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Attack on Auditor Independence in Iowa

Last night, the Iowa Senate quickly passed a bill that effectively limits the State Auditor’s independent oversight by restricting his access to records. The National State Auditors Association (NSAA) President and Connecticut State Auditor John C. Geragosian wrote the following letter in response. It was signed onto by a number of other state auditors. Here is the bulk of his letter:

March 8, 2023

To Whom It May Concern:

As President of the National State Auditors Association, I, and other independent state auditors from around the country are writing to express our concerns with Iowa Senate File 478.

This bill will negatively impact Auditor Sand’s ability to independently and sufficiently perform his audit work. State auditors should have unfettered access to confidential records to ensure that state agencies are following their policies and procedures and state and federal law. This is also necessary to ensure that we prevent waste, fraud, and abuse of state programs and funds. State auditors also have the immense responsibility to guard against disclosure of any confidential information. It is a responsibility we take seriously. We are concerned that this bill will negatively impact the auditor’s ability to independently and sufficiently perform his audit work.

According to professional auditing standards from the U.S.

Government Accountability Office and the American Institute of Certified Public Accountants, auditors must be independent and have the ability to obtain sufficient, appropriate audit evidence to achieve audit objectives. Independence is a foundational requirement and is embedded in professional auditing standards.

In addition, Uniform Guidance (2 CFR Part 200) requirements prescribed by the U.S. Office of Management and Budget require that auditors adhere to Government Auditing Standards, including those standards pertaining to independence. The audit requirements in the Uniform Guidance that are used to conduct audits of federal grant funds include the issuance of an opinion on compliance with the laws and regulations of major federal grant programs.

If the auditor cannot obtain sufficient, appropriate evidence due to externally imposed limitations such as those outlined in this bill, they may disclaim an opinion on the state’s financial statements and its compliance with the laws and regulations of major federal grant programs. This means that these limitations are so severe that the auditor is unable to issue an opinion. This should not be the desired outcome of any audit and would lead to significant concerns for the federal grant-awarding

agencies and could result in a loss of federal funds. A disclaimer on the financial statements could also negatively impact the state’s bond rating.

Auditor independence is an essential element for the proper oversight of public funds. Therefore, we respectfully request that you eliminate the limitations in Iowa Senate File 478.


John C. Geragosian, President

Connecticut State Auditor

Other State and Territorial Auditors in support of this letter:

Kris Curtis, Alaska Legislative Auditor

Roger Norman, Arkansas Legislative Auditor

Grant Parks, California State Auditor

Clark J. Chapin, Connecticut State Auditor

Greg Griffin, Georgia State Auditor

April Renfro, Idaho Legislative Auditor

Frank Mautino, Illinois Auditor General

Matt Dunlap, Maine State Auditor

Judy Randall, Minnesota Legislative Auditor

Angus Maciver, Montana Legislative Auditor

Daniel Crossman, Nevada Legislative Auditor

David J. Kaschak, New Jersey State Auditor

Tina Kim, New York Deputy Comptroller for State Government Accountability

Beth A. Wood, North Carolina State Auditor

Kip Memmott, Oregon Director of Audits

Yesmin M. Valdivieso, Puerto Rico Comptroller of the Commonwealth

David Bergantino, Rhode Island Interim Auditor General

K. Earle Powell, South Carolina Director of Legislative Audit Council

John Dougall, Utah State Auditor

Pat McCarthy, Washington State Auditor


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