Implementation of SAS No. 134 and Related SASs

01/06/2022: We do NOT have the updated SAS 134 Engagement Letters, AUP Engagement Letters, Communications, etc. Please refer to https://ahacpa.org/announcements/sas-134 for additional information. When those become available we will send out an email blast. 

Auditor CPE Requirements


Chapter 4 of the Government Auditing Standards (aka Yellow Book) states the following regarding CPE

Requirements: General

4.02 The audit organization’s management must assign auditors to conduct the engagement who before beginning work on the engagement collectively possess the competence needed to address the engagement objectives and perform their work in accordance with GAGAS.

4.03 The audit organization’s management must assign auditors who before beginning work on the engagement possess the competence needed for their assigned roles.

4.04 The audit organization should have a process for recruitment, hiring, continuous development, assignment, and evaluation of personnel so that the workforce has the essential knowledge, skills, and abilities necessary to conduct the engagement. The nature, extent, and formality of the process will depend on various factors, such as the size of the  audit organization, its structure, and its work.

4.16 Auditors who plan, direct, perform engagement procedures for, or report on an engagement conducted in accordance with GAGAS should develop and maintain their professional competence by completing at least 80 hours of CPE in every 2-year period as follows.

CPE Hours Subject matter categories of CPE
24 hours Subject matter directly related to the government environment, government auditing, or the specific or unique environment in which the audited entity operates
56 hours Subject matter that directly enhance auditors’ professional expertise to conduct engagements

Application Guidance: Exemptions and Exceptions

4.25 Auditors may be exempted from the 56-hour CPE requirement by the audit organization, but not the 24-hour requirement, if they

a. charge less than 20 percent of their time annually to engagements conducted in accordance with GAGAS and
b. are only involved in performing engagement procedures, but not involved in planning, directing, or reporting on the engagement.

The 20 percent may be based on historical or estimated charges in a year, provided that the audit organization has a basis for this determination and monitors actual time. For auditors who change status such that they are charging
more than 20 percent of their time annually to engagements under GAGAS, the audit organization may prorate the required CPE hours similar to when auditors are assigned to GAGAS engagements after the beginning of a 2-year CPE
measurement period, as discussed in paragraph 4.42.

4.26 Nonsupervisory auditors who charge less than 40 hours of their time annually to engagements conducted in accordance with GAGAS may be exempted by the organization from all CPE  Requirements in paragraph 4.16.

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