Costs, Schedule, and Other Things


What will a IPSA audit cost? 

The SEC’s final rule included cost estimates for the IPSA Audit that ranged from $25,000 to $100,000.  At, we suggest the costs will not be at the low end of this range.  If you’ve reviewed government documents before, you know how those estimates go (how long does it take you to prepare your tax return at home, compared to how long the government estimates?).    As has been the case for many other new types of audits (Sarbanes-Oxley audits of internal systems and controls; Environmental Management Systems audits; Quality Management Systems audits; supply chain audits for restricted hazardous substances; chemical facility anti-terrorism standard audits), the first couple years are more effort-intensive (and costly) for all parties.  As the audits become more routine, and companies’ systems and controls are more robust, the costs will decline. 


How long will a IPSA audit take?

This depends on many factors, including client audit readiness.   Compare this with your experience at other audits (financial, internal, management systems) – especially those your company has not been involved with before.  At, we suggest the time could be as little as two weeks, or as much as ten weeks. 


How is managing workload? 

At, we are expanding our network of IPSA Auditors – but selectively.  We expect to limit our clientele to companies we can work with effectively, and produce quality IPSA Audit reports. 


The IPSA audit covers the calendar year, right?  What if we learn something new in January?  Or February?  Or the day after the IPSA Auditor left?  Or May 29?

This issue of timing is not addressed in the DFCM Final Rule, or in SEC’s FAQs.  These situations are likely to occur – especially with the trickle of supplier questionnaires starting to come in.  At, we have taken cues from criteria for these matters for financial reporting (Form SD is a financial filing) and management systems audits.  Absent SEC requirements, we review our rationale with audit clients, get agreement, and proceed from there.


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