SSAE 16 – Standards for Attestation Engagements No. 16

News and Information on SSAE 16, The New Standard for SAS 70's

If you have never been audited before, as is the case with many service organizations, you are probably wondering what kind of documentation will I need to give the auditors? What will they do with it once they have it?

A high level explanation per the SSAE 16 Guidance:

(1) access to all information, such as records and documentation, including service
level agreements, of which management is aware that is relevant to the
description of the service organization’s system and the assertion;
(2) additional information that the service auditor may request from management for
the purpose of the examination engagement;
(3) unrestricted access to personnel within the service organization from whom the
service auditor determines it is necessary to obtain evidence relevant to the
service auditor’s engagement; and
(4) written representations at the conclusion of the engagement

Basically, you must give up anything needed by the service auditor that will permit them to attest to “Management’s description of the service organization’s system”, the main change associated with SSAE 16.

Many of the controls at your organization will be reliant upon documents such as service level agreements and subservice organization’s SSAE 16 reports. Controls will also require you to pass off policies and procedures, organizational charts, job descriptions, firewall configurations, and other internal documentation.

The most intrusive part of the SSAE 16 Review is that the auditors will need to talk to any and all of the employees that have a role in performing the controls being tested. Without that access, it would be impossible for the auditors to have a clear understanding of the processes when testing your controls. However, this shouldn’t be viewed as a negative, it will help your employees improve their processes in the future by gaining tips and insight from the auditors that will help them be better prepared for next year’s audit. Also, it will help clear up any potential findings or issues the auditors find, as in many cases there is no problem and an explanation is all that is needed, making the audit go MUCH smoother.

All of the documentation and information provided will never be seen by anyone other than the auditors performing the testing. The documentation is needed for the service auditors to assess the design and operating effectiveness of your controls. Once the testing and review phases are complete, your report will be issued and all that will be included is whether you either passed or failed that control, so don’t worry!



If you have any questions feel free to leave them in the comments section below and we will do our best to respond!

Click Here to Find a Professional CPA Firm to Perform Your SSAE 16

SSAE 16 was built upon the ISAE 3402 framework, which essentially is the same thing but accepted at an international level, with a number of deviations which will be discussed here over time. The AICPA and other standard settings organizations are now encouraged to design their frameworks for reporting on controls at a service organization around the ISAE 3402 framework, this will allow for increased fluidity and lower expenses to complete globally. ISAE 3402 was intentionally designed to allow for minor modifications to adjust for local protocols and existing frameworks.

SSAE 16 contains 9 deviations from the ISAE 3402 framework, at a high level include:

1. Intentional Acts by Service Organization Personnel
2. Anomalies
3. Direct Assistance
4. Subsequent Events
5. Statement Restricting Use of the Service Auditor’s Report
6. Documentation Completion
7. Engagement Acceptance and Continuance
8. Disclaimer of Opinion
9. Elements of the SSAE Report That are Not Required in the ISAE 3402 Report

These topics will be delved into in greater depth at a later time, however, are not of concern if you do not plan on performing outsourcing services for an organization located outside of the United States.

Click Here to Find a Professional CPA Firm to Perform Your SSAE 16

Controls at a Service Organization refer to the controls that are in place at your company.

Many of these controls should be covered within your policies and procedures, as they should reflect an accurate depiction of the various processes that occur within your organization. Accurate policies and procedures (P&P) should be designed, implemented, and documented by the service organization. When the service auditor is testing the effectiveness of your control objectives and activities, your P&P support the achievement of the control objectives. While P&P are not enough to determine that a process is operating effectively, they can support the design effectiveness of a control.

Typically a service auditor will perform testing, beyond P&P, around the control objectives and activities to support the fact that employees are performing their duties in accordance with the P&P, because without the additional testing, it would be impossible have comfort that they are actually being followed.

Simply put, good policies and procedures will only get you so far during an audit because you still need to prove to the auditors that the functions management say are being performed are being carried out correctly.

Click Here to Find a Professional CPA Firm to Perform Your SSAE 16

I’ve been hearing from various people in the marketplace that they were interested in learning about some steps, at a high level, that they need to take to get off the ground and on their way to completing their SSAE 16 Report Type I or Type II. So, I will give you guys a breakdown of some of the things you should be doing now, and some things to think about down the line as you progress.


This SSAE 16 Checklist is geared towards service organizations whom have never done a SAS 70 in the past and will be taking up the task this coming year when SSAE 16 will be in full effect. A more detailed version geared towards companies that have some experience being audited will be coming down the line.

• Do your research.
  • You have already come across our site, so you have begun the process of researching SSAE 16 and the responsibilities that come with performing one. I would continue to search for SAS 70 related information as well, as most of that knowledge is applicable.
• Find a few CPA firms who perform SSAE 16′s (or SAS 70).
  • You will want to research a number of firms that could perform and sign off on your SSAE 16 Report, which, only CPA firms are permitted to do. This process should be handled with the utmost care as you are putting a lot of trust into the company you choose, they can make or break you.
  • Some things to consider:
    1. The size of your company – You may not be able to afford a large CPA firm.
    2. The clientele you are attracting – Some companies will not feel secure with the quality of your SSAE 16 if it was performed by a firm that isn’t well known.
    3. Total SSAE 16′s or SAS 70′s performed – You do not want to use a company who has never done such work in the past, unless they are comprised of former employees of another quality firm and have decided to take off on their own.
    4. The methodology employed – You will want to quiz the companies and gain comfort around their methods and ensure you are comfortable with their responses and agree based upon your research.
• Narrow your search.
  • Based upon how you felt about each company, the people, the methodology, their previous experience, and of course, cost,  you should narrow down your search to the top 2 companies.
  • Pricing for SSAE 16′s and SAS 70′s can vary greatly depending upon the company performing the work and the size of your organization, however, I wouldn’t expect to pay any less than $25,000-$30,000.
    • You should look for a fixed rate fee so there is no potential for them to raise rates on you as the project progresses.
• Define the scope.
  • Once you have engaged a firm to perform the work, make sure you define the scope of the audit early on in the process. Not doing so could lead to excessive delays and potential cost overruns.
• Define your control objectives and activities.
  • In conjunction with your CPA firm, define the controls and test steps to be tested and make sure that they have been reviewed by process owners and any of the stakeholders at the CPA firm who may be reviewing and/or signing off on the report to ensure everyone is in agreeance. If this isn’t completed prior to testing, you are asking for a world of trouble.
• Perform a Readiness Assessment.
  • You can either choose to perform a readiness assessment on your own, based upon the test steps already defined, or, if you do not have the capacity or ability to do so internally, you can look towards either the firm performing your review or another firm who is skilled in preparing companies for audits.

These steps laid out here will set you on your way to getting your SSAE 16 started up and going and should help to guide you through the toughest parts of the process. Once you have completed all of the steps we have laid out, you should be able to rely on the knowledge of your CPA firm to take you through the finish line.

If you have any further questions feel free to add it to the comments below and we will do our best to respond!

Click Here to Find a Professional CPA Firm to Perform Your SSAE 16

Some organizations have heard of SAS 70 or SSAE 16, but, don’t really know WHY they need to pay to have a bunch of auditors trounce through their company for a month or two during the year, especially right after their financial audit just finished.
The answer is simple: Many companies will not even think about using your company to perform services for them without a clean Type II Report in place.
Some benefits of having an SSAE 16 performed:

• Ability to perform outsourcing services for Public Companies.
  • If performing financially significant duties for a Public Company, they are required to use a SSAE 16 qualified provider as it is the only way to give investors assurance over controls that are not performed by the Company in question.
• Public and Private companies are more likely to trust your organization with their data.
  • If you were to trust a company with your data, you would want complete assurance it will be handled with the utmost care
• A year round accessible knowledge source (your auditors).
  • As a service organization, large or small, you will always have questions regarding your business and having a set of auditors in place with access to a wide array of business knowledge, it will allow you to bounce your questions and concerns off of a group of trusted individuals.
• A third party to review your controls and activities to ensure they are functioning appropriately, and give advice on how to improve upon them.
  • Sometimes your internal audit department is good, but, not always as stringent as they should be. This will help to serve as a check on their work, as well as your staff. Additionally, if there were any findings noted, your auditors are in a great position to give you some tricks and tips to improve to ensure everything functions well the following period.
• Improving performance of the organization.
  • Just the knowledge that a review is being performed of an employee’s work that can have far reaching consequences for the company as a whole. No more, “Oh, I didn’t realize that reviewing user access was THAT important to do this month, sorry”, now, everyone knows that if it’s not done, the success or failure of the organization could rest upon them.

Think of the SSAE 16 as an annual investment into your company, increasing potential new clients, productivity and accountability.

Click Here to Find a Professional CPA Firm to Perform Your SSAE 16

When performing a SSAE 16 Review, you will be inundated with various terms that you may have never heard of before. We plan on continuing with a serious of posts dedicated to explaining the various terminology that you should be aware of to ensure when the auditors are explaining things to you, you don’t lost in the jargon.

Today we will discuss the Carve-out Method.

When management is in the process of writing their description of their system (‘management’s description of the service organization’s system’), there are various ways to address controls or functions relevant to the processes that are outsourced to another organization (‘subservice organization’). Using the carve-out method, you would exclude the subservice organization’s relevant control objectives and related controls from management’s description and scope of the service auditor’s engagement.

Now, this doesn’t mean you don’t need to address the controls that take place at a subservice organization, what it means is that you will need to have controls in place to monitor the effectiveness of the controls at the subservice organization. The most typical way to address this would be to obtain an SSAE 16 from the subservice organization, assuming the relevant controls were covered within their report.

Click Here to Find a Professional CPA Firm to Perform Your SSAE 16

There are significant differences between a Type I and Type II report, however, we aren’t going to discuss that here, thats for another day. We will discuss the basics of a SSAE 16 Type I Report and some areas that should be focused on if this is the direction your company wants to take.

While the Type I Report doesn’t carry much weight, there are benefits, and that’s why it exists as an option. A Type I Report is specifically defined by the SSAE 16 guidance as a “report on a description of a service organization’s system and the suitability of the design of controls”, essentially, a determination of if your company’s controls designed appropriately. When performing a Type I report, the auditors will test the design effectiveness of your company’s defined controls by examining a sample of 1 item per control. This provides a user organization with some comfort that your company (the service organization) has at least some controls in place. This can be useful when trying to obtain a contract and to show good faith to the potential user organization that your company is moving in the right direction. Most user organizations will require a Type II Report before contracting your company as a service organization of theirs.

The Type I Report is made up of 3 major areas, per the SSAE No. 16 Guidance:

a description of the service organization’s system prepared by management of the service organization.

- Management will need to prepare a description of the control objectives that are in place and being tested at their organization, as it relates to the process that is being reviewed for use by a User Organization. This will read sort of like a narrative of the process and how your control objectives tie in to each other and the process as a whole, giving a User Organization an overview of what and how, at a high level, their data will be handled.

a written assertion by the Service Organization’s management about whether, in all material respects, and based on suitable criteria:

1. the description of the service organization’s system fairly presents the service organization’s system that was designed and implemented as of a specified date.
2. the controls related to the control objectives stated in the description were suitably designed to achieve those control objectives as of the specified date.

- Management will need to prepare a written assertion attesting to the fair presentation and design of controls. Previously under SAS 70, it was the auditors who reported directly on the controls and management was not required to attest to anything. (There will be a separate post describing this in detail as this is a major difference)

The final component:

a service auditor’s report that expresses an opinion on the matters in b1-2.

- The auditors that are hired to perform the testing will need to review the Management’s assessment of the design of controls and attest to the validity of Management’s opinion. The auditors will walk through the control objectives and control activities in place at your company and verify they are, in fact, designed as Management noted. This is where the auditors will obtain a sample of 1 to support each control activity and express the results of their testing.

Specifics of reporting details for a SSAE Type I will be discussed later on!

Click Here to Find a Professional CPA Firm to Perform Your SSAE 16

So you have been performing a SAS 70 for the last couple years, or, are getting ready prepared to embark on your first SAS 70, and all of a sudden you hear that a brand new standard has been issued!

Don’t worry about it!

SSAE 16 is an improvement to the current standard for Reporting on Controls at a Service Organization, the SAS70, with some changes that will help bring your company and the rest of the companies in the US up to date with new international service organization reporting standards, ISAE 3402. This will help allow you and your counterparts in the US be able to compete on an international level, allowing for companies around the world to be able to use YOU as their service organization with complete comfort.

One very important issue that you should be very aware of is that SSAE 16 will formally be issued in June 2010 with an effective date of June 15, 2011, meaning that if you are not on top of this new standard soon, you need to be. Many organizations have a 12 month testing period that begins in July, and if this sounds like your company, you will be required to be compliant with the New Standards as of July 1, 2010.

Major differences between SAS 70 and the New Standard, SSAE 16 and ISAE 3042:

1) Management of the Service Organization will be required to provide the service auditor with a written assertion about the following, when performing either a Type I or Type II engagement, which the service auditor will then attest to:

• The fairness of the presentation of the description of the service organization’s system;
• The suitability of the design of the controls to achieve the related control objectives stated in the description; and
• The operating effectiveness of those controls to achieve the related control objectives stated in the description (Type II Only)

2) During the process of understanding the service organization’s system, the Service Auditor would be required to obtain information that would identify risks that the description of the service organization’s system is not fairly presented or that the control objectives stated in the description were not achieved due to intentional actions by service organization personnel.

Changes that Directly Impact Type II Engagements

1) The Service Auditor’s opinion on the fairness of the presentation of description of the service organization’s system and on the suitability of the design of the controls would be for a full period, as opposed to a specified date. (i.e. Your report would be for the 6 months covering July 2010 through December 2010.)

• The Type II report would identify the customers to whom use of the report is restricted as “customers of the service organization’s system during some or all of the period covered by the service auditor’s report”

2) Evidence obtained in prior engagements related to the satisfactory operation of controls in prior periods will not be sufficient to reduce the amount of testing performed.

Expected Change Which Didn’t Occur:

While it was expected that SSAE 16 would build upon the previous SAS 70 standard of reporting only on financial reporting activities and allow a service organization to branch out in to other areas of their business, such as regulatory compliance and performance metrics, this was not included within the initial final version of the New Standard and there has been no guidance as to when it would be expected, if ever, to be.

Click Here to Find a Professional CPA Firm to Perform Your SSAE 16

This tip is focused on designing controls that reflect the process being testing, if they don’t, a headache of massive proportions will be created once testing begins.

What do you do to make sure you don’t screw this up? Have as many meetings as it takes to get it right.

What you need to do is sit down with the auditors, the department lead, the main employees responsible for performing the process, and anyone else whom could either play a role in testing or modifying the control in the future. Once that is done, Management should discuss what they determined the control to be and how it should operate, that is then reviewed by the auditors, and then the employees performing the tasks should be reconsulted to verify that the control still reflects their process accurately.

Many times people try to speed this process up and half-ass it, leaving many open items which upon testing could easily blow up into a huge problem. When the control isn’t 100% agreed upon prior to testing and a deviation is noted, it’s a tough call between failing the control and the ability to adjust it to accurately reflect the process. The problem is modifying a control after testing has begun is not proper and needs to be avoided at all costs.

Locking the controls locked down early on could save weeks in wrapping up your new SSAE 16 Report.

We have seen issues like this cause delays in issuing of the report to the client and running additional fees, since adjusting controls isn’t free. Coming from the perspective of the auditor, we can let you know the pitfalls, consequences and how to best navigate the audit process. If you have any comments or questions please leave them below!

Click Here to Find a Professional CPA Firm to Perform Your SSAE 16

Another series we will have periodic posts about will be related to potential controls that would be expected to be in place, almost regardless of the entity in question.

This will be a real basic one to help get everyone up to speed, we will delve into other areas that may be a little more advanced in the future.

Example: Firewalls are in place at all externally facing access points.

The point of this control is to ensure that firewalls are being used at the organization to help prevent hacking attempts, thus, the theft of data. Companies outsourcing their workloads want to have comfort that the company performing the work has adequate security measures in place to lower the chance of their data being stolen.

Firewalls are some of the most basic devices that need to be in place at a business to protect data and if your business does not currently employ firewalls on their network, it is a must do and should be looked into immediately.

Click Here to Find a Professional CPA Firm to Perform Your SSAE 16