and what types of accounts they have” (P3) and by using materiality as a frame for
understanding which accounts are important and determining which of these contain esti-
mates.12
This is generally followed by understanding management’s process or model used to
develop the estimate. The goal of this step is to understand enough about how manage-
ment generated its estimate to determine the audit approach to use. This includes under-
standing what judgments go into the estimate and where the higher risk areas are in the
process. The language auditors used to describe this step (e.g., “figure out,” “dig deep,”
“really understand”) emphasizes both the importance of thoroughly understanding man-
agement’s method and the absence of a standardized approach to obtaining this under-
standing. The latter implies auditors must use their judgment to decide how to approach
this step and whether their understanding is adequate after executing that approach.
Nonetheless, we note that the analytical judgment auditors describe applying in this
step uses management’s model as a starting point. They are working to understand what
management did to generate an estimate, rather than what an ideal approach would be.
This is generally followed by deciding which method to use to audit management’s
estimate. We find that auditors most commonly audit management’s process for generat-
ing the estimate, and they only rarely prepare an independent expectation or use subse-
quent events data to validate an estimate.
Next, auditors perform the various procedures to actually audit the estimate. The
order and inclusion of these steps varies by auditor; however, auditors collectively describe
the process of auditing management’s estimate as involving five major steps: testing con-
trols, testing data, testing management’s calculations, evaluating the assumptions used,
and evaluating the reasonableness of management’s model. Auditors described testing con-
trols and testing data using concrete and straightforward language. This is likely because
auditors commonly perform these steps when auditing accounts other than estimates and
they do not view these steps as having the more abstract goals of other steps unique to
estimates (e.g., understanding the model, evaluating assumptions). Similarly, auditors gave
relatively cursory descriptions of testing management’s calculations that convey a lower
level of judgment necessary to complete this step.
Interviewees each described using multiple methods to evaluate assumptions. The lan-
guage used (i.e., “validate,” “verify,” “look back”) suggests that, while they attempt to
exercise skepticism, they tend to focus on corroborating management’s assumptions rather
than determining an appropriate assumption independently for comparison to manage-
ment’s assumptions. Moreover, their descriptions convey that this process is heavily
dependent on auditors’ judgment to determine not only how much evidence is necessary
but also what type of evidence is appropriate to use in evaluating assumptions. Auditors
also explained that a key consideration when evaluating the reasonableness of manage-
ment’s method or model is whether the model makes sense, given the type of account
being estimated and the client’s industry (i.e., is the model typically used for an account
or industry). Auditors did not report considering whether there are relevant factors or
assumptions missing from the model.
12. We attribute quotes to auditors using the identifiers assigned in Table 1 (e.g., M1 indicates a manager
made the comment, P1 indicates a partner).
TABLE 2
Process performed when auditing estimates as described by interviewees
Number of
interviewees
describing
Steps and substeps described by interviewees (n = 21) Percentage
TABLE 2 (continued)
Number of
interviewees
describing
Steps and substeps described by interviewees (n = 21) Percentage
Number of
interviewees
describing
Steps and substeps described by interviewees (n = 21) Percentage
Figure 1 Model of the process of auditing estimates as described by auditing standards and
interviewees
Description:
Percentage of 21 interviewees who discussed each step is shown in parentheses. Dotted lines indicate
steps described by interviewees that are not included in auditing standards about estimates (i.e.,
AU 342 and AU 328). Note that some interviewees also discussed two steps that are not
depicted above because they are not unique to the process of auditing estimates: documenting
work (23.8 percent) and reviewing workpapers (4.8 percent).
Four of the steps collectively identified by auditors—testing controls, testing data, test-
ing management’s calculations, and evaluating the assumptions used—coincide with those
in standards. The remaining step identified by auditors—evaluating the reasonableness of
management’s model—is not explicitly contemplated by the standards. In addition, none
of the auditors mentioned the fifth step identified in standards—considering whether there
were additional factors or assumptions beyond those already incorporated in the model
that should be taken into account. Finally, on average, auditors reported performing only
1.8 of the 5 steps outlined by the standards in auditing management’s process.13 While
these steps are not all strictly required by standards, our view is that it would be difficult
to collect sufficient evidence about the reasonableness of the estimate without performing
all steps in most cases.
Next, auditors complete the process by determining whether the estimate is reason-
able. If the estimate does not appear reasonable considering the rest of the audit evidence
and the financial statements taken as a whole, they iterate back through the original pro-
cess to collect additional evidence, or, in some cases, they decide that their initial approach
was inappropriate or inefficient and choose a new approach (e.g., preparing an indepen-
dent expectation of the estimate instead of testing management’s estimation process). Once
13. The 21 auditors that were asked to describe the process made 37 mentions of testing controls, testing data,
evaluating assumptions, considering external evidence, and testing calculations. The number of steps
reported by each interviewee (out of these five steps) ranged from 0 to 4, with a mean of 1.8 and a median
of 2.
the evidence is sufficient, auditors conclude whether the estimate contains a material mis-
statement. Auditors’ descriptions of this step reveal that deciding whether an estimate is
materially misstated is not a black and white decision; it involves significant judgment and
iteration with management. This creates an opportunity for management to influence
auditors’ judgments (intentionally or not) at a crucial point in the process of auditing
estimates.
14. Please see supporting information, “Appendix S1: Details of Auditors’ Process and Problems when Audit-
ing Complex Estimates” as an addition to the online article.
TABLE 3
Primary preparers of steps in the process of auditing estimates
Identify accounts/areas
with significant estimates 1.8% 28.1% 31.6% 17.5% 1.8% 19.3%
Understand management’s
method/model 4.2 35.2 31.0 11.3 14.1 4.2
Select audit approach 18.5 25.9 25.9 18.5 11.1 –
Evaluate reasonableness
of management model used – 40.0 40.0 20.0 – –
Test controls over
management’s method and
data used – 50.0 50.0 – – –
Test underlying data used –
in model 37.5 41.7 12.5 4.2 4.2
Test management’s
calculations 25.0 50.0 25.0 – – –
Evaluate appropriateness
of model assumptions 13.6 57.6 20.3 5.1 3.4 –
Formulate independent
expectation 23.1 38.5 7.7 7.7 23.1 –
Review subsequent events 25.0 50.0 25.0 – – –
Evaluate reasonableness
of estimate, considering
audit evidence and financial
statements taken as a whole 9.1 27.3 36.4 27.3 – –
Conclude whether estimate –
is materially misstated 5.6 22.2 44.4 22.2 5.6
Document work 16.7 16.7 33.3 16.7 16.7 –
Review workpapers – – – 100.0 – –
Notes:
* The table reports the primary preparers identified by the 21 interviewees who described the
process of auditing estimates reported in Table 2.
†
The table shows the percentage of total responses indicating each position as primary preparer
because some interviewees indicated more than one primary preparer.
Auditors first encounter problems when identifying accounts containing significant esti-
mates. One manager (M10) described the problem as starting the audit work before “getting
a very good understanding of the whole area in which there is significant risk.” This makes it
difficult to see where the risk resides, resulting in a misallocation of effort or in framing the
problem incorrectly so that the analysis that follows is inappropriate. For example, an audi-
tor could misidentify the reporting level (i.e., unit of analysis) for a goodwill impairment test,
causing him or her to include the wrong accounts in the analysis. These descriptions suggest
that identifying which accounts contain significant estimates is difficult because there is no
standard approach to completing this step and it requires substantial judgment.
Auditors next experience problems understanding management’s method or model.
Specifically, auditors sometimes fail to understand what the model’s key risk drivers are
due to a lack of knowledge about the methods or models used and therefore they misinter-
pret which assumptions are critical.
TABLE 4
Comparison of auditor- and PCAOB-identified problems
Problems Estimates-related
mentioned deficiencies identified
Problem area by auditors Rank by PCAOB Rank
Document work 7 1
Auditor inexperience 6 2
Coordination with specialists 5 3
Client issues 3 4
Total 21
Notes:
* These are problems identified by 24 auditors in the interviews that are comparable to deficiencies
identified in PCAOB inspection reports.
†
These are problems identified by auditors in the interviews that are not comparable to deficiencies
identified in PCAOB inspection reports. PCAOB inspections identify specific failures (see
“Appendix S2: Categories Used to Code Inspection Report Deficiencies” as an addition to the
online article for examples), rather than general problems related to issues such as
documentation (e.g., PCAOB 2012b), auditor inexperience, etc.
In choosing the audit approach, auditors report failing to involve a specialist to pro-
vide input on the method or assumptions contained in the estimate. One manager (M8)
explained that auditors “follow the planned approach even though there is a better
approach out there,” indicating an inflexibility or lack of responsiveness to changing con-
ditions that may impair audit quality.
Auditors also have problems evaluating the reasonableness of management’s model
because they often “audit to the client’s numbers rather than framing the problem inde-
pendently” (M2). Auditors focused solely on “the client’s numbers” may not notice
whether management’s method is inappropriate or has changed from the prior year with-
out reason. This issue is exacerbated by auditors’ lack of knowledge about valuation,
which causes them to rely on specialists without gaining their own understanding of the
model being used. Thus, auditors’ lack of knowledge about valuation and understanding
of valuation models continues to cause problems as auditors move past the preliminary
steps in auditing estimates (e.g., identifying significant estimates and understanding man-
agement’s method) into testing management’s process, likely increasing management’s abil-
ity to influence audit judgments.
Problems related to testing the underlying data used to prepare the estimate include
auditors overlooking the possibility that the data underlying the estimate is incomplete or
inaccurate. A partner (P7) characterized this problem as “taking management’s word with-
out validating sources,” and he attributed this problem to a failure to execute tests of con-
trols rather than a failure to realize testing was necessary, as well as to overreliance on
management.
Auditors described several problems evaluating the assumptions that underlie estimates.
Auditors often lack knowledge or experience with the finance methodology that forms the
basis for discount rates and other elements of models, and this makes it difficult to ask
appropriate follow-up questions to challenge assumptions and causes auditors to rely on
surface level analysis that may not make sense when considered more carefully. A partner
(P4) noted that auditing assumptions requires “directly challenging management’s assump-
tions,” and a manager (M4) observed a reluctance to do so because of the perception that
the “client knows their situation best and therefore has [the] best information about
assumptions.” Collectively, auditors’ descriptions of problems with evaluating assumptions
suggest that auditors’ lack of knowledge or experience with valuation models contributes to
these problems and makes it easy for management to influence their judgments.
Problems with considering whether relevant factors or assumptions are missing from
the estimate include failing to make use of relevant external benchmarks and failing to
evaluate inconsistencies between the estimate or underlying assumptions and implications
of the current economic environment. These failures occur because auditors do not always
understand how industry or economic information affects the company.
Finally, auditors have problems with evaluating whether the estimate is reasonable,
given the evidence collected and the pattern of information in the rest of the financial
statements. Auditors reported having trouble seeing the big picture that surrounds the esti-
mate, which can cause them to fail to realize how negative evidence collected during the
audit impacts the estimate. They indicated that taking a step back to see the big picture at
this stage helps them to avoid these problems, and a partner (P11) pointed out that
because “connecting the dots is difficult” auditors “need smarts” to be able to do this.
Auditors’ descriptions focus mainly on detecting bias in management’s estimates, high-
lighting the importance of auditors having the “smarts” to succeed in this step and avoid
undue management influence.
Our interviewees also reported some general problems with documentation that likely
affect multiple steps in the process of auditing estimates. In addition to concerns about the
sufficiency of audit documentation, auditors also expressed concerns about achieving
proper allocation of time between documenting audit work and other tasks. Their descrip-
tions suggest that auditors perceive a conflict between completing a good audit and com-
pleting good audit documentation.
Interviewees also reported some general problems related to auditor and client exper-
tise. Some problems stem from client issues such as lack of management expertise in gen-
erating estimates, and others relate to auditor inexperience with complex accounts or lack
of knowledge of relevant accounting rules related to auditing estimates. This suggests that
auditor knowledge and expertise are critical for proper performance of many steps of the
process of auditing estimates, from understanding management’s model to understanding
the evidence collected when testing management’s process to ultimately concluding
whether the estimate is materially misstated.
Finally, auditors noted that either relying too heavily on a specialist’s analysis or fail-
ing to involve a specialist can result in auditors failing to obtain an understanding of man-
agement’s method or model. Third-party specialists are sometimes reluctant to disclose
their proprietary models, and this can prevent the auditor from getting an understanding
of models. In general, when specialists are required, coordination issues that limit access
to specialists and dependence on specialists to understand the models prevent auditors
from gaining a sufficient understanding of the models to effectively evaluate the audit
work around estimates.
The problems auditors identified were largely focused on auditing management’s pro-
cess for preparing the estimate. Twenty-one (87.5 percent) of our interviewees (not tabu-
lated) described one or more problems with this approach, while only one auditor (4.2
percent) described a problem with each of the other two approaches (preparing indepen-
dent estimates and using subsequent events data to evaluate estimates). The relative infre-
quency of problems cited with independent estimates and use of subsequent events data
likely reflects the fact that these audit approaches are not used much.
In sum, the interviews indicate that auditors experience problems throughout the pro-
cess of auditing estimates. In addition to problems with auditing management’s process,
auditors noted problems with identifying significant estimates and choosing which audit
approach to take in the early stages of the audit and with evaluating the reasonableness of
the estimate at the end of the process. It is clear that auditors believe that the problems
primarily occur in the steps that require the most judgment to complete: understanding
management’s method or model; evaluating the reasonableness of the model used; evaluat-
ing the appropriateness of the assumptions used in the model; and evaluating the reason-
ableness of the estimate. Auditors seem to struggle in the final stages of auditing estimates
because they must consider two types of information not contained within the estimate or
model itself—external information about economic and industry conditions and informa-
tion about other aspects of the audit that may be inconsistent with the estimate or may
otherwise indicate potential problems with the estimate. It is also notable that auditors
attribute problems in several steps (understanding the model, evaluating whether the
model is reasonable, evaluating assumptions, considering whether relevant factors are
missing, evaluating the reasonableness of the estimate in light of other audit evidence, and
generating independent expectations), either directly or indirectly, to auditors’ lack of rele-
vant knowledge or expertise.
A key insight from the interviews is that the steps in auditing estimates are interre-
lated such that problems at one stage often cascade to affect other steps. As a manager
(M1) explained, “missing the dependencies at the beginning will make everything they do
wrong.” That is, a failure to understand management’s model often implies the auditor
doesn’t understand the significance of a particular assumption or the sensitivity of the esti-
mate to changes in that assumption. This makes evaluating the appropriateness of the
assumption and evaluating the reasonableness of the estimate difficult.
change and/or continuity in audit practice. This coercive pressure has the potential to dis-
rupt the methods used to audit estimates, which could improve practices surrounding these
accounts and reduce the persistence of the identified problems. However, the PCAOB has
yet to issue any standards changing how complex estimates should be audited, so they
have not provided a regulatory jolt that would apply pressure to change institutionalized
practices through standard setting to date.15 Consequently, any pressure from the PCAOB
for changes to audit practice related to estimates currently must come from the inspection
process. Inspections have the potential to provide pressure to change audit practice if the
inspections reveal problems with the audits and the PCAOB identifies remedies to those
problems that are presented as more appropriate than existing practice.
We examine PCAOB inspection reports to evaluate whether they exert pressure for
change or continuity in the audit of complex estimates. The public portion of inspection
reports provides information to firms about how and how well other firms audit esti-
mates. We analyze the public portion of PCAOB inspection reports along three dimen-
sions: the extent to which accounts containing estimates are identified as problematic,
what accounting and auditing issues are associated with these accounts, and in which
steps in the process of auditing estimates deficiencies occur.16 We also analyze the private
portions of the three inspection reports that were released when firms failed to satisfacto-
rily address quality control criticisms within one year of the initial release of the inspec-
tion reports in our sample.17 We examine these reports for additional evidence about
whether the PCAOB exerts pressure for continuity or change in practice through the pri-
vate portions of the inspection reports. It may be that the PCAOB uses the private com-
ments to suggest remedies to problems identified in the public comments. This analysis
provides insight for our theoretical analysis of current audit practices for auditing esti-
mates (Section 6). It also allows us to corroborate interviewees’ descriptions of problems
encountered when auditing estimates and to provide additional insight into those
problems.
The PCAOB takes a risk-based approach when selecting the audits to be inspected
by choosing audits that they believe have higher risk of material misstatement (PCAOB
2008). They further choose the areas of these audits they view as likely to pose the
biggest accounting, auditing, or compliance challenges (Olson 2008). Thus, while inspec-
tion reports are not representative of all deficiencies that might exist on audit engage-
15. In 2012, the PCAOB added “Accounting estimates including fair value measurements and related disclo-
sures” to its list of other active standard-setting topics. On September 30, 2013 the PCAOB announced
that it is drafting a proposed standard, however, no timeline has been announced for its release (PCAOB
2013c).
16. We analyzed the 2008 and 2009 inspection reports of the annually inspected audit firms. In 2008, there
were ten annually inspected firms: BDO Seidman, Crowe Horwath, Deloitte, Ernst & Young, Grant
Thornton, KPMG, KPMG Canada, Malone and Bailey, McGladrey and Pullen, and PricewaterhouseCo-
opers. In 2009, there were only eight annually inspected firms, as KPMG Canada and Malone and Bailey
did not require annual inspection. Church and Shefchik (2012) examine the content of inspection reports
for annually inspected firms for an overlapping period (2004–2009); however, their analysis does not focus
on audits of estimates. They report more generally on the severity of deficiencies identified, whether the
deficiencies resulted in misstatement, the frequency of deficiencies, accounts affected over time, and audit
firm responses to inspection reports.
17. PCAOB inspection reports contain public (Part I) and private (Part II) portions. Part I contains a listing
of audit deficiencies discovered during inspection and is the source of our analysis reported in Tables 4, 5,
and 6. Part II typically relates to issues with the firms’ quality control systems. The PCAOB initially
releases this portion of the report only to the inspected firm and these comments remain private if the firm
addresses them to the PCAOB’s satisfaction within one year. If a firm fails to satisfactorily address any of
these comments within one year, the PCAOB publicly releases the portions of the report discussing the un-
remediated criticisms; any criticisms that have been satisfactorily addressed are redacted before release.
The PCAOB released three Part II reports for the annually inspected firms in our sample time period
(PCAOB 2012a; PCAOB 2013a, b).
ments, they do provide evidence about the types of problems auditors have when
auditing material, higher risk areas (which the following analysis shows frequently
include estimates). This directed search for problems related to material and higher-risk
areas is indicative of one way in which the PCAOB could exert pressure on audit
firms, although it is unclear ex ante whether this pressure is for change or continuity
in the audit process.
Two authors independently coded the content of the public portion of the inspection
reports. For each issuer listed in each audit firm’s report, we identified the financial state-
ment account group(s) with auditing deficiencies. When disclosed, we also collected the
general accounting or auditing issue for the account. Finally, we coded the auditing defi-
ciency(ies) based on the inspection report descriptions.18 This coding was necessary
because the PCAOB did not identify the auditing standards to which the deficiencies
related at the time these inspections were performed. We developed a coding scheme
describing 15 unique auditing deficiencies.19 The first seven deficiency types in the coding
scheme identify problems with how auditors use valuation or other models that underlie
estimates (i.e., problems within the process of auditing estimates outlined in Figure 1).
The remaining eight categories are not specifically related to use of models. The coders’
initial agreement was 71.9 percent; Cohen’s j was 0.68 (p < 0.01). Coders mutually agreed
on the final category codes, which are used in the analysis.
Table 4, panel A summarizes the types of auditing deficiencies the inspectors identified
related to the audit of estimates and their frequencies. Inspectors identified a total of 331
deficiencies of which at least 227 (68.6 percent) are related to the audit of estimates.20
The PCAOB noted problems with nearly every step that standards describe in the process
of auditing estimates, including considering whether relevant factors are excluded from the
model, the step that our interviewees did not indicate they performed. The exception is
that the PCAOB made no mention of problems specifically related to preparation of inde-
pendent estimates or review of subsequent events, which we expect occurred because firms
do not use these approaches very frequently.21
Table 5 summarizes the accounts with PCAOB-identified auditing deficiencies. The
PCAOB identified 168 accounts with deficiencies, with 99 (58.9 percent) of these related
to four particularly judgment-laden accounts: revenue, investments and securities, good-
will, and allowance for loan losses. Several other accounts with deficiencies similarly
require significant judgment to audit, and many contain estimates (e.g., intangibles,
income taxes, accounts receivable, derivatives, and long-lived assets). The high fre-
quency of deficiencies related to complex accounts requiring significant judgment or
estimation makes this analysis useful for our purpose, and the types of accounts with
18. Each account group could have multiple deficiencies. For example, in BDO Seidman’s 2009 inspection
report, the PCAOB identified eight issuers with auditing deficiencies. For Issuer A, the PCAOB identified
four account groups with deficiencies (i.e., fixed-maturity securities, available-for-sale investments, claims
losses, and revenue). The accounting and auditing issues for this issuer included fair value, impairment,
estimation, and meeting audit objectives, respectively, for the above-identified accounts. Finally, the
PCAOB identified two auditing deficiencies for the fixed-maturity securities: relying on controls without
testing their effectiveness and failure to test data used in valuation models (PCAOB 2010a).
19. Please see supporting information, “Appendix S2: Categories Used to Code Inspection Report Deficien-
cies” as an addition to the online article.
20. The inspectors also noted 104 other deficiencies, some of which are clearly not related to audits of esti-
mates (e.g., problems with analytical procedures and confirmations), and others may or may not relate to
estimates (e.g., failure to collect sufficient evidence).
21. The PCAOB is charged with inspecting whether auditors comply with auditing standards. Since the stan-
dards allow auditors to choose one or more of three approaches and make no mention of when one is
preferable, the PCAOB would be unlikely to cite deficiencies about approaches not used if an approved
approach is used. Instead, PCAOB deficiencies focus on how the audit work performed falls short of stan-
dards for the approach the auditors chose.
TABLE 5
Accounts with PCAOB-identified deficiencies
Revenue 32 19.0
Investments and securities 31 18.5
Goodwill 19 11.3
Allowance for loan losses 17 10.1
Pension plan assets 12 7.1
Inventory 7 4.2
Intangibles 7 4.2
Income tax accounting 6 3.6
Accounts receivable 4 2.4
Contingent liability 4 2.4
Derivatives 3 1.8
Long-lived assets 3 1.8
Assets 2 1.2
Controls 2 1.2
Going concern 2 1.2
Other 17 10.1
TABLE 6
Accounting issues for accounts with PCAOB-identified deficiencies
Note:
The PCAOB did not identify the accounting or auditing issue for the remaining 38 accounts with
deficiencies.
deficiencies overlap considerably with the types of estimates interviewees discussed (as
shown in Table 1).
Table 6 summarizes the accounting and auditing issues that the PCAOB identified as
related to the deficiencies. The table reveals that fair value, impairments, and estimation
accounted for 88 of 130 (67.7 percent) issues identified. This indicates that the deficiencies
identified by the PCAOB related to more subjective accounting.
22. The PCAOB describes in Part I only deficiencies that it believes show evidence that the inspected audit
firm had not obtained sufficient competent evidence to support its audit opinion(s) (PCAOB 2013b).
firm). Notably, the first two concerns were each related to auditing fair values and esti-
mates.23 The comments related the previously identified deficiencies to a lack of supervi-
sion and review. One report stated:
The reported deficiencies raise questions regarding the sufficiency, rigor, and efficacy of
the supervision and review activities of the Firm’s engagement managers, engagement
partners, and SEC concurring review partners, including their exercise of due care and
the thoroughness with which they review work papers. The inspection observations sug-
gest the possibility that more attention needs to be devoted to supervision and review
activities in connection with audit of areas involving a high degree of judgment, manage-
ment estimation ****. (PCAOB 2013a, 13).24
In our view, these comments do not apply pressure for audit firms to change the
methods used to evaluate fair values and other complex estimates. Rather, these comments
encourage the firms to improve the efficacy of their existing procedures.25 To the extent
that root causes of the problems reside in the method, and a change in method is needed
to resolve problems, this approach will be unsuccessful. In that case, the PCAOB’s inspec-
tions focusing on estimates provide an illustration of how standard setters’ attempts to
influence audit practice can be ineffective (Malsch and Gendron 2011).
Overall, this evidence suggests that the PCAOB inspection process does not yield pres-
sure for change in approach or choice of procedures used on audits. While the PCAOB
appears to specify the problems it finds with the audits of complex estimates, it falls short
of theorizing the problems, in that it does not identify a change that would clearly be
more appropriate than current practices. Rather, its focus seems to be on identifying
weaknesses in the execution of chosen methods. Thus, the implication of the inspection
comments is that the problems are with the execution rather than the choice of methods.
This sort of feedback is unlikely to prompt the audit firms to conclude that a change in
method is required or to deduce what type of change would be effective. Given the
23. Of course, we cannot determine from the released portions of Part II of the inspection reports if the
redacted issues were satisfactorily addressed because the PCAOB made specific suggestions for change that
the firms were able to implement within one year. It could be that for less complex issues, the PCAOB
makes specific suggestions for improvement that are a source of pressure for change in practices. We can-
not know the content of the redacted portions of the Part II reports as the PCAOB is prohibited by law
from discussing their contents. However, our examination of these reports indicates that for complex
issues, such as auditing complex estimates, the PCAOB does not pressure the firms to change the nature
of their planned procedures. Instead, it appears they pressure the firms to increase the sufficiency and
extent of their planned procedures, effectively creating pressure for continuity in current practices.
24. **** indicates material that was redacted from the release of Part II of the report.
25. There was one comment in the three reports that we viewed as suggesting a specific change, however, it
was not clearly related to the audit of estimates. Rather, it concerned three partners’ workloads, and the
consequences for their effectiveness (PCAOB 2013b).
PCAOB’s mandate to inspect firms to determine whether they have complied with auditing
standards, it seems that the primary way that the PCAOB could pressure firms for
changes in practice is through changes in auditing standards.
Second, institutional theory proposes that one way that organizations legitimize the
procedures for a new situation is by adapting the procedures they already use in other
situations, even if these procedures are not the best fit for the new situation (Zucker
1987). We find that auditors have adapted both the method and the structural approach
used to audit accounts without uncertainty to the audit of complex estimates. Nonesti-
mated accounts generally follow historical cost accounting and are audited by verifying
original costs. We find that firms adopted this verification approach when auditing com-
plex estimates even though verification is less appropriate for accounts whose valuation
involves uncertainty. Additionally, audit firms adapted the highly structured and rou-
tinely used method of breaking the audit into a series of compartmentalized steps to
the audit of complex estimates. This checklist-like approach easily accommodates verify-
ing discrete components of management’s estimates, but does not accommodate the
complexity of a more integrated process. By using this approach, firms create the illu-
sion that the audit program steps are unrelated; thus, interdependencies among the steps
are overlooked, preventing a more holistic, critical evaluation of the estimate. The per-
ceived legitimacy of existing verification methods for auditing nonestimated accounts
leads to framing audits of complex estimates as piecemeal verification tasks rather than
as critical evaluation tasks.
Finally, institutional theory proposes that procedures propagate across organizations
via mimetic isomorphism, a process of copying the policies and procedures of other orga-
nizations in an environment. This process makes the organizations more similar without
necessarily improving their efficiency or effectiveness (DiMaggio and Powell 1983). As we
demonstrate in our analysis of PCAOB inspection reports, audits of accounts containing
complex estimates are especially likely to be inspected. Further, inspection reports reveal
that inspection deficiencies are largely focused on problems with auditing management’s
process for creating estimates. Thus, the PCAOB’s inspection reports facilitate mimetic
isomorphism by signaling that this method is commonly used. Additionally, since the
PCAOB’s inspection reports identify problems with auditing management’s process but do
not suggest solutions to these problems, change that might result from coercive isomor-
phism is impeded. In fact, the lack of suggestion to use alternative methods implies tacit
agreement with, and increases the legitimacy of, the choice to audit management’s process.
Thus, despite a goal of improving audit quality, the inspection process may facilitate the
spread of suboptimal methods for auditing complex estimates, consistent with the proposi-
tions of institutional theory.
Institutional theory also explains the convention that has arisen surrounding the divi-
sion of knowledge between auditors and valuation specialists. Power (1996) argues that
auditors have long promoted the value of auditing knowledge over other types of knowl-
edge as a way of advancing the field. Power (2003) explains that the knowledge base of
auditing must be legitimated in the same way that procedures become accepted, so the cri-
teria to be considered a qualified auditing expert are a function of this legitimating pro-
cess. This suggests that auditors will model knowledge acquisition on practices followed in
other processes within their organizations and on those followed by other organizations
within their environment. Thus, auditors created a division of knowledge such that they
take responsibility for understanding how to obtain evidence about the accounting-related
elements of estimates and they delegate knowledge of and evidence gathering about valua-
tion-related elements of estimates to valuation specialists.
That said, it is clear that expert knowledge of valuation is required in order for com-
plex estimates to be auditable. If the measurement of complex estimates were viewed as
beyond the limits of expertise, complex estimates, and, by extension, financial statements
incorporating large estimated amounts, would not be auditable (e.g., Power 1996). Rather
than have auditors build valuation expertise themselves, audit firms choose to endorse and
rely upon the expertise of valuation specialists. That is, our interviewees describe the audit
team as being composed largely of auditors without deep or well-developed knowledge
about the models used to develop complex estimates, with expertise coming from special-
ists. This division of knowledge makes it difficult for auditors to understand the signifi-
cance of assumptions and the sensitivity of estimate values to changes in assumptions.
However, each of the firms interviewed follows this institutionalized convention, evidence
of mimetic isomorphism. Thus, audit firms have made complex estimates auditable by
relying on others (valuation specialists) who have the knowledge needed to evaluate these
accounts and by adapting their judgment frameworks and checklist-like audit programs to
this environment, consistent with institutional theory.
research might focus on developing new audit methodologies that (i) rely less on man-
agement representations and/or (ii) employ integrated audit processes rather than com-
partmentalized verification steps, thereby addressing the root causes of current
problems. Current standards allow auditors to generate independent estimates, and this
would seem to meet both criteria. However, the International Auditing and Assurance
Standards Board (IAASB) appears to endorse an approach focused on testing manage-
ment’s process and data in its recently issued practice note on auditing financial instru-
ments (IFAC 2011, ¶114). Apparently because of cost (efficiency) concerns, they
characterize developing an independent estimate as a last resort. Because auditors cur-
rently do not tend to generate independent estimates very frequently, it is an open
question as to whether doing so would increase the reliability of estimates. We encour-
age future researchers to examine more fully the costs and benefits of developing inde-
pendent estimates, including whether there are predictable conditions under which the
benefits exceed the costs and whether and how technology can reduce the costs and
simplify the task of generating independent estimates.
Research could examine the effectiveness of alternative means by which firms could re-
frame the auditor’s task as critically evaluating the reasonableness of the overall estimate
rather than verifying the individual elements of management’s model or process. For
example, when modeling an estimate is overly complex and subsequent data are not infor-
mative, auditors may be able to take additional steps, such as explicitly considering what
features the model should have and what parameter values are reasonable before viewing
management’s model to avoid anchoring on management’s model and estimate.
Future research could also examine how auditors resolve problems that arise during
audits of estimates, especially contradictions among assumptions used to generate esti-
mates. A detailed examination of this resolution process, relying on in-depth interviews of
auditors, could enhance our understanding of how and under what conditions bias
remains in audited complex estimates. Finally, research using the theoretical insights of
institutional theory (e.g., the notion of institutional work [Lawrence, Suddaby, and Leca
2009]) could enhance our understanding of how other important auditing practices are cre-
ated, maintained, and modified.
In conclusion, we note that the auditors we spoke with were very forthcoming about
problems they experience in auditing estimates. It appears that auditors (and audit firms)
are well aware that they experience serious problems auditing estimates. This leads to
some interesting questions about the institution of auditing: Why do these problems per-
sist, given they are so well known? How do auditors gain sufficient comfort to sign off on
financial statements containing complex estimates, given their awareness of the shortcom-
ings in their own process? To what extent does problem persistence influence auditor per-
formance in other types of tasks? Our analysis provides some initial answers to these
questions, but they warrant future research, as does the question of whether complex esti-
mates are truly auditable, and, if not, whether audit technology to make them so can be
developed in the near term.
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SUPPORTING INFORMATION
Additional Supporting Information may be found in the online version of this article:
Appendix S1. Details of Auditors’ Process and Problems when Auditing Complex Esti-
mates
Appendix S2. Categories Used to Code Inspection Report Deficiencies