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QUALITY OF EVIDENCE. FRCC Compliance Workshop September/October 2008. Evidence is essential. The Registered Entity has the burden to prove compliance through presentation of quality evidence to a standard or requirement. “Provide Quality Evidence ”. Objective .
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QUALITY OF EVIDENCE FRCC Compliance Workshop September/October 2008
Evidence is essential The Registered Entity has the burden to prove compliance through presentation of quality evidence to a standard or requirement. “Provide Quality Evidence ”
Objective Objective – What is quality evidence? • Define evidence and the types of evidence. • Describe what constitutes quality evidence. • Define appropriate and sufficient evidence. • Provide a better understanding of evidence and its role in compliance monitoring activities.
Definition of Evidence Evidence is: • Data or information on which factual statements can be based. • A collection of relevant and sufficient information offered to verify a presented fact. • Obtained through examining and analyzing records, observing events, or conducting interviews.
Presenting Your Evidence • Auditors gather evidence to draw conclusions on findings in a logical method based upon factual evidence. • Facts are to be valid and relevant for the point needed to be proven. • A fact is something that can be objectively verified, is real and does exists. • Facts must be verifiable. • A verifiable fact is one whose data or information can be substantiated by comparison, investigation or confirmation. • Entities should consider presenting and submitting their evidence in the same manner.
Types of Evidence Evidence can be provided as: • Physical evidence • Direct observations • Corroborating evidence • Corroborating evidence is evidence that tends to support a proposition that is already supported by some evidence. (Wikipedia 9/11/2008) • To strengthen or support with other evidence; make more certain (the Free dictionary 9/11/2008)
Types of Evidence Physical Evidence is direct inspection of activities of people, property, or events: • Some examples include: • Schedules • Charts • Maps • Graphs • One-lines • Manuals • Procedures and Policies • Plans
Types of Evidence Documentation: • Physical forms of evidence which already exists • Can be both external or internal • Some examples include: • Letters • Contracts • Assessments • Agreements • Spreadsheets • Database Extracts • E-mails • Studies
Types of Evidence Direct Observations: • What an auditor sees during your review. • Strengthened through corroboration with other evidence. • By itself is almost always unreliable. • Is achieved by monitoring of personnel, facilities, equipment, and tools.
Types of Evidence Corroborating evidence is: • Additional information from interviews, logs, etc provides clarity to make the appropriate compliance decision. • Used to establish the appropriateness of evidence. • Tests the reliability of evidence and provides confirmation. • Some examples include: • Reliability Coordinator or Neighboring questionnaires • Voice recordings • Logs • Interviews
An Example of Corroborating Evidence The auditor requests evidence that a Registered Entity has followed all directives from the Reliability Coordinator • The Registered Entity states it has not received any directives: • Response is neither sufficient, nor adequate • Testimonial • Low quality • May not withstand scrutiny Corroborating evidence could be an e-mail from the Reliability Coordinator stating the Reliability Coordinator did: • Not send any directives to the Registered Entity during the specified time frame, or • Did send a directive and it was followed
Quality Evidence Quality evidence is evaluated by its: • Appropriateness • relevant, valid and reliable to support findings. • Sufficiency • enough information to lead another person to the same conclusion. • Quality • high quality evidence to be used as proof of findings.
Appropriateness of Evidence Quality evidence must be appropriate: • Relevant to the reliability standard requirements: • Is there enough to persuade the auditor his findings are reasonable? • Is it logically related to the requirement? • Valid as a document: • Is the evidence based upon sound reasoning and accurate information? • Reliable information: • Can the evidence be substantiated when tested?
Example of Appropriate Evidence An agreement is offered as evidence. The auditor will seek to determine: • Is this the original document? • Does the agreement contain the Registered Entity letterhead, approval signature and date,revision date, etc? • Does the agreement address the subject of the requirement? • Is this version the current version?
Sufficient Evidence Quality evidence must be sufficient: • Is there enough evidence to lead an auditor to the same findings that you have reached. • Strong evidence may be better than a large volume of weak evidence.
Example of Sufficient Evidence • The auditor is provided three documents to determine if a procedure exists and is coordinated with neighboring entities: • A procedure • E-mails • Previous version of procedure • The above evidence is sufficient as: • A valid procedure is provided which addresses all sub-requirements even if they do not apply to the audited entity. • E-mails provide evidence the procedure was sent, received and confirmed as coordinated. • Previous version of procedure shows the procedure existed for the audit period.
Quality Evidence • The evidence must be of the highest quality to be used as proof of findings. • Quality evidence should contain: • Documents title • Purpose • Date approved • Revision level • Effective date • Authorizing signatures
Testimonial Evidence Written or oral statements in response to inquiries or interviews. • Examples are: • Reliability Coordinator or Neighboring questionnaires • Interviews • Letters sent for confirmation
Computer Processed Evidence Computer evidence can be provided if: • The evidence can be determined to be sufficient and appropriate. • Is the information considered quality evidence? • Can the evidence be validated from electronic logs to confirm creation? • Some examples include: • Printouts (titled, dated) • Screen shots • Logs (titled, dated) • Study results (titled, dated)
Professional Judgment All evidence reviewed requires some level of professional judgment. “Professional judgment of the auditors is based on their: • Knowledge • Skills • Experiences • Good Faith Application • Integrity
Final Thoughts Some things to remember: • Who you are trying to convince, the auditors. • Compliance is based upon the evidence provided. • Would you objectively make a determination of compliance or possible violation?
Conclusion At the end of the review, enough quality evidence must have been provided to: Soundly substantiate the teams findings and Support your expected findings