In Re Cedric M. Scott, PhD v. the State of Texas
Opinion
ACCEPTED
15-25-00227-CV
FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 12/9/2025 9:33 PM
CHRISTOPHER A. PRINE
CLERK
FILED IN
IN THE FIFTEENTH COURT OF APPEALS 15th COURT OF APPEALS
AUSTIN, TEXAS
AT AUSTIN, TEXAS 12/9/2025 9:33:51 PM CHRISTOPHER A. PRINE
Clerk
Case No. 15-25-00227 - CV (Transferred from the Third Court of Appeals)
IN RE CEDRIC M. SCOTT, PhD Relator, Pro Se
v.
GENERAL LAND OFFICE OF THE STATE OF TEXAS Real Party of Interest
Original Proceeding from the 250th Judicial District Court of Travis County, Texas
Trial Court Cause No. D-1-GN-25-000006
RELATOR’S MOTION TO EXPEDITE CONSIDERATION OF PENDING PETITION FOR WRIT OF MANDAMUS
TO THE HONORABLE FIFTEENTH COURT OF APPEALS:
Relator, Cedric M. Scott, PhD1, respectfully moves the Court to expedite
consideration of her Petition for Writ of Mandamus, which the Clerk accepted for
filing on December 8, 2025. The mandamus presents substantial constitutional,
procedural, and administrative defects that have halted the judicial process for
nearly a year. The absence of a successor judge since November 21, 2025, the
presence of void orders entered by a constitutionally disqualified trial judge, the
missing Court reporter’s record, and the systemic prejudice to Relator warrant
accelerated review.
Relator continues to suffer irreparable harm—including blacklisting, loss of
comparable employment since December 3, 2024, ongoing procedural paralysis,
and the inability to advance her claims due to the trial court’s inability to act.
Expedited consideration is necessary to prevent further harm and restore lawful
judicial process.
I. PROCEDURAL DEFECTS REQUIRING MANDAMUS INTERVENTION
A. Constitutional Disqualification Rendered All Orders Void
Judge Cory R. Liu previously represented GLO in HUD-related matters.
1 Plaintiff’s first name is pronounced See-Drick and not Said-Drick. Gender is female, and pronouns are she, her, and hers.
Under Tex. Const. art. V, § 11, this created constitutional disqualification. Orders
issued by a disqualified judge are void ab initio. Buckholts I.S.D. v. Glaser, 632
S.W.2d 146, 148–49 (Tex. 1982).
B. No Successor Judge Has Been Appointed
Judge Liu recused on November 21, 2025. As of today, no successor judge
has been assigned. Void orders remain uncorrected. Time-sensitive filings cannot
be ruled on. The trial court is unable to act. This constitutes the type of “stalled
judicial machinery” mandamus is designed to correct. In re Patel, 619 S.W.3d 651,
654 (Tex. 2021).
C. GLO Continues to Benefit From Procedural Paralysis
GLO has not answered the live petition, has not disputed the findings of its
own Internal Audit Report No. 25-01, and continues to benefit from the procedural
standstill created by the constitutional disqualification and lack of a successor
judge. Relator, by contrast, remains unable to obtain judicial review of void orders
or advance her claims.
This breakdown functions as a litigation shield for GLO. The agency avoids
responding to filings, avoids addressing corroborated compliance failures, and
avoids scrutiny of its inconsistent representations. With no judge in place, these
issues cannot be addressed. This one-sided paralysis is precisely the type of
structural defect a mandamus exists to remedy.
II. SIGNIFICANCE OF THE MISSING 10/29/2025 TRANSCRIPT
Relator filed a Motion to Preserve the Record before filing her mandamus.
The transcript, due November 21, 2025, has not been filed. It contains:
1. GLO’s counsel inferring the non-existence of the internal audit report,
2. Statements bearing on Relator’s credibility, and
3. The context surrounding void orders entered by a disqualified judge.
Despite Relator’s motion for preservation of the hearing transcription, its
absence further prejudices Relator and heightens the need for expedited relief.
III. INTERNAL AUDIT REPORT 25-01 CORROBORATES RELATOR’S PROTECTED DISCLOSURES
GLO’s Internal Audit Report No. 25-01, completed in sometime in
September 2025 and transmitted to the Office of the Governor, the Legislative
Budget Board, the State Auditor’s Office, and not shared to Relator documents
systemic deficiencies, including:
• Inadequate training
• Documentation failures
• Monitoring noncompliance
• Procurement irregularities
• Weak internal controls
• Undefined roles and responsibilities
The above findings mirror the deficiencies Relator documented and shared
with Grant Management and Internal Audit Director prior to her termination
summarized in TAB J and TAB K referenced in her pending mandamus. Those
materials were also submitted to the trial court with Relator’s Second Amended
Petition, which GLO has refused to answer the petition.
IV. ADDITIONAL GROUNDS DEMONSTRATING THE NEED FOR EXPEDITED REVIEW
A. GLO’s Litigation Position Conflicts With Mandatory Audit Standards and Its Own QAIP Framework
Relator provides this additional context to demonstrate why expedited
review is necessary and why GLO’s litigation posture is inconsistent with its own
internal-audit obligations.
1. Audit Standards (AS) 1311 Requires Internal Self-Assessments and Ongoing Monitoring
The FY2023 Internal Audit Quality Assurance and Improvement Program
(QAIP) Report, addressed to Commissioner Dawn Buckingham on October 9,
2023, confirms that GLO is required to conduct ongoing internal-audit monitoring
and periodic self-assessments. Exhibit 1- FY2023 QAIP Report at pages 1–4, where
the report describes:
a. Continuous monitoring of internal audit activities;
b. Periodic internal self-assessments;
c. Evaluation of conformance with internal-audit standards;
d. Documentation of internal processes and audit performance; and
e. Communication of periodic assessment results to GLO leadership.
Critically, page 4 of the QAIP Report expressly restates the requirements of the
Institute of Internal Audit Attribute Standard 1311, confirming that internal
assessments “must include ongoing monitoring of the performance of the internal
audit activity” and “periodic self-assessment or assessments by other persons
within the organization with sufficient knowledge of internal audit practices.”
2. GLO’s QAIP Reports Acknowledge and Operationalize AS 1311 Requirements
Across pages 1–6, the FY2023 and FY2022 QAIP Reports demonstrates that GLO:
a. Performs internal self-assessments annually;
b. Conducts ongoing monitoring through weekly meetings with audit teams;
c. Tracks performance, documentation, audit plans, and fieldwork;
d. Uses formal internal-audit policies and procedures; and
e. Performs post-audit analyses and status reporting.
These processes mirror the specific internal-audit functions that Relator
repeatedly reported as deficient within CDR Grant Management—specifically
documentation, oversight, internal controls, and monitoring. Exhibit 1- FY2023
and Exhibit 2 - QAIP Reports
3. GLO’s Interrogatory Response Contradicts These Published Requirements
In sworn discovery responses, GLO claimed that CDR–Grant Management
personnel were “not required” to conduct internal self-assessments. This is
contradictory with:
• AS 1311’s explicit requirement for periodic self-assessments;
• GLO’s own published QAIP processes confirming the same; and
• The responsibilities assigned to CDR oversight personnel, including senior
management, regional managers, and senior grant managers.
The contradiction is not minor. It demonstrates that GLO’s litigation
narrative—framing deficiencies as performance issues or managerial
disagreement—is incompatible with:
• External audit standards (AS 1311),
• Internal agency publications (FY2023 QAIP Report), and
• GLO’s Internal Audit Report No. 25-01’s conclusion that the deficiencies
were systemic, and not performance issues.
4. These Contradictions Reinforce Why Expedited Review Is Necessary
The inconsistencies between GLO’s sworn assertions and its own QAIP
framework:
• Confirm Relator’s disclosures were accurate and grounded in established
audit expectations;
• Demonstrate that deficiencies were structural and agency-wide, not
individual;
• Show that GLO’s litigation posture is at odds with its documented practices;
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ACCEPTED
15-25-00227-CV
FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 12/9/2025 9:33 PM
CHRISTOPHER A. PRINE
CLERK
FILED IN
IN THE FIFTEENTH COURT OF APPEALS 15th COURT OF APPEALS
AUSTIN, TEXAS
AT AUSTIN, TEXAS 12/9/2025 9:33:51 PM CHRISTOPHER A. PRINE
Clerk
Case No. 15-25-00227 - CV (Transferred from the Third Court of Appeals)
IN RE CEDRIC M. SCOTT, PhD Relator, Pro Se
v.
GENERAL LAND OFFICE OF THE STATE OF TEXAS Real Party of Interest
Original Proceeding from the 250th Judicial District Court of Travis County, Texas
Trial Court Cause No. D-1-GN-25-000006
RELATOR’S MOTION TO EXPEDITE CONSIDERATION OF PENDING PETITION FOR WRIT OF MANDAMUS
TO THE HONORABLE FIFTEENTH COURT OF APPEALS:
Relator, Cedric M. Scott, PhD1, respectfully moves the Court to expedite
consideration of her Petition for Writ of Mandamus, which the Clerk accepted for
filing on December 8, 2025. The mandamus presents substantial constitutional,
procedural, and administrative defects that have halted the judicial process for
nearly a year. The absence of a successor judge since November 21, 2025, the
presence of void orders entered by a constitutionally disqualified trial judge, the
missing Court reporter’s record, and the systemic prejudice to Relator warrant
accelerated review.
Relator continues to suffer irreparable harm—including blacklisting, loss of
comparable employment since December 3, 2024, ongoing procedural paralysis,
and the inability to advance her claims due to the trial court’s inability to act.
Expedited consideration is necessary to prevent further harm and restore lawful
judicial process.
I. PROCEDURAL DEFECTS REQUIRING MANDAMUS INTERVENTION
A. Constitutional Disqualification Rendered All Orders Void
Judge Cory R. Liu previously represented GLO in HUD-related matters.
1 Plaintiff’s first name is pronounced See-Drick and not Said-Drick. Gender is female, and pronouns are she, her, and hers.
Under Tex. Const. art. V, § 11, this created constitutional disqualification. Orders
issued by a disqualified judge are void ab initio. Buckholts I.S.D. v. Glaser, 632
S.W.2d 146, 148–49 (Tex. 1982).
B. No Successor Judge Has Been Appointed
Judge Liu recused on November 21, 2025. As of today, no successor judge
has been assigned. Void orders remain uncorrected. Time-sensitive filings cannot
be ruled on. The trial court is unable to act. This constitutes the type of “stalled
judicial machinery” mandamus is designed to correct. In re Patel, 619 S.W.3d 651,
654 (Tex. 2021).
C. GLO Continues to Benefit From Procedural Paralysis
GLO has not answered the live petition, has not disputed the findings of its
own Internal Audit Report No. 25-01, and continues to benefit from the procedural
standstill created by the constitutional disqualification and lack of a successor
judge. Relator, by contrast, remains unable to obtain judicial review of void orders
or advance her claims.
This breakdown functions as a litigation shield for GLO. The agency avoids
responding to filings, avoids addressing corroborated compliance failures, and
avoids scrutiny of its inconsistent representations. With no judge in place, these
issues cannot be addressed. This one-sided paralysis is precisely the type of
structural defect a mandamus exists to remedy.
II. SIGNIFICANCE OF THE MISSING 10/29/2025 TRANSCRIPT
Relator filed a Motion to Preserve the Record before filing her mandamus.
The transcript, due November 21, 2025, has not been filed. It contains:
1. GLO’s counsel inferring the non-existence of the internal audit report,
2. Statements bearing on Relator’s credibility, and
3. The context surrounding void orders entered by a disqualified judge.
Despite Relator’s motion for preservation of the hearing transcription, its
absence further prejudices Relator and heightens the need for expedited relief.
III. INTERNAL AUDIT REPORT 25-01 CORROBORATES RELATOR’S PROTECTED DISCLOSURES
GLO’s Internal Audit Report No. 25-01, completed in sometime in
September 2025 and transmitted to the Office of the Governor, the Legislative
Budget Board, the State Auditor’s Office, and not shared to Relator documents
systemic deficiencies, including:
• Inadequate training
• Documentation failures
• Monitoring noncompliance
• Procurement irregularities
• Weak internal controls
• Undefined roles and responsibilities
The above findings mirror the deficiencies Relator documented and shared
with Grant Management and Internal Audit Director prior to her termination
summarized in TAB J and TAB K referenced in her pending mandamus. Those
materials were also submitted to the trial court with Relator’s Second Amended
Petition, which GLO has refused to answer the petition.
IV. ADDITIONAL GROUNDS DEMONSTRATING THE NEED FOR EXPEDITED REVIEW
A. GLO’s Litigation Position Conflicts With Mandatory Audit Standards and Its Own QAIP Framework
Relator provides this additional context to demonstrate why expedited
review is necessary and why GLO’s litigation posture is inconsistent with its own
internal-audit obligations.
1. Audit Standards (AS) 1311 Requires Internal Self-Assessments and Ongoing Monitoring
The FY2023 Internal Audit Quality Assurance and Improvement Program
(QAIP) Report, addressed to Commissioner Dawn Buckingham on October 9,
2023, confirms that GLO is required to conduct ongoing internal-audit monitoring
and periodic self-assessments. Exhibit 1- FY2023 QAIP Report at pages 1–4, where
the report describes:
a. Continuous monitoring of internal audit activities;
b. Periodic internal self-assessments;
c. Evaluation of conformance with internal-audit standards;
d. Documentation of internal processes and audit performance; and
e. Communication of periodic assessment results to GLO leadership.
Critically, page 4 of the QAIP Report expressly restates the requirements of the
Institute of Internal Audit Attribute Standard 1311, confirming that internal
assessments “must include ongoing monitoring of the performance of the internal
audit activity” and “periodic self-assessment or assessments by other persons
within the organization with sufficient knowledge of internal audit practices.”
2. GLO’s QAIP Reports Acknowledge and Operationalize AS 1311 Requirements
Across pages 1–6, the FY2023 and FY2022 QAIP Reports demonstrates that GLO:
a. Performs internal self-assessments annually;
b. Conducts ongoing monitoring through weekly meetings with audit teams;
c. Tracks performance, documentation, audit plans, and fieldwork;
d. Uses formal internal-audit policies and procedures; and
e. Performs post-audit analyses and status reporting.
These processes mirror the specific internal-audit functions that Relator
repeatedly reported as deficient within CDR Grant Management—specifically
documentation, oversight, internal controls, and monitoring. Exhibit 1- FY2023
and Exhibit 2 - QAIP Reports
3. GLO’s Interrogatory Response Contradicts These Published Requirements
In sworn discovery responses, GLO claimed that CDR–Grant Management
personnel were “not required” to conduct internal self-assessments. This is
contradictory with:
• AS 1311’s explicit requirement for periodic self-assessments;
• GLO’s own published QAIP processes confirming the same; and
• The responsibilities assigned to CDR oversight personnel, including senior
management, regional managers, and senior grant managers.
The contradiction is not minor. It demonstrates that GLO’s litigation
narrative—framing deficiencies as performance issues or managerial
disagreement—is incompatible with:
• External audit standards (AS 1311),
• Internal agency publications (FY2023 QAIP Report), and
• GLO’s Internal Audit Report No. 25-01’s conclusion that the deficiencies
were systemic, and not performance issues.
4. These Contradictions Reinforce Why Expedited Review Is Necessary
The inconsistencies between GLO’s sworn assertions and its own QAIP
framework:
• Confirm Relator’s disclosures were accurate and grounded in established
audit expectations;
• Demonstrate that deficiencies were structural and agency-wide, not
individual;
• Show that GLO’s litigation posture is at odds with its documented practices;
• Reinforce that continued delay allows GLO to benefit from procedural
paralysis; and
• Support expedited review because the underlying issues are no longer
factually disputed.
Together, these contradictions underscore why Relator faces ongoing
prejudice and why void-order issues must be addressed promptly2.
Required TRAP 52.7 Disclaimer
Relator does not submit these publicly available QAIP publications as
evidence for purposes of the mandamus record. They are referenced solely to
demonstrate inconsistencies in GLO’s litigation posture and the systemic nature of
the deficiencies corroborated by GLO’s Internal Audit Report No. 25-01.
2 Internal Audit Report No. 25-01 identifies systemic deficiencies in documentation, monitoring, and internal controls—each of which corresponds to the exact oversight functions that AS 1311- required internal assessments are designed to evaluate. See FY2023 QAIP Report, pp. 3–4 (detailing ongoing monitoring, self-assessment requirements, documentation review, audit-status monitoring, and continuous quality-review procedures). These alignment points further corroborate Relator’s disclosures and contradict GLO’s sworn assertion that no such oversight duties applied to CDR personnel.
V. PRAYER
Relator respectfully prays that the Court grant this Motion to Expedite,
expedite consideration of the pending Petition for Writ of Mandamus, and grant
such other relief to which Relator may be justly entitled.
Respectfully submitted,
/s/ Cedric M. Scott
Cedric M. Scott, PhD Relator, Pro Se Email: cedricscott41@gmail.com
Date: December 9, 2025
CERTIFICATE OF CONFERENCE
Pursuant to Texas Rule of Appellate Procedure 10.1(a)(5), Relator certifies
that a conference regarding this Motion to Expedite was impracticable because this
is an original mandamus proceeding and the Respondent Judge does not participate
in such matters. Additionally, the relief sought is procedural and time-sensitive, and
the Real Party in Interest has not answered Relator’s Second Amended Petition
which raises additional issues requiring judicial resolution, and the underlying case
remains unable to proceed due to the absence of a successor judge; therefore,
consultation would not eliminate the need for court intervention. Accordingly, this
motion is submitted without conference.
s/ Cedric M. Scott Cedric M. Scott, PhD
Relator, Pro Se
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing Relator’s Motion to Expedite
Consideration of Pending Petition for Writ of Mandamus was served on counsel
for the Real Party in Interest, in accordance with Texas Rule of Appellate Procedure
9.5, on December 9, 2025 by electronic service (e-Filing).
Counsel for the General Land Office
Sara Labashosky State Bar No. 24129467 slabashosky@bickerstaff.com
Gunnar P. Seaquist State Bar No. 24043358 gseaquist@bickerstaff.com
Bickerstaff Heath Delgado Acosta LLP 3711 S. MoPac Expressway Building One, Suite 300 Austin, Texas 78746 (512) 472-8021
/s/ Cedric M. Scott Cedric M. Scott, PhD
Relator, Pro Se
IN THE FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS
Case No. 15-25-00227-CV (Transferred from the Third Court of Appeals)
IN RE CEDRIC M. SCOTT, PhD, Relator, Pro Se
Original Proceeding from Cause No. D-1-GN-25-000006 250th Judicial District Court, Travis County, Texas
EXHIBIT 1 - GLO FY2023 INTERNAL AUDIT QUALITY ASSURANCE AND IMPROVEMENT PROGRAM (QAIP) REPORT
(Referenced in Section IV of Relator’s Motion to Expedite) Submitted by: Cedric M. Scott, PhD Relator, Pro Se
Date: October 31, 2022
To: George P. Bush, Commissioner Mark Havens, Chief Clerk
From: Tracey Hall, Chief Auditor
Subject: 2022 Annual Report on the Internal Audit, Quality Assurance and Improvement Program
______________________________________________________________________________
The following report is presented in accordance with the Institute of Internal Auditors’(IIA) International Standards for the Professional Practice of Internal Auditing (Standards) and with the U.S. Government Accountability Office’s Government Auditing Standards, commonly referred to as generally accepted government auditing standards (GAGAS), both of which require internal audit divisions to develop and maintain a Quality Assurance and Improvement Program (QAIP) that includes both internal and external assessments of internal audit.
The objective of the internal and external assessments is to evaluate the internal audit activity’s conformance with the definition of internal auditing, the Standards, and the IIA Code of Ethics. The Standards require the results of these periodic assessments to be communicated to those charged with governance at least annually.
The Office of Internal Audit, for the Texas General Land Office (GLO) and Veterans Land Board (VLB), maintains an ongoing QAIP and performs ongoing monitoring of the quality of internal audit activities as well as periodic reviews performed through self-assessment and external quality assessment reviews.
This report and the detailed results that follow are intended to satisfy both sets of Standards by demonstrating that an internal assessment was performed, listing all the relevant IIA and GAO requirements, and indicating the evidence of compliance with each requirement. The Office of Internal Audit successfully passed its external quality assessment in June 2021. The Office of Internal Audit will undergo its next external quality assessment in 2024 (see Appendix for excerpts from the 2021 External Quality Assurance Review).
If you have questions or comments about this report, please contact me at (512) 463-6078.
22022 Annual Report on the GLO Internal Audit - Quality Assurance and Improvment Program
_______________________________________________________________________________________________________________________________________________________________________________
DETAILED RESULTS:
Standard No. Requirement(s) Evidence of Compliance and Title
IIA AS 1300 1, The chief audit executive (CAE, also referred to as The Internal Audit (IA) Policies and Procedures Manual has been developed Quality the Chief Auditor) must develop and maintain a and maintained on the IA shared drive. It is updated as needed, at a minimum Assurance and quality assurance and improvement program that of at least every three years with the most recent revision conducted in July Improvement covers all aspects of the internal audit activity. 2022. Program A General Audit Program that consists of detailed procedures for ensuring compliance with the Standards, GAGAS, IA policies and procedures, and applicable legal and regulatory requirements are utilized during every audit engagement.
A Quality Control (QC) Reviewer, an auditor external to the project, is assigned to every audit and performs review of all audit work papers to ensure their integrity, compliance, and satisfaction of the Standards, GAGAS and audit objectives.
The Chief Auditor reviews and approves audit objectives, plans, testing programs, and reports for all audit engagements.
In its Annual Report on the GLO Internal Audit – QAIP, IA staff reviews the Standards and GAGAS for any updates to ensure the department’s QAIP is current and complies with all applicable requirements.
1 The Institute of Internal Auditors’ (IIA) International Professional Practices Framework (IPPF, commonly referred to as the Red Book) is the conceptual framework that organizes authoritative
guidance promulgated by the IIA. Conformance with The IIA’s International Standards for the Professional Practice of Internal Auditing (Standards) is essential in meeting the responsibilities of internal auditors and the internal audit activity. The structure of the Standards is divided between Attribute and Performance Standards. Attribute Standards (AS) address the attributes of organizations and individuals performing internal auditing. The Performance Standards (PS) describes the nature of internal auditing and provides quality criteria against which the performance of the services can be measured. The Attribute and Performance Standards are provided to apply to all internal audit services.
32022 Annual Report on the GLO Internal Audit - Quality Assurance and Improvment Program
_______________________________________________________________________________________________________________________________________________________________________________
Standard No. Requirement(s) Evidence of Compliance and Title
IIA AS 1310, The quality assurance and improvement program must A QC Reviewer is assigned to every engagement to perform an internal Requirements include both internal and external assessments. review of all work papers to ensure adherence to the Standards, GAGAS, of the Quality and applicable legal and regulatory requirements. Assurance and Improvement The Chief Auditor reviews and approves key audit plans, documents and Program samples of the QC work performed.
An external Quality Assurance Review (QAR) 2 is obtained every 3 years and performed by peers of the IA function. The QAR was last completed in June 2021 (see Appendix for excerpts from the 2021 External Quality Assurance Review). IA will undergo its next QAR in 2024.
2 The IIA's International Professional Practices Framework (IPPF), the U.S. Government Accountability Office’s (GAO) Government Auditing Standards (known as the Yellow Book), commonly
referred to as generally accepted government auditing standards (GAGAS), and the Texas Internal Auditing Act (the Act) require that IA functions obtain external quality assurance reviews to assess compliance with Standards and the Act and to appraise the quality of their operations. GAGAS require these reviews at least every three years. A periodic external quality assurance review, or peer review, of the IA function is an essential part of a comprehensive quality assurance program. If the QAR is successfully fulfilled (passed) the Chief Auditor may state that the internal audit activity conforms with the International Standards for the Professional Practice of Internal Auditing only if the results of the quality assurance and improvement program support such a statement (IIA AS 1321).
42022 Annual Report on the GLO Internal Audit - Quality Assurance and Improvment Program
_______________________________________________________________________________________________________________________________________________________________________________
Standard No. Requirement(s) Evidence of Compliance and Title
IIA AS 1311, Internal assessments must include: The QC Reviewer for each audit reviews and signs off on every audit Internal working paper to ensure completeness and compliance with the Standards.
Ongoing monitoring of the performance of the Assessments internal audit activity.
The Chief Auditor meets with each audit team at least monthly or as needed Periodic self-assessment or assessments by other to discuss the status of the audit and potential issues.
persons within the organization with sufficient knowledge of internal audit practices.
Time and resources for each audit are tracked by audit phase regarding to planning the audit, performing fieldwork, reporting, and quality control and supervisory review.
Auditors communicate to management through a project status report and with the Chief Auditor on an ongoing basis throughout the audits, identifying work performed and potential audit issues.
The Chief Auditor monitors the status of the Annual Internal Audit Plan and notifies the Deputy Land Commissioner/Chief Clerk of any deviations or recommended changes.
At the conclusion of every project, auditors complete a post audit analysis to communicate the quality of ongoing performance and any follow-up action needed to ensure appropriate improvements are implemented within the audit process.
The Chief Auditor reviews key documents, including the audit plan, objectives, audit program, summary memo, and draft report.
The Chief Auditor reviews a sample of work for each audit to ensure the quality of the QC review function.
Customer Surveys are distributed to auditee management and other employees by the Chief Auditor immediately following the issuance of each audit report.
A comparison of budget-to-actual hours spent is conducted for all audits.
52022 Annual Report on the GLO Internal Audit - Quality Assurance and Improvment Program
_______________________________________________________________________________________________________________________________________________________________________________
Standard No. Requirement(s) Evidence of Compliance & Title
IIA AS 1312, External assessments must be conducted at least once The Texas Internal Auditing Act (Act) requires internal auditors to comply External every five years by a qualified, independent assessor with the Act as well as IIA and GAO Standards, including the IIA Code of Assessments or assessment team from outside the organization. The Ethics. IA follows the more restrictive requirement for external peer reviews, chief audit executive must discuss with the board: which is every three years.
The form and frequency of external assessment.
The engagement letter for the external Quality Assurance Review (QAR), The qualifications and independence of the signed by the Deputy Land Commissioner/Chief Clerk, addresses the external assessor or assessment team, including qualifications and independence of the external review team members, any potential conflict of interest.
including any potential conflicts of interest.
IIA AS 1320, The chief audit executive must communicate the The Chief Auditor prepares a report on the results of the Quality Assurance Reporting on results of the quality assurance and improvement and Improvement Program (QAIP) annually and distributes it to the the Quality program to senior management and the board. Commissioner and the Deputy Land Commissioner/Chief Clerk. Assurance and Disclosure should include: Improvement The results of the Quality Assurance and Improvement Program include the The scope and frequency of both the internal and Program results of both internal and external assessments.
external assessments.
The qualifications and independence of the An external Quality Assurance Review (QAR) is obtained every 3 years and assessor(s) or assessment team, including performed by peers of the IA function. The QAR was last completed in June potential conflicts of interest.
Conclusions of assessors. 2021 (see Appendix for excerpts from the 2021 External Quality Corrective action plans. Assurance Review). IA will undergo its next QAR in 2024.
The final report on the external Quality Assurance Review (QAR) is communicated to the Commissioner, the reporting authority of the Chief Auditor, and to the Deputy Land Commissioner/Chief Clerk. The 2021 QAR report was provided to them in June 2021.
62022 Annual Report on the GLO Internal Audit - Quality Assurance and Improvment Program
_______________________________________________________________________________________________________________________________________________________________________________
Standard No. Requirement(s) Evidence of Compliance and Title
IIA AS 1321, Use Indicating that the internal audit activity conforms The IA activities conform with the IIA Code of Ethics and the Standards. of “Conforms with the International Standards for the Professional with the Practice of Internal Auditing is appropriate only if The results of the Quality Assurance and Improvement Program include the International supported by the results of the quality assurance and results of both internal and external assessments (see Standard No. IIA AS Standards for the improvement program. 1320 for details). Professional Practice of Internal Auditing”
IIA AS 1322, When nonconformance with the Code of Ethics or The IA activities conform with the IIA Code of Ethics and the Standards. Disclosure of the Standards impacts the overall scope or operation Nonconformance of the internal audit activity, the chief audit executive The results of the Quality Assurance and Improvement Program include the must disclose the nonconformance and the impact to results of both internal and external assessments of which any nonsenior management and the board. conformance was addressed. (see Standard No. IIA AS 1320 for details).
GAGAS 5.02, An audit organization conducting engagements in The Chief Auditor has established a system of quality control designed to Quality Control accordance with GAGAS must establish and provide reasonable assurance of compliance with the Standards, and legal and Assurance maintain a system of quality control that is designed and regulatory requirements (see Standard No. IIA AS 1300 for details).
to provide the audit organization with reasonable assurance that the organization and its personnel An external Quality Assurance Review (QAR) is obtained every 3 years comply with professional standards and applicable and performed by peers of the IA function. The QAR was last completed in legal and regulatory requirements. June 2021 (see Appendix for excerpts from the 2021 External Quality Assurance Review). IA will undergo its next QAR in 2024.
72022 Annual Report on the GLO Internal Audit - Quality Assurance and Improvment Program
_______________________________________________________________________________________________________________________________________________________________________________
Standard No. Requirement(s) Evidence of Compliance & Title
GAGAS 5.04, An audit organization should document its quality The IA Policies and Procedures Manual includes sections on: System of control policies and procedures and communicate Quality those policies and procedures to its personnel. The Rules and Regulations that IA is required to follow Control audit organization should document compliance with Internal Auditing Standards (IIA and GAO, including the IIA Code of its quality control policies and procedures and Ethics) maintain such documentation for a period of time Working Paper Standards sufficient to enable those performing monitoring Principles and Rules of Conduct procedures and peer reviews to evaluate the extent to Independence and Objectivity which the audit organization complies with its quality Conflict of Interest control policies and procedures. Confidentiality
IA completes an annual assessment of its Quality Assurance and Improvement Program (QAIP). The resulting report is provided to Executive Management.
All internal auditors are required to complete annual independence statements that include any possible impairment to their independence regarding any auditable program of the agency.
Each individual audit requires all assigned audit team members to complete an independence statement, assess and report on any actual and potential independence issues.
All evidence of quality control reviews is documented by signoffs and coaching notes within the audit in the TeamMate auditing software.
The IA Policies and Procedures Manual requires all working papers for audits and other projects to be retained in accordance with the State of Texas Records Retention Schedule for a period of seven fiscal years after the final report is issued.
82022 Annual Report on the GLO Internal Audit - Quality Assurance and Improvment Program
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Standard No. Requirement(s) Evidence of Compliance and Title
GAGAS 5.05, The audit organization should establish policies and The IA Policies and Procedures Manual provides detailed information about Leadership procedures on leadership responsibilities for quality how to perform and document audit planning, fieldwork, and reporting. Responsibilities within the audit organization that include designating for Quality responsibility for quality of engagements conducted The IA shared drive and TeamMate Team Store contain many forms and within the in accordance with GAGAS and communicating templates for internal auditors to use to help ensure engagements are Audit policies and procedures relating to quality.
performed in accordance with the Standards, and legal and regulatory Organization requirements.
GAGAS 5.06, The audit organization should establish policies and The IA Policies and Procedures Manual state that all Internal audit members Leadership procedures designed to provide reasonable assurance are expected to maintain an appropriate certification, such as Certified Responsibilities that those assigned operational responsibility for the Public Accountant (CPA), Certified Internal Auditor (CIA), Certified for Quality audit organization’s system of quality control have Information Systems Auditor (CISA), Certified Fraud Examiner (CFE) or within the sufficient and appropriate experience and ability, and Certified Government Auditing Professional (CGAP). Audit the necessary authority, to assume that responsibility. Organization All IA members have relevant experience and degrees and/or professional certifications.
The IA Policies and Procedures Manual includes requirements from the Texas Internal Auditing Act (Texas Government Code 2102.006(b)) that the Chief Audit Executive must be a Certified Public Accountant or Certified Internal Auditor and have at least three years of auditing experience.
GAGAS 5.08, The audit organization should establish policies and The IA Policies and Procedures Manual section on the IA Quality Assurance Independence, procedures on independence and legal and ethical and Improvement Program details many of the components that help ensure Legal, and requirements that are designed to provide reasonable auditors perform quality work and specifies that the QC Reviewer and the Ethical assurance that the organization and its personnel Chief Auditor monitor the quality of their work. Requirements maintain independence and comply with applicable legal and ethical requirements. All internal auditors are required to complete annual independence statements that include any possible impairment to their independence regarding any auditable program of the agency.
The Chief Auditor considers any potential conflicts of interest in determining audit assignments.
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Standard No. Requirement(s) Evidence of Compliance and Title
GAGAS 5.09, At least annually, the audit organization should obtain All internal auditors are required to complete annual independence Independence, written affirmation of compliance with its policies and statements that include any possible impairment to their independence Legal, and procedures on independence from all of its personnel regarding any auditable program of the agency. Ethical required to be independent. Requirements Each individual audit requires all assigned audit team members to complete an independence statement to assess and report on any actual and potential independence issues.
The Chief Auditor considers any potential conflicts of interest in determining audit assignments. The Chief Auditor will determine the appropriate actions to maintain independence in conducting internal audit work. Possible actions include but are not limited to assigning the auditor only to projects where independence is not an issue, reassigning the auditor to another project or to other tasks within the project, or increased supervision. The Chief Auditor must document these actions.
GAGAS 5.12, The audit organization should establish policies and IA ensures current policies and procedures for the initiation, acceptance and Initiation, procedures for the initiation, acceptance, and continuance of audits are designed to provide reasonable assurance that the Acceptance, continuance of engagements that are designed to IA function will continually conduct only audits in which it can ensure and provide reasonable assurance that the organization compliance with professional standards, legal requirements, and ethical Continuance of will undertake engagements only if it: principles and that it is acting within the legal mandate or authority of the Engagements audit organization.
a. complies with professional standards, applicable legal and regulatory requirements, and ethical The IA function performs an extensive risk assessment process of the principles;
agency programs annually in order to select relevant audits that add value to b. acts within its legal mandate or authority; and the agency having been identified by areas of potential risk. An annual audit c. has the capabilities, including time and resources, plan is developed from the risk assessment which takes into consideration to do so.
the available audit resources. IA has developed and maintained an IA Policies and Procedures Manual. All IA members have relevant experience and degrees and/or professional certifications.
Time budgets are established during the scoping phase of the audit and budget-to-actual-hours reports are completed during all audits.
102022 Annual Report on the GLO Internal Audit - Quality Assurance and Improvment Program
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Standard No. Requirement(s) Evidence of Compliance and Title
GAGAS 5.15, The audit organization should establish policies and The IA Policies and Procedures Manual state that all Internal audit members Human procedures for human resources that are designed to are expected to maintain an appropriate certification, such as Certified Resources provide the organization with reasonable assurance Public Accountant (CPA), Certified Internal Auditor (CIA), Certified that it has personnel with the competence to conduct Information Systems Auditor (CISA), Certified Fraud Examiner (CFE) or GAGAS engagements in accordance with Certified Government Auditing Professional (CGAP). professional standards and applicable legal and regulatory requirements. All IA members have relevant experience, degrees and/or professional certifications.
GAGAS 5.16, The audit organization should establish policies and The IA Policies and Procedures Training Policy requires auditors to Human procedures to provide reasonable assurance that complete 80 hours of continuing professional education (CPE) within a two- Resources auditors who are performing work in accordance with year period, with at least forty hours completed each year. Of the eighty GAGAS meet the continuing professional education hours required for a two-year period, twenty-four hours should be in (CPE) requirements, including maintaining government-related subjects, and two hours of Ethics. documentation of the CPE completed and any exemptions granted. (Due to COVID-19 pandemic All Internal Auditors track CPE hours utilizing the Training Tracking Sheet GAGAS issued a CPE exception alert.) 3 to ensure each employee completes required hours of CPE each year.
GAGAS 5.22, The audit organization should establish policies and The IA Policies and Procedures Manual includes detailed requirements for Engagement procedures for engagement performance, work papers, documentation and reporting to be in conformance with the Performance documentation, and reporting that are designed to Standards and GAGAS.
provide the audit organization with reasonable assurance that engagements are conducted and reports Audits are reviewed at each stage of the audit, and the audit report is are issued in accordance with professional standards approved by the Chief Auditor prior to issuance. and applicable legal and regulatory requirements.
3 COVID-19: GAGAS CPE Alert effective February 29, 2020: https://www.gao.gov/yellowbook/overview
The GAO provides three exceptions to the GAGAS CPE requirements for circumstances related to the COVID-19 pandemic and clarification of an existing exemption: (1) For 2-year CPE periods that end February 29, 2020 through December 31, 2020, auditors who have not completed the 80-hour or the 24-hour CPE requirements for the 2-year period may have up to 6 months immediately following the 2-year period to make up the deficiency; (2) Auditors are not required to complete at least 20-hours of CPE for a 1-year CPE period that ends February 29, 2020 through December 31, 2020; and (3) From the audit organization’s 2-year period in effect on February 29, 2020, auditors may carry over up to 40 hours of CPE, in excess of the 80-hour requirement, to the next CPE measurement period. For 2-year CPE measurement periods ending after December 31, 2020, only CPE hours earned through December 31, 2020 may be carried over. Clarification of Existing GAGAS CPE Exemption: If the auditor is working, including teleworking, audit organizations and auditors may not use the exemption outlined in paragraph 4.29.
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Standard No. Requirement(s) Evidence of Compliance and Title
GAGAS 5.23, If auditors change the engagement objectives during The IA Policies and Procedures Manual include procedures on determining Engagement the engagement, they should document the revised audit objectives, staffing requirements, scheduling, time budgets, areas to be Performance engagement objectives and the reasons for the covered, detailed tests to be performed, and the extent to which a detailed changes. examination is to be conducted during the initial planning phase. Each audit requires an Audit Plan which identifies the objectives and scope of the engagement.
If there is a change in audit scope or objectives, the Chief Audit Executive will issue a “memo to file” to Executive Management and the program area being audited. The memo will provide justification for any changes in scope or objective. Any changes to an audit objective detailed in the Annual Internal Audit Plan require approval from the Commissioner.
GAGAS 5.24, The audit organization should establish policies and The IA Policies and Procedures Manual contains procedures on conducting Engagement procedures designed to provide it with reasonable consulting, management assistance, and special project engagements. The Performance assurance that: Chief Auditor will obtain approval from the Chief Clerk for projects that may require a significant number of hours to impact the projects in the a. appropriate consultation takes place on difficult Annual Audit Plan. If a report is applicable to the special project or or contentious issues that arise among consultation engagement, the Chief Auditor will provide the requestor a engagement team members in the course of report detailing the information gathered or observations made and will conducting a GAGAS engagement;
provide the report to executive management as appropriate.
b. both the individual seeking consultation and the individual consulted document and agree upon the nature and scope of such consultations; and c. the conclusions resulting from consultations are documented, understood by both the individual seeking consultation and the individual consulted, and implemented.
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Standard No. Requirement(s) Evidence of Compliance and Title
GAGAS 5.25, If an engagement is terminated before it is completed If an engagement is terminated before it is completed and an audit report is Engagement and an audit report is not issued, auditors should not issued, the Chief Audit Executive will issue a “memo to file” to Performance document the results of the work to the date of Executive Management and the program area being audited. The memo will termination and why the engagement was terminated. provide justification for terminating the engagement. Any changes to an audit objective detailed in the Annual Internal Audit Plan must be approved by the Commissioner.
GAGAS 5.36, The audit organization should establish policies and The IA Policies and Procedures Manual contains detailed Quality Control Engagement procedures that require engagement team members Review procedures required for each audit and establishes criteria for Performance with appropriate levels of skill and proficiency in acceptable working papers. Supervision auditing to supervise engagements and review work performed by other engagement team members. A QC Reviewer is assigned to every engagement to perform an internal review of and sign off on all work papers to ensure adherence to the Standards and applicable legal and regulatory requirements.
The Chief Auditor reviews and signs off on key working papers, including, but not limited to, the audit plan, audit program, and referenced draft report.
All IA members have relevant experience and degrees and/or professional certifications.
IA’s standard audit program in TeamMate includes a planning step in which management and the Chief Auditor selects audit team members based on an evaluation of team competencies and qualifications required to perform assigned roles for each project.
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Standard No. Requirement(s) Evidence of Compliance and Title
GAGAS 5.37, The audit organization should assign responsibility The Chief Auditor is assigned responsibility for each engagement and Engagement for each engagement to an engagement partner or reviews and signs off on key working papers, including, but not limited to, Performance director with authority designated by the audit the audit plan, audit program, and referenced draft report. The final report Supervision organization to assume that responsibility and should and management responses to corrective actions are reviewed and approved establish policies and procedures requiring the by the Chief Auditor. organization to:
The Chief Auditor meets with each audit team weekly to discuss the status a. communicate the identity and role of the of the audit and potential issues.
engagement partner or director to management and those charged with governance of the audited entity and b. clearly define the responsibilities of the engagement partner or director and communicate them to that individual.
GAGAS 5.42, The audit organization should establish policies and The IA function has policies and procedures that ensure the continued Monitoring of procedures for monitoring its system of quality monitoring of quality within the work performed by the IA function. Quality control.
This annual QAIP report constitutes the results of the annual internal quality assessment.
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Standard No. Requirement(s) Evidence of Compliance and Title
GAGAS 5.43, The audit organization should perform monitoring The IA function has policies and procedures that ensure the continued Monitoring of procedures that enable it to assess compliance with monitoring of quality within the work performed by the IA function. Quality professional standards and quality control policies and procedures for GAGAS engagements. Individuals This annual QAIP report constitutes the results of the annual internal quality performing monitoring should have sufficient assessment. expertise and authority within the audit organization.
An external Quality Assurance Review (QAR) is obtained every 3 years and performed by peers of the IA function. The QAR was last completed in June 2021 (see Appendix for excerpts from the 2021 External Quality Assurance Review). IA will undergo its next QAR in 2024.
The IA Policies and Procedures Manual state that all Internal audit members are expected to maintain an appropriate certification, such as Certified Public Accountant (CPA), Certified Internal Auditor (CIA), Certified Information Systems Auditor (CISA), Certified Fraud Examiner (CFE) or Certified Government Auditing Professional (CGAP).
All IA members have relevant experience and degrees and/or professional certifications.
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Standard No. Requirement(s) Evidence of Compliance and Title
GAGAS 5.44, The audit organization should analyze and summarize The IA function has policies and procedures that ensure the continued Monitoring of the results of its monitoring process at least annually, monitoring of quality within the work performed by the IA function. Quality with identification of any systemic or repetitive issues needing improvement, along with recommendations This annual QAIP report constitutes the results of the annual internal quality for corrective action. The audit organization should assessment. Process improvement recommendations noted in the QAIP communicate to the relevant engagement partner or report will be considered during the next update of the IA Policies and director, and other appropriate personnel, any Procedures Manual. deficiencies noted during the monitoring process and recommend appropriate remedial action. This communication should be sufficient to enable the audit organization and appropriate personnel to take prompt corrective action related to deficiencies, when necessary, in accordance with their defined roles and responsibilities. Information communicated should include the following:
a. a description of the monitoring procedures performed; b. the conclusions reached from the monitoring procedures; and c. when relevant, a description of systemic, repetitive, or other deficiencies and of the actions taken to resolve those deficiencies.
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Standard No. Requirement(s) Evidence of Compliance and Title
GAGAS 5.45, The audit organization should evaluate the effects of During its annual Quality Assurance and Improvement Program assessment, Monitoring of deficiencies noted during monitoring of the audit IA evaluates existing policies, procedures, and processes to note any Quality organization’s system of quality control to determine deficiencies and review compliance with professional standards and and implement appropriate actions to address the applicable legal and regulatory requirements. Process improvement deficiencies. This evaluation should include recommendations noted in the QAIP report will be considered during the assessments to determine if the deficiencies noted next update of the IA Policies and Procedures Manual. indicate that the audit organization’s system of quality control is insufficient to provide it with The IA function has policies and procedures that ensure the continued reasonable assurance that it complies with monitoring of quality within the work performed by the IA function. professional standards and applicable legal and regulatory requirements, and that accordingly the An external Quality Assurance Review (QAR) is obtained every 3 years and reports that the audit organization issues are not performed by peers of the IA function. The QAR was last completed in June appropriate in the circumstances. 2021 (see Appendix for excerpts from the 2021 External Quality Assurance Review). IA will undergo its next QAR in 2024.
GAGAS 5.46, The audit organization should establish policies and The IA Policies and Procedures Manual requires all working papers for Monitoring of procedures that require retention of engagement audits and other projects to be retained in accordance with the State of Quality documentation for a period of time sufficient to Texas Records Retention Schedule for a period of seven fiscal years after permit those performing monitoring procedures and the final report is issued. peer review of the organization to evaluate its compliance with its system of quality control or for a longer period if required by law or regulation.
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Standard No. Requirement(s) Evidence of Compliance and Title
GAGAS 5.60, Each audit organization conducting engagements in An external Quality Assurance Review (QAR) is obtained every 3 years and External Peer accordance with GAAS must obtain an external peer performed by peers of the IA function. The QAR was last completed in June Review review conducted by reviewers independent of the 2021 (see Appendix for excerpts from the 2021 External Quality audit organization being reviewed. The peer review Assurance Review). IA will undergo its next QAR in 2024. 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 control was suitably designed and (2) the organization is complying with its quality control system so that it has reasonable assurance that it is performing and reporting in conformity with professional standards and applicable legal and regulatory requirements in all material respects.
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APPENDIX:
Excerpts of the 2021 External Quality Assurance Review of the Texas General Land Office, Office of Internal Audit
192022 Annual Report on the GLO Internal Audit - Quality Assurance and Improvment Program
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IN THE FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS
Case No. 15-25-00227-CV (Transferred from the Third Court of Appeals)
IN RE CEDRIC M. SCOTT, PhD, Relator, Pro Se
Original Proceeding from Cause No. D-1-GN-25-000006 250th Judicial District Court, Travis County, Texas
EXHIBIT 2 - GLO FY2022 INTERNAL AUDIT QUALITY ASSURANCE AND IMPROVEMENT PROGRAM (QAIP) REPORT
(Referenced in Section IV of Relator’s Motion to Expedite) Submitted by: Cedric M. Scott, PhD Relator, Pro Se
Date: October 9, 2023
To: Dawn Buckingham, M.D., Commissioner
From: Tracey Hall, Chief Auditor
cc: Jennifer Jones, Deputy Land Commissioner Mark Havens, Chief Clerk
Subject: 2023 Annual Report on the Internal Audit Quality Assurance and Improvement Program
______________________________________________________________________________
The following report is presented in accordance with the Institute of Internal Auditors’(IIA) International Standards for the Professional Practice of Internal Auditing (Standards) and with the U.S. Government Accountability Office’s Government Auditing Standards, commonly referred to as generally accepted government auditing standards (GAGAS), both of which require internal audit divisions to develop and maintain a Quality Assurance and Improvement Program (QAIP) that includes both internal and external assessments of internal audit.
The objective of the internal and external assessments is to evaluate the internal audit activity’s conformance with the definition of internal auditing, the Standards, and the IIA Code of Ethics. The Standards require the results of these periodic assessments to be communicated to those charged with governance at least annually.
The Office of Internal Audit for the Texas General Land Office (GLO) and Veterans Land Board (VLB) maintains an ongoing QAIP and performs continuous monitoring of the quality of internal audit activities, as well as periodic reviews conducted through self-assessment and external quality assessment reviews.
This report and the detailed results included are intended to satisfy both sets of Standards by demonstrating that an internal assessment was performed, listing all the relevant IIA and GAO requirements, and indicating the evidence of compliance with each requirement. The Office of Internal Audit successfully passed its external quality assessment in June 2021. The Office of Internal Audit will undergo its next external quality assessment in 2024 (see Appendix for excerpts from the 2021 External Quality Assurance Review).
If you have questions or comments about this report, please contact me at (512) 463-6078.
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DETAILED RESULTS:
Standard No. Requirement(s) Evidence of Compliance and Title
IIA AS 1300 1, The chief audit executive (CAE, also referred to as The Internal Audit (IA) Policies and Procedures Manual has been developed Quality the Chief Auditor) must develop and maintain a and maintained on the IA shared drive. It is updated as needed, at least every Assurance and quality assurance and improvement program that three years, with the most recent revision conducted in July 2022. Improvement covers all aspects of the internal audit activity. Program A General Audit Program comprising detailed procedures for ensuring compliance with the Standards, GAGAS, IA policies and procedures, and applicable legal and regulatory requirements are utilized during every audit engagement. These procedures include:
o Audit Team Competencies o Independence Statements o Project Planning Summaries o Project Risk Assessments and o Fieldwork programs
The Chief Auditor reviews and approves audit objectives, plans, testing programs, and reports for all audit engagements.
In its Annual Report on the GLO Internal Audit – QAIP, IA staff reviews the Standards and GAGAS for any updates to ensure the department’s QAIP is current and complies with all applicable requirements.
1 The Institute of Internal Auditors’ (IIA) International Professional Practices Framework (IPPF, commonly referred to as the Red Book) is the conceptual framework that organizes authoritative
guidance promulgated by the IIA. Conformance with The IIA’s International Standards for the Professional Practice of Internal Auditing (Standards) is essential in meeting the responsibilities of internal auditors and the internal audit activity. The structure of the Standards is divided between Attribute and Performance Standards. Attribute Standards (AS) address the attributes of organizations and individuals performing internal auditing. The Performance Standards (PS) describes the nature of internal auditing and provides quality criteria against which the performance of the services can be measured. The Attribute and Performance Standards are provided to apply to all internal audit services.
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Standard No. Requirement(s) Evidence of Compliance and Title
IIA AS 1310, The quality assurance and improvement program must The IA Manager reviews all audit work papers to ensure their integrity, Requirements include both internal and external assessments. compliance, and satisfaction with the Standards, GAGAS, and audit of the Quality objectives. Assurance and Improvement The IA Manager and the Chief Auditor review and approve key audit plans, Program documents, and samples of the QC work performed.
An external Quality Assurance Review (QAR) 2 is obtained every three years and performed by peers of the IA function. The QAR was last completed in June 2021 (see Appendix for excerpts from the 2021 External Quality Assurance Review). IA will undergo its next QAR in 2024.
2 The IIA's International Professional Practices Framework (IPPF), the U.S. Government Accountability Office’s (GAO) Government Auditing Standards (known as the Yellow Book), commonly
referred to as generally accepted government auditing standards (GAGAS), and the Texas Internal Auditing Act (the Act) require that IA functions obtain external quality assurance reviews to assess compliance with Standards and the Act and to appraise the quality of their operations. GAGAS require these reviews at least every three years. A periodic external quality assurance review, or peer review, of the IA function is an essential part of a comprehensive quality assurance program. If the QAR is successfully fulfilled (passed) the Chief Auditor may state that the internal audit activity conforms with the International Standards for the Professional Practice of Internal Auditing only if the results of the quality assurance and improvement program support such a statement (IIA AS 1321).
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Standard No. Requirement(s) Evidence of Compliance and Title
IIA AS 1311, Internal assessments must include: The IA Manager for each audit reviews and signs off on every audit Internal working paper to ensure completeness and compliance with the Standards.
Ongoing monitoring of the performance of the Assessments internal audit activity.
The Chief Auditor and IA Manager meet with each audit team weekly, Periodic self-assessment or assessments by other based on the Agile audit process, to discuss the audit status and potential persons within the organization with sufficient issues.
knowledge of internal audit practices.
Time and resources for each audit are tracked by the audit phase regarding planning the audit, assessing risk, performing fieldwork, reporting, and quality control and supervisory review.
Auditors communicate to management through a project status report and with the Chief Auditor continuously throughout the audits, identifying work performed and potential audit issues.
The Chief Auditor monitors the status of the Annual Internal Audit Plan and notifies the Commissioner and Chief Clerk of any deviations or recommended changes.
After every project, auditors complete a post-audit analysis to communicate ongoing performance quality and any follow-up action needed to implement appropriate improvements within the audit process.
The Chief Auditor and IA Manager review key documents, including the audit plan, objectives, audit program, summary memo, and draft report.
The Chief Auditor and IA Manager review work for each audit to ensure the quality of the QC review function.
Customer Surveys are distributed to auditee management and other employees by the Chief Auditor immediately following the issuance of each audit report.
A comparison of budget-to-actual hours spent is conducted for all audits.
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Standard No. Requirement(s) Evidence of Compliance & Title
IIA AS 1312, External assessments must be conducted at least once The Texas Internal Auditing Act (Act) requires internal auditors to comply External every five years by a qualified, independent assessor with the Act and IIA and GAO Standards, including the IIA Code of Ethics. Assessments or assessment team from outside the organization. The IA follows the more restrictive requirement for external peer reviews every chief audit executive must discuss the following with three years. the board:
The engagement letter for the external Quality Assurance Review (QAR), The form and frequency of external assessment.
signed by the Chief Clerk, addresses the qualifications and independence of The qualifications and independence of the the external review team members, including any potential conflicts of external assessor or assessment team, including interest.
any potential conflict of interest.
IIA AS 1320, The chief audit executive must communicate the The Chief Auditor annually prepares a report on the Quality Assurance and Reporting on results of the quality assurance and improvement Improvement Program (QAIP) results and distributes it to the Commissioner the Quality program to senior management and the board. and Chief Clerk. Assurance and Disclosure should include: Improvement The results of the Quality Assurance and Improvement Program include the The scope and frequency of both the internal and Program results of both internal and external assessments.
external assessments.
The qualifications and independence of the An external Quality Assurance Review (QAR) is obtained every three years assessor(s) or assessment team, including and performed by peers of the IA function. The QAR was last completed in potential conflicts of interest.
Conclusions of assessors. June 2021 (see Appendix for excerpts from the 2021 External Quality Corrective action plans. Assurance Review). IA will undergo its next QAR in 2024.
The final report on the external Quality Assurance Review (QAR) is communicated to the Commissioner and Chief Clerk, the reporting authority of Internal Audit. The 2021 QAR report was provided to them in June 2021.
62023 Annual Report on the GLO Internal Audit - Quality Assurance and Improvment Program
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Standard No. Requirement(s) Evidence of Compliance and Title
IIA AS 1321, Use Indicating that the internal audit activity conforms The IA activities conform with the IIA Code of Ethics and the Standards. of “Conforms with the International Standards for the Professional with the Practice of Internal Auditing is appropriate only if The Quality Assurance and Improvement Program results include internal International supported by the results of the quality assurance and and external assessments (see Standard No. IIA AS 1320 for details). Standards for the improvement program. Professional Practice of Internal Auditing”
IIA AS 1322, When non-conformance with the Code of Ethics or The IA activities conform with the IIA Code of Ethics and the Standards. Disclosure of the Standards impacts the overall scope or operation Nonconformance of the internal audit activity, the chief audit executive The Quality Assurance and Improvement Program includes the results of must disclose the nonconformance and the impact to internal and external assessments of which any non-conformance was senior management and the board. addressed. (See Standard No. IIA AS 1320 for details).
GAGAS 5.02, An audit organization conducting engagements in The Chief Auditor has established a system of quality control designed to Quality Control accordance with GAGAS must establish and provide reasonable assurance of compliance with the Standards and legal and Assurance maintain a system of quality control that is designed and regulatory requirements (see Standard No. IIA AS 1300 for details).
to provide the audit organization with reasonable assurance that the organization and its personnel An external Quality Assurance Review (QAR) is obtained every three comply with professional standards and applicable years and performed by peers of the IA function. The QAR was last legal and regulatory requirements. completed in June 2021 (see Appendix for excerpts from the 2021 External Quality Assurance Review). IA will undergo its next QAR in 2024.
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Standard No. Requirement(s) Evidence of Compliance & Title
GAGAS 5.04, An audit organization should document its quality The IA Policies and Procedures Manual includes sections on: System of control policies and procedures and communicate Quality those policies and procedures to its personnel. The Rules and Regulations that IA is required to follow Control audit organization should document compliance with Internal Auditing Standards (IIA and GAO, including the IIA Code of its quality control policies and procedures and Ethics) maintain such documentation for a period of time Working Paper Standards sufficient to enable those performing monitoring Principles and Rules of Conduct procedures and peer reviews to evaluate the extent to Independence and Objectivity which the audit organization complies with its quality Conflict of Interest control policies and procedures. Confidentiality
IA completes an annual assessment of its Quality Assurance and Improvement Program (QAIP). The resulting report is provided to Executive Management.
All internal auditors must complete annual independence statements that include any possible impairment to their independence regarding any auditable program of the agency.
Each audit requires all assigned audit team members to complete an independence statement assessing and reporting on any actual and potential independence issues.
Signoffs and coaching notes document all evidence of quality control reviews within the audit in the TeamMate auditing software.
The IA Policies and Procedures Manual requires all working papers for audits and other projects to be retained per the State of Texas Records Retention Schedule for seven fiscal years after the final report is issued.
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Standard No. Requirement(s) Evidence of Compliance and Title
GAGAS 5.05, The audit organization should establish policies and The IA Policies and Procedures Manual provides detailed information about Leadership procedures on leadership responsibilities for quality performing and documenting audit planning, fieldwork, and reporting. Responsibilities within the audit organization that include designating for Quality responsibility for quality of engagements conducted The IA shared drive and TeamMate Team Store contains many forms and within the in accordance with GAGAS and communicating templates for internal auditors to use to help ensure engagements are Audit policies and procedures relating to quality.
performed in accordance with the Standards and legal and regulatory Organization requirements.
GAGAS 5.06, The audit organization should establish policies and The IA Policies and Procedures Manual states that all Internal audit Leadership procedures designed to provide reasonable assurance members are expected to maintain an appropriate certification, such as Responsibilities that those assigned operational responsibility for the Certified Public Accountant (CPA), Certified Internal Auditor (CIA), for Quality audit organization’s system of quality control have Certified Information Systems Auditor (CISA), Certified Fraud Examiner within the sufficient and appropriate experience and ability, and (CFE) or Certified Government Auditing Professional (CGAP). Audit the necessary authority to assume that responsibility. Organization All IA members have relevant experience, degrees, and professional certifications.
The IA Policies and Procedures Manual includes requirements from the Texas Internal Auditing Act (Texas Government Code 2102.006(b)) that the Chief Audit Executive must be a Certified Public Accountant or Certified Internal Auditor and have at least three years of auditing experience.
GAGAS 5.08, The audit organization should establish policies and The IA Policies and Procedures Manual section on the IA Quality Assurance Independence, procedures on independence and legal and ethical and Improvement Program details many components that help ensure Legal, and requirements designed to provide reasonable auditors perform quality work and specifies that the IA Manager and the Ethical assurance that the organization and its personnel Chief Auditor monitor the quality of their work. Requirements maintain independence and comply with applicable legal and ethical requirements. All internal auditors are required to complete annual independence statements that include any possible impairment to their independence regarding any auditable program of the agency.
The Chief Auditor considers any potential conflicts of interest in determining audit assignments.
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Standard No. Requirement(s) Evidence of Compliance and Title
GAGAS 5.09, At least annually, the audit organization should obtain All internal auditors are required to complete annual independence Independence, written affirmation of compliance with its policies and statements that include any possible impairment to their independence Legal, and procedures on independence from all of its personnel regarding any auditable program of the agency. Ethical required to be independent. Requirements Each audit requires all assigned audit team members to complete an independence statement to assess and report on any actual and potential independence issues.
The Chief Auditor considers any potential conflicts of interest in determining audit assignments. The Chief Auditor will determine the appropriate actions to maintain independence in conducting internal audit work. Possible activities include but are not limited to assigning the auditor only to projects where independence is not an issue, reassigning the auditor to another project or other tasks within the project, or increased supervision. The Chief Auditor must document these actions.
GAGAS 5.12, The audit organization should establish policies and IA ensures current policies and procedures for the initiation, acceptance, and Initiation, procedures for the initiation, acceptance, and continuance of audits are designed to provide reasonable assurance that the Acceptance, continuance of engagements that are designed to IA function will continually conduct only audits in which it can ensure and provide reasonable assurance that the organization compliance with professional standards, legal requirements, and ethical Continuance of will undertake engagements only if it: principles and that it is acting within the legal mandate or authority of the Engagements audit organization.
a. complies with professional standards, applicable legal and regulatory requirements, and ethical The IA function performs an extensive risk assessment process of the principles;
agency programs annually to select relevant audits that add value to the b. acts within its legal mandate or authority; and agency having been identified by areas of potential risk. An annual audit c. has the capabilities, including time and resources, plan is developed from the risk assessment, which considers the available to do so.
audit resources. IA has developed and maintained an IA Policies and Procedures Manual. All IA members have relevant experience degrees and professional certifications.
Time budgets are established during the scoping phase of the audit, and budget-to-actual-hours reports are completed during all audits.
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Standard No. Requirement(s) Evidence of Compliance and Title
GAGAS 5.15, The audit organization should establish policies and The IA Policies and Procedures Manual states that all Internal audit Human procedures for human resources designed to provide members are expected to maintain an appropriate certification, such as Resources the organization with reasonable assurance that it has Certified Public Accountant (CPA), Certified Internal Auditor (CIA), personnel with the competence to conduct GAGAS Certified Information Systems Auditor (CISA), Certified Fraud Examiner engagements in accordance with professional (CFE) or Certified Government Auditing Professional (CGAP). standards and applicable legal and regulatory requirements. All IA members have relevant experience, degrees, and professional certifications.
GAGAS 5.16, The audit organization should establish policies and The IA Policies and Procedures Training Policy requires auditors to Human procedures to provide reasonable assurance that complete 80 hours of continuing professional education (CPE) within two Resources auditors who are performing work in accordance with years, with at least 40 hours completed each year. Of the eighty hours GAGAS meet the continuing professional education required for two years, twenty-four hours should be in government-related (CPE) requirements, including maintaining subjects and two hours of Ethics. documentation of the CPE completed and any exemptions granted. (Due to COVID-19 pandemic All Internal Auditors track CPE hours utilizing the Training Tracking Sheet GAGAS issued a CPE exception alert.) 3 to ensure each employee completes the required hours of CPE each year.
GAGAS 5.22, The audit organization should establish policies and The IA Policies and Procedures Manual includes detailed requirements for Engagement procedures for engagement performance, work papers, documentation, and reporting to be in conformance with the Performance documentation, and reporting that are designed to Standards and GAGAS.
provide the audit organization with reasonable assurance that engagements are conducted, and Audits are reviewed at each stage of the audit, and the audit report is reports are issued in accordance with professional approved by the Chief Auditor prior to issuance. standards and applicable legal and regulatory requirements.
3 COVID-19: GAGAS CPE Alert effective February 29, 2020: https://www.gao.gov/yellowbook/overview
The GAO provides three exceptions to the GAGAS CPE requirements for circumstances related to the COVID-19 pandemic and clarification of an existing exemption: (1) For 2-year CPE periods that end February 29, 2020 through December 31, 2020, auditors who have not completed the 80-hour or the 24-hour CPE requirements for the 2-year period may have up to 6 months immediately following the 2-year period to make up the deficiency; (2) Auditors are not required to complete at least 20-hours of CPE for a 1-year CPE period that ends February 29, 2020 through December 31, 2020; and (3) From the audit organization’s 2-year period in effect on February 29, 2020, auditors may carry over up to 40 hours of CPE, in excess of the 80-hour requirement, to the next CPE measurement period. For 2-year CPE measurement periods ending after December 31, 2020, only CPE hours earned through December 31, 2020 may be carried over. Clarification of Existing GAGAS CPE Exemption: If the auditor is working, including teleworking, audit organizations and auditors may not use the exemption outlined in paragraph 4.29.
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Standard No. Requirement(s) Evidence of Compliance and Title
GAGAS 5.23, If auditors change the engagement objectives during The IA Policies and Procedures Manual includes procedures on determining Engagement the engagement, they should document the revised audit objectives, staffing requirements, scheduling, time budgets, areas to be Performance engagement objectives and the reasons for the covered, detailed tests to be performed, and the extent to which a thorough changes. examination is to be conducted during the initial planning phase. Each audit requires an Audit Plan which identifies the objectives and scope of the engagement.
If there is a change in audit scope or objectives, the Chief Audit Executive will issue a “memo to file” to Executive Management and the program area being audited. The memo will provide justification for any changes in scope or objective. Any changes to an audit objective detailed in the Annual Internal Audit Plan require approval from the Commissioner.
GAGAS 5.24, The audit organization should establish policies and The IA Policies and Procedures Manual contains procedures for conducting Engagement procedures designed to provide it with reasonable consulting, management assistance, and special project engagements. The Performance assurance that: Chief Auditor will obtain approval from the Chief Clerk for projects that may require a significant number of hours to impact the projects in the a. appropriate consultation takes place on difficult Annual Audit Plan. If a report is applicable to the particular project or or contentious issues that arise among consultation engagement, the Chief Auditor will provide the requestor a engagement team members in the course of report detailing the information gathered or observations made and will conducting a GAGAS engagement;
provide the report to executive management as appropriate.
b. both the individual seeking consultation and the individual consulted document and agree upon the nature and scope of such consultations; and c. the conclusions resulting from consultations are documented, understood by both the individual seeking consultation and the individual consulted, and implemented.
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Standard No. Requirement(s) Evidence of Compliance and Title
GAGAS 5.25, If an engagement is terminated before it is completed If an engagement is terminated before it is completed and an audit report is Engagement and an audit report is not issued, auditors should not issued, the Chief Audit Executive will issue a “memo to file” to Performance document the results of the work to the date of Executive Management and the program area being audited. The memo will termination and why the engagement was terminated. provide justification for terminating the engagement. Any changes to an audit objective detailed in the Annual Internal Audit Plan must be approved by the Commissioner.
GAGAS 5.36, The audit organization should establish policies and The IA Policies and Procedures Manual contains detailed Quality Control Engagement procedures that require engagement team members Review procedures required for each audit and establishes criteria for Performance with appropriate levels of skill and proficiency in acceptable working papers. Supervision auditing to supervise engagements and review work performed by other engagement team members. The IA Manager performs an internal review of and sign off on all work papers for every engagement to ensure adherence to the Standards and applicable legal and regulatory requirements.
The Chief Auditor, along with the IA Manager, reviews and signs off on key working papers, including, but not limited to, the audit plan, audit program, and referenced draft report.
All IA members have relevant experience, degrees, and professional certifications.
IA’s standard audit program in TeamMate includes a planning step in which management and the Chief Auditor selects audit team members based on an evaluation of team competencies and qualifications required to perform assigned roles for each project.
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Standard No. Requirement(s) Evidence of Compliance and Title
GAGAS 5.37, The audit organization should assign responsibility The Chief Auditor is assigned responsibility for each engagement and Engagement for each engagement to an engagement partner or reviews and signs off on key working papers, including, but not limited to, Performance director with authority designated by the audit the audit plan, audit program, and referenced draft report. The Chief Auditor Supervision organization to assume that responsibility and should reviews and approves the final report and management responses to establish policies and procedures requiring the corrective actions. organization to:
The Chief Auditor and IA Manager meets with each audit team weekly to a. communicate the identity and role of the discuss the audit status and potential issues.
engagement partner or director to management and those charged with governance of the audited entity and b. clearly define the responsibilities of the engagement partner or director and communicate them to that individual.
GAGAS 5.42, The audit organization should establish policies and The IA function has policies and procedures that ensure the continued Monitoring of procedures for monitoring its quality control system. monitoring of quality within the work performed by the IA function. Quality This annual QAIP report constitutes the results of the annual internal quality assessment.
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Standard No. Requirement(s) Evidence of Compliance and Title
GAGAS 5.43, The audit organization should perform monitoring The IA function has policies and procedures that ensure the continued Monitoring of procedures that enable it to assess compliance with monitoring of quality within the work performed by the IA function. Quality professional standards and quality control policies and procedures for GAGAS engagements. Individuals This annual QAIP report constitutes the results of the annual internal quality performing monitoring should have sufficient assessment. expertise and authority within the audit organization.
An external Quality Assurance Review (QAR) is obtained every three years and performed by peers of the IA function. The QAR was last completed in June 2021 (see Appendix for excerpts from the 2021 External Quality Assurance Review). IA will undergo its next QAR in 2024.
The IA Policies and Procedures Manual states that all Internal audit members are expected to maintain an appropriate certification, such as Certified Public Accountant (CPA), Certified Internal Auditor (CIA), Certified Information Systems Auditor (CISA), Certified Fraud Examiner (CFE) or Certified Government Auditing Professional (CGAP).
All IA members have relevant experience, degrees, and professional certifications.
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Standard No. Requirement(s) Evidence of Compliance and Title
GAGAS 5.44, The audit organization should analyze and summarize The IA function has policies and procedures that ensure the continued Monitoring of the results of its monitoring process at least annually, monitoring of quality within the work performed by the IA function. Quality with the identification of any systemic or repetitive issues needing improvement, along with This annual QAIP report constitutes the results of the annual internal quality recommendations for corrective action. The audit assessment. Process improvement recommendations noted in the QAIP organization should communicate to the relevant report will be considered during the next update of the IA Policies and engagement partner or director and other appropriate Procedures Manual. personnel any deficiencies noted during the monitoring process and recommend appropriate remedial action. This communication should be sufficient to enable the audit organization and appropriate personnel to take prompt corrective action related to deficiencies, when necessary, in accordance with their defined roles and responsibilities. Information communicated should include the following:
a. a description of the monitoring procedures performed; b. the conclusions reached from the monitoring procedures; and c. when relevant, a description of systemic, repetitive, or other deficiencies and of the actions taken to resolve those deficiencies.
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Standard No. Requirement(s) Evidence of Compliance and Title
GAGAS 5.45, The audit organization should evaluate the effects of During its annual Quality Assurance and Improvement Program assessment, Monitoring of deficiencies noted during monitoring of the audit IA evaluates existing policies, procedures, and processes to note Quality organization’s system of quality control to determine deficiencies and review compliance with professional standards and and implement appropriate actions to address the applicable legal and regulatory requirements. Process improvement deficiencies. This evaluation should include recommendations noted in the QAIP report will be considered during the assessments to determine if the deficiencies noted next update of the IA Policies and Procedures Manual. indicate that the audit organization’s system of quality control is insufficient to provide it with The IA function has policies and procedures that ensure the continued reasonable assurance that it complies with monitoring of quality within the work performed by the IA function. professional standards and applicable legal and regulatory requirements and that, accordingly, the An external Quality Assurance Review (QAR) is obtained every three years reports that the audit organization issues are not and performed by peers of the IA function. The QAR was last completed in appropriate in the circumstances. June 2021 (see Appendix for excerpts from the 2021 External Quality Assurance Review). IA will undergo its next QAR in 2024.
GAGAS 5.46, The audit organization should establish policies and The IA Policies and Procedures Manual requires all working papers for Monitoring of procedures that require retention of engagement audits and other projects to be retained in accordance with the State of Quality documentation for a period of time sufficient to Texas Records Retention Schedule for a period of seven fiscal years after permit those performing monitoring procedures and the final report is issued. peer review of the organization to evaluate its compliance with its quality control system or for a longer period if required by law or regulation.
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Standard No. Requirement(s) Evidence of Compliance and Title
GAGAS 5.60, Each audit organization conducting engagements in An external Quality Assurance Review (QAR) is obtained every three years External Peer accordance with GAAS must obtain an external peer and performed by peers of the IA function. The QAR was last completed in Review review conducted by reviewers independent of the June 2021 (see Appendix for excerpts from the 2021 External Quality audit organization being reviewed. The peer review Assurance Review). IA will undergo its next QAR in 2024. 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 control was suitably designed and (2) the organization is complying with its quality control system so that it has reasonable assurance that it is performing and reporting in conformity with professional standards and applicable legal and regulatory requirements in all material respects.
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APPENDIX:
Excerpts of the 2021 External Quality Assurance Review of the Texas General Land Office, Office of Internal Audit
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Case Contacts
Name BarNumber Email TimestampSubmitted Status
Honorable Cory R.Liu 250.submission@traviscountytx.gov 12/9/2025 9:33:51 PM SENT
Jeffrey Moore jmoore@bickerstaff.com 12/9/2025 9:33:51 PM SENT
Sara Labashosky slabashosky@bickerstaff.com 12/9/2025 9:33:51 PM SENT
Gunnar Seaquist gseaquist@bickerstaff.com 12/9/2025 9:33:51 PM SENT
In Re Cedric M. Scott, PhD v. the State of Texas (In Re Cedric M. Scott, PhD v. the State of Texas) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.