BOP Program Statement 1211.02 § 3

Component and agency-wide audits conducted by the Division of Compliance and Oversight

(DCO) must comply with Generally Accepted Government Auditing Standards (GAGAS).

a. Independence. Independence is an essential part of auditing to establish credibility,

effectiveness, and overall integrity of the auditing process. DCO will follow requirements of

GAGAS for auditing internal controls.

In accordance with GAGAS, Independence comprises the following:

 Independence of mind. The state of mind that permits the conduct of an engagement

without being affected by influences that compromise professional judgment, thereby

allowing an individual to act with integrity and exercise objectivity and professional

skepticism.

 Independence in appearance. The absence of circumstances that would cause a reasonable

and informed third party to reasonably conclude that the integrity, objectivity, or professional

skepticism of an audit organization or member of the engagement team had been

compromised.

Auditors and audit organizations maintain their independence so that their opinions, findings,

conclusions, judgments, and recommendations will be impartial and will be viewed as impartial

by reasonable and informed third parties.

b. Continuing Professional Education. Continuing Professional Education (CPE) is essential

for improving auditor proficiency and maintaining quality audits. DCO staff conducting

1211.02 6/22/2026 PROPERTY OF US GOVERNMENT 3

Component or Agency-wide audits will follow all requirements identified in GAGAS, Chapter 4,

“Competence and Continuing Education.”

GAGAS requires all staff who plan, direct, perform audit procedures, or report on an audit

conducted in accordance with GAGAS, to develop and maintain their professional competence

by completing at least 80 hours of CPE in every two-year period as follows:

 24 hours. Subject matter directly related to the government environment, government

auditing, or the specific or unique environment in which the audited entity operates.

 56 hours. Subject matter that directly enhance auditors’ professional expertise to conduct

engagements.

c. Peer Review. The peer review process is critical to ensuring the reliability and quality of

audits being conducted within our agency. DCO will follow all requirements identified in

GAGAS, Chapter 5, Section “External Peer Review.” To comply with GAGAS, DCO must

obtain an external peer review by an independent, outside audit organization, every three years.

In accordance with GAGAS, “5.155 Each audit organization conducting engagements in

accordance with GAGAS must obtain an external peer review conducted by reviewers

independent of the audit organization being reviewed. The peer review should be sufficient in

scope to provide a reasonable basis for determining whether, for the period under review, (1) the

reviewed audit organization’s system of quality management was suitably designed and (2) the

organization is complying with its system of quality management so that it has reasonable

assurance that it is fulfilling its responsibilities in accordance with professional standards and

performing and reporting in conformity with such standards in all material respects.”