Q.

I understand that reciprocal auditing is not permitted, but what about “circular auditing?”

A.

Circular auditing, in which a consortium of three or more States, or three or more local jurisdictions, agrees to perform audits at facilities in other consortium States, is permissible, with a few caveats. First, the circular auditing schedule must be developed so that no audits would be considered impermissible reciprocal audits (click here for more information on reciprocal audits).  Second, no audits can be allowed in cases in which the auditor’s agency contracts for space in the facility being audited.

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Auditing,
Audit Process