IRP AUDIT PROCEDURES MANUAL AND INTERNATIONAL REGISTRATION PLAN ARTICLE 1 INTRODUCTION Current Text Proposed Text/Comments 101. Purpose of the Manual 101. Purpose of the Manual (a) The purpose of the Audit Procedures The purpose of the Audit Procedures Manual is Manual is to establish a uniform procedure for to establish uniform audit procedure for all all Member Jurisdictions to follow. This Member Jurisdictions to follow. This includes includes notifying the Registrants of an Audit, notifying the Registrants of an audit, conducting the Audit, reporting the Audit, conducting the audit, reporting the finding, assessing shortages, granting credit, and assessing amounts owing or refundable, and canceling Registrants, should it become canceling Registrants, if required. necessary. (b) The purpose of auditing Registrants under the International Registration Plan, hereafter referred to as “the Plan”, is to protect the integrity of the Vehicle registration laws of all Member Jurisdictions and to ensure equitable treatment of all Registrants subject to the Plan. In accordance with the purpose and principles of the Plan in providing for efficient use of the Member Jurisdictions’ highway systems, it is incumbent upon each Member Jurisdiction to meet its obligations under the provisions of the Plan, i.e., proportional registration of commercial Vehicles, by insuring proper Operational Records of Registrant Total Distance operated, and official Audit of the appropriate Operational Records of all Registrants as prescribed by Article X of the Plan and the Audit Procedures Manual (APM). 102 Background 1 (a) The International Registration Plan is an agreement providing for registration reciprocity among Member Jurisdictions. The unique feature of the Plan is that, even though Apportionable Fees are paid to the various Jurisdictions in which Vehicles of a Fleet are operated, the only Plate and Cab Card issued for each Fleet Vehicle are the Plate and Cab Card issued by the Base Jurisdiction. The Plan provides for payment of Apportionable Fees on the basis of the proportion of Total Distance operated in all Jurisdictions by the Fleet of which a Vehicle is part. (b) Under the provisions of Article X of the Plan, each base jurisdiction shall audit the apportioned registration applications and supporting documents of Registrants to verify the accuracy of distance figures derived from operational records and other registration information. This does not preclude audits of individual Registrants several times during the peer review period. Such audits may cover one to four registration years. The base jurisdiction shall notify all affected Member Jurisdictions (as defined in Section 803.2), in which the Registrant paid apportioned fees, or should have paid apportioned fees of the audit results upon the completion of any such audits. 2 ARTICLE 2 GENERAL ACCOUNTING AND AUDITING STANDARDS 201. Training and Proficiency 201. Proficiency and Due Professional Care The Audit is to be performed by a person or For an audit to be acceptable to all Member persons having adequate technical training and Jurisdictions, it must be conducted with due proficiency as an auditor. professional care and the results clearly documented. An audit is to be performed by a person or persons having adequate training and proficiency as an auditor. 202. Professional Care 202. Professional Care (a) For an Audit to be acceptable to all (a) Proficiency – Auditors performing the Member Jurisdictions, it must be conducted in engagement should possess the knowledge, a professional manner and the results clearly skills and other competencies needed to documented. perform the audit. The audit function collectively should possess or obtain the (b) Since the concept of the Plan is for the knowledge, skills, and other competencies Registrants to pay fees to the various Member needed to perform its responsibilities as Jurisdictions based on the percentage of Total outlined in Article 3, Chapter 304 of this Distance traveled, it is obvious that an manual. effective, uniform Audit program is essential to verify the integrity of transactions. If such a (b) Due Professional Care – The auditors program is not established, each Member should apply the care and skill expected of a Jurisdiction will be inclined to send auditors reasonably prudent and competent auditor. into other Member Jurisdictions to verify the accuracy of the In-Jurisdiction Distance percentages and Apportionable Fees paid, creating an undue burden on Registrants. It is, therefore, essential that the basic Audit program adopted by each Member Jurisdiction be uniform and thorough to ensure accuracy. It is each Member Jurisdiction’s responsibility to conduct an accurate Audit in a professional manner and to submit a report to each Member Jurisdiction in which the Registrant paid Apportionable Fees or should have paid Apportionable Fees. Any discrepancies in Total Distance reported for Member Jurisdictions are to be reported, and the Base Jurisdiction should make a complete Audit of the registration for the Member Jurisdictions, making whatever adjustments are necessary. 3 203. Study and Evaluation 202. Study and Evaluation For a proper Audit to be conducted, a study As part of the audit process, the auditor(s) must and evaluation of the Registrant’s reporting gain an understanding of and document the system and internal accounting controls must Registrant’s reporting system and make an be performed. It is essential that the auditor evaluation of the Registrant’s internal controls. gain an understanding of the Registrant’s A walk through of the Registrant’s system reporting system to aid in the Audit process. should be performed to ensure that internal Additionally, where reliance is to be placed on controls are functioning as described. Any internal accounting controls for sampling test weaknesses in internal controls should be work and projections, the auditor must documented and their impact on the audit taken determine the reliability of the internal into account through changes to the audit accounting controls and the impact of any program. weaknesses in the controls on sampling procedures employed in the Audit. 204. Adequate Planning and Supervision 203. Adequate Planning and Supervision (a) Audit work shall be adequately planned and (a) Audit work must be adequately planned and supervised. A standardized Audit program (or supervised. A standardized audit program checklist), describing the Audit procedures should be utilized. The use of a standardized contained in this Audit Procedures Manual and audit program provides for consistent other recommended Audit procedures, should application of audit procedures. It serves as a be utilized. The use of a standardized Audit training tool for new auditors, and facilitates program provides for consistent application of the review of the audit by the audit supervisor. Audit procedures. It serves as a training tool It does not, however, preclude the use of for new auditors, and facilitates the review of auditor judgment, when the auditor and the Audit by the Audit supervisor. It does not, supervisor have reason to believe that a however, preclude the use of auditor judgment, situation warrants an adjustment to standard when the auditor and supervisor have reason to recommended procedures. Deviations from the believe that a situation warrants an adjustment standard recommended procedures shall be to standard recommended procedures. documented and approved by the Audit Deviations from the standard recommended supervisor. procedures should be documented and approved by the Audit supervisor. (b) The audit function must have a system which includes a supervisory review of the (b) The Audit report and working papers working papers to ensure accuracy, and should be reviewed and approved by an Audit completeness. This review should be supervisor. This will assure that all Audits are documented in the working papers. conducted accurately and consistently. 4 205. Auditor Independence 204. Auditor Independence (a) The auditor must be free from personal and (a) In all matters relating to the audit work, the external impairments to independence. In all audit organization and the individual auditor, matters relating to the assignment, whether government or public, must be free independence in mental attitude is to be from personal, external, and organizational maintained by the auditor. The auditor must be impairments to independence, and must avoid without bias with respect to the Registrant the appearance of such impairments of under Audit, since otherwise the auditor would independence. lack the impartiality necessary for dependable Audit findings. (b) Auditors and audit organizations must maintain independence so that their opinions, (b) In order to maintain independence, auditors findings, conclusions, judgments, and should not be involved with the processing of recommendations will be impartial and viewed registration applications. as impartial by objective third parties with knowledge of the relevant information. Auditors should avoid situations that could lead objective third parties with knowledge of the relevant information to conclude the auditors are not able to maintain independence and thus are not capable of exercising objective and impartial judgment on all issues associated with conducting the audit and reporting on the work. 206. Working Paper Documentation 205. Working Paper Documentation (a) The Audit report shall be supported by (a) The Audit Report must be supported by adequate working papers. The working papers adequate working papers. The working papers should be prepared by the auditor and shall be prepared by the auditor and reviewed/approved by an auditor supervisor. reviewed/approved by an auditor supervisor. They should support the basis for the findings They shall support the basis for the findings and recommendations in the Audit report. and recommendations in the Audit Report. Working papers should be sufficiently detailed Working papers shall be sufficiently detailed so that a reviewer (internal or external) can so a reader can understand them without understand them without extensive oral extensive oral explanations from the auditor. explanations from the auditor. (b) Working papers may be in the form of (b) Working papers may be in the form of paper or electronic media (imaged documents, paper or electronic media (imaged documents, spreadsheet files, databases, word processing spreadsheet files, databases, word processing documents). Working papers must: documents). Working papers should: (i) Provide the principal support for the Audit (i) Provide the principal support for the Audit Report; report; (ii) Aid in the performance of and review of (ii) Aid in the performance of and review of audits; Audits; (iii) Document planning, audit procedures (iv) Document whether Audit objectives were performed, and conclusions reached achieved; and (iv) Document whether audit objectives were 5 (iii) Facilitate third party reviews; achieved. (v) Document planning, Audit procedures performed, and conclusions reached. 6 ARTICLE 3 AUDITOR QUALIFICATIONS AND RESPONSIBILITIES 301. Auditor Qualification 301. Auditor Qualification Each Member Jurisdiction is responsible for Each Member Jurisdiction is responsible for the staffing of qualified auditors based on the staffing of qualified auditors based on Member Jurisdiction’s personnel guidelines. Member Jurisdiction’s personnel guidelines. The staff assigned to conduct Audits must The staff assigned to conduct audits must possess adequate professional proficiency for possess adequate professional proficiency for the tasks required. This standard places the tasks required. This standard places responsibility on the Member Jurisdiction to responsibility on the Member Jurisdiction to ensure that each Audit is conducted by auditors ensure each audit is conducted by auditors who who have the knowledge and skills necessary have the knowledge and skills necessary to to conduct the Audit. In cases where the Audit conduct the audit. In cases where the audit is process is performed by a private concern, the performed by a third party or contract audit(s), Member Jurisdiction must ensure that the the Member Jurisdiction must ensure the third contracted auditors meet applicable party or contract auditor(s) meet applicable professional standards. professional standards. 302. Auditor Responsibilities 302. Auditor Responsibilities (a) Auditors must give all Registrants equal (a) Auditors must give all Registrants and and fair consideration. There must be no Member Jurisdictions equal and fair preferential treatment given. consideration to promote consistency in the application of regulations. (b) Auditors must conduct Audits in accordance with the Audit Procedures Manual (b) Auditors must conduct audits in accordance and Member Jurisdiction’s Audit procedures. with the APM and their own jurisdiction’s audit procedures. (c)Auditors conduct Audits on behalf of all Member Jurisdictions. Auditors must conduct (c) Auditors should conduct themselves in a Audits giving each Member Jurisdiction equal manner promoting cooperation and good and fair consideration. relations with Registrants and Member Jurisdictions. (d) Auditors should conduct themselves in a manner that promotes cooperation and good relations with Registrants and Member Jurisdictions. 303. Scope of Duties 303. Scope of Duties (a) The Base Jurisdictions are responsible for (a) The base jurisdictions are responsible for the actions of their auditors as they work the actions of their auditors as they work within the scope of their duties. Auditors shall within the scope of their duties. Auditors shall not have organizational restrictions that not have organizational restrictions precluding preclude them from conducting a full scope them from conducting a full scope professional professional Audit in accordance with this Audit in accordance with this manual. manual. (b) The auditor must discuss any discrepancies (b) The auditor shall be allowed to discuss any with the Registrant. 7 discrepancies with the Registrant. (c) The auditor should make recommendations (c) The auditor shall be able to make to the Registrant. recommendations to the Registrant. 304. Training (a) The jurisdiction must ensure auditors maintain proficiency in IRP auditing by providing formal or informal training opportunities through internal or external training sources. (b) The auditor is responsible for the following: (i) Continuing their own educational opportunities in order to enhance and maintain auditing proficiency. (ii) Pursue Continuing Professional Education, CPE (related to their organization’s activities and industry) in order to maintain their proficiency with regard to the governance, risk and control processes of their unique organization. 8 ARTICLE 4 REGISTRANT RESPONSIBILITIES 401. Adequacy of Records 401. Adequacy of Records (a) A Registrant’s distance accounting system **The record keeping requirements which are must consistently produce the information outlined under the current APM will be required by the Audit Procedures Manual as incorporated into the IRP Agreement (Plan) necessary to evaluate the accuracy of Vehicle under Article X. movement and to substantiate the Registrant’s application for apportioned registration under the Plan. The Registrant’s source documents must contain sufficient detail that Vehicle (a) A Registrant’s distance accounting system movement may be traced. must consistently produce the information required by the Audit Procedures Manual as (b) The Registrant must maintain Operational necessary to evaluate the accuracy of Vehicle Records that support the total In-Jurisdiction movement and to substantiate the Registrant’s Distance and Total Distance traveled application for apportioned registration under everywhere. Operational Records include the Plan. The Registrant’s source documents source documents suitable for verification of must contain sufficient detail verifying Fleet distance as reported on the Registrant’s Vehicle movement. application for apportionment. An acceptable source document for verifying Fleet distance (b) The Registrant must maintain Operational traveled is an “Individual Vehicle Distance Records supporting the total In-Jurisdiction Record” (IVDR). A standardized IVDR is Distance and Total Distance traveled. suggested and encouraged, but not required. Operational Records include source While it is desirable, the necessary information documents suitable for verification of Fleet for a trip need not be contained on a single distance as reported on the Registrant’s source document. IVDRs shall contain the application for apportionment. An acceptable following information: source document for verifying Fleet distance traveled is an “Individual Vehicle Distance (i) Date of trip (starting and ending); Record” (IVDR). A standardized IVDR is (ii) Trip origin and destination; suggested and encouraged, but not required. (iii) Route of travel (may be waived by Base While it is desirable, the necessary Jurisdiction); information for a trip need not be contained on (iv) Beginning and ending odometer or a single source document. IVDRs shall hubodometer reading of the trip (may be contain the following information: waived by Base Jurisdiction); (v) Total Distance; (i) Date of trip (starting and ending); (vi) In-Jurisdiction Distance; and (ii) Trip origin and destination; (vii) Power Unit number or vehicle (iii) Route of travel; the name or number of identification number. the highway or road (may be waived by Base Jurisdiction); (c) The Base Jurisdiction may waive either item (iv) Beginning and ending odometer or (iii) or (iv) above, but may not waive both items hubodometer reading of the trip (may be (iii) and (iv). Also, a Base Jurisdiction may, in waived by Base Jurisdiction); its discretion, require an IVDR to include (v) Total Distance; 9 additional information as follows: (vi) In-Jurisdiction Distance; and (vii) Power Unit number or vehicle (i) Fleet number; identification number. (ii) Registrant’s name; (iii) Trailer number; and (c) The Base Jurisdiction may waive either (iv) Driver’s signature and/or name. item (iii) or (iv) above, but may not waive both items (iii) and (iv). Also, a Base Jurisdiction may, in its discretion, require an IVDR to include additional information as follows: (i) Fleet number; (ii) Registrant’s name; (iii) Trailer number; and (iv) Driver’s signature and/or name. 402. Monthly, Quarterly, and Yearly 402. Monthly, Quarterly, and Yearly Summaries Summaries (a) From the information recorded on IVDRs, (a) From the information recorded on IVDRs, the Registrant must prepare and maintain: the Registrant must prepare and maintain: (i) A monthly summary that recaps In- (i) A monthly summary recapping In- Jurisdiction and Total Distance traveled by each Jurisdiction and Total Distance traveled by Power Unit operated during the calendar each Power Unit operated during the calendar month; month; (ii) A quarterly summary that recaps In- (ii) A quarterly summary recapping In- Jurisdiction and Total Distance traveled by the Jurisdiction and Total Distance traveled by the Fleet during each calendar quarter; and Fleet during each calendar quarter; and (iii) A summary of the quarterly recaps used in (iii) A summary of the quarterly recaps used in preparing the application for apportionment. preparing the application for apportionment. (b) Summaries are not acceptable at face value (b) Summaries are not acceptable at face value and must be supported by source documents and must be supported by source documents such as IVDRs in order to be of any use during such as IVDRs in order to be of any use an Audit. during an Audit. 403. Receiving Contract 403. Receiving Contract The IVDRs as mentioned can be utilized by any Registrant; however, a different situation is encountered in accumulating distance on one- way vehicle Fleet Vehicles. The source documents or IVDRs on a one-way Vehicle is the “receiving contract,” which is the paper work completed when a one-way vehicle is turned in or otherwise “received.” 10
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