Question

Background

Helio, Inc. (the Company) is a medical device company founded in 2013 in Provo, Utah that specializes in the development and manufacturing of cutting-edge medical devices designed for all types of joint replacement surgeries. In January 2015, the FDA approved Helio’s premier product, a hinged titanium axle designed to provide physicians with more precise placement of joints during joint replacement surgery.

In early 2016, approximately one year after the new product’s approval, the Company hired a new senior vice president (SVP) of sales to oversee sales, physician training, product delivery, and customer service. The broad set of responsibilities allowed the charismatic SVP to significantly influence the Company’s revenue generation. The hiring of the new SVP was also done in large part to help guide the company’s development of an important new sales channel: third-party distributors that are each strategically located in close proximity to key hospitals in regions around the country.

The move to hire the SVP was in direct response to overwhelming disappointment about the first year’s sales volume for the new surgical implant, which was lagging significantly behind expectations. Reports from the field led management to recommend the new sales channel to the board of directors that overwhelmingly approved the new strategy, the execution of which was being led by the new SVP.

Execution of strategy

To help execute the new strategy, the SVP hired five regional sales managers who would become his trusted cohorts. Together, they set aggressive sales targets for the Company’s surgical implants. The sales targets focused on achieving a growth pattern that was characterized by a record high sales volume for each successive quarter in each region. In fact, it is fair to say that the sales targets were intentionally created at almost unreachable levels to remove any question about possible weakness in demand for the Company’s new product.

The strategy focused on the development of a new sales channel with third-party distributors. Each of the distributors had already established close relationships with the physicians that were actually using the product during surgical procedures. To help pay for the launch of their new product, along with the execution of the new strategy, the Company was also working hard to raise a significant amount of new investment capital to fund the resulting increased operating costs. In order to be successful in attracting the new investment capital, top management made it clear to the SVP how important it was to report strong sales for its premier product, the surgical implant for titanium joints. The SVP, in turn, passed along the same message to the regional sales managers.

© 2018 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 741662

1

Management control philosophy

The upper management team of Helio can be described as being aggressive in business practices and often emphasizes speed and efficiency when implementing their decisions. Management rarely hires external consultants because they are of the opinion that consultants are too expensive and often follow a conservative approach. The upper management team meets regularly with its key managers. In general, the upper management team has cooperated with the audit team in order to provide fair and adequate financial reporting, but there have been disagreements in the past. The Company has a strict policy for following all established internal control procedures.

Incentive compensation

Top management focuses significant attention on achieving short-term performance measures based on the audited financial statements when determining compensation and making promotion decisions. Revenue earned is the most important criterion in performance assessment throughout the organization. As part of the launch of its new surgical implant, a new bonus plan was established to provide additional incentives for the entire organization to focus on this new opportunity, with revenue earned as the key criterion used to determine incentive compensation.

Preliminary results

Despite the SVP’s optimism about sales in 2017, internal reports have indicated that the actual sales volume of the surgical implant was well below budget each quarter. The SVP responded to these reports by repeatedly communicating his disappointment to the regional sales managers. Furthermore, he consistently warned that if the team could not boost sales, the Company would likely not be able to raise additional investment capital and would then be forced to significantly downsize its headcount.

Unfortunately, boosting revenue of the new surgical implants was not as simple as merely shipping the product to distributors. The distributors were hesitant to purchase product until the sale to the final customer was finalized as the distributors did not want to be stuck with the inventory on their own balance sheets. Further, the terms of the sales do not include any refund or rebate conditions. In addition, the Company has no intention of changing those terms and accepting any return. Therefore, any sale to distributors are final.

By the end of 2017, the Company had signed on a total of 73 distributors to sell its surgical implants in more than 20 different states throughout the United States. Each distributor was independently owned and operated but the company routinely shared best practices among its network. The SVP monitored sales closely from the distributor network through his regional sales managers. In fact, he even maintained a monthly sales report from each of the 73 distributors.

The Company invoices customers when the goods are shipped, and invoicing triggers the recording of revenue. The Company does not include freight costs in sales revenue but does offset shipping costs with any freight charged to customers.

The following relevant financial data is taken from the Company’s unaudited trial balance, which was used to produce the unaudited financial statements:

© 2018 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 741662

Sales revenue, year ended 12/31/2017	$84,867,855
Gross accounts receivable, 12/31/2017	$11,988,886

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Audit approach

Your audit team is currently in the midst of year-end testing in the revenue and accounts receivable cycle for the audit of the calendar year 2017 financial statements. Your testing will focus on the existence/occurrence, cutoff, and accuracy assertions for sales revenue, as well as the existence and valuation assertions for accounts receivable. The audit team has assessed the risk of material misstatement (RMM) for each relevant assertion in order to determine the nature, timing, and extent of the procedures to be performed at Helio.

Other members of the audit team have already completed a walk-through of the revenue and accounts receivable processes, identified “what could go wrongs” within the process, and identified the controls that have been placed in operation to mitigate the risks. Based on the work performed, the team decided to test the operating effectiveness of certain key controls during interim testing. The results are found below.

Tests of controls – Revenue and accounts receivable cycle – Interim

Four key application controls were tested at interim. The information technology (IT) auditors tested the general controls (GITCs) over program changes, access to programs, and computer operations that are relevant to the revenue and accounts receivable cycle. The GITCs were found to be effective. In addition, the IT auditors tested the system to make sure that proper segregation of duties occurred throughout the period and were operating effectively.

The first control is an automated three-way sales match. The control matches the details from 1) an approved sales order; 2) relevant shipping documents; and 3) the sales invoice before revenue is recorded. A test of the control’s operating effectiveness was conducted at the interim. No exceptions

new customers, including the new distributors. A test of the control’s operating effectiveness was conducted at interim. No exceptions were noted.

The third control is an automated sales authorization control. When a sales order is entered into the system, the amount of the sale is added to the existing accounts receivable balance for that customer. The sum is then compared to the customer’s credit limit. A test of the control’s operating effectiveness was conducted at interim. No exceptions were noted.

The fourth control is a monthly review of the adequacy of the allowance for doubtful accounts, completed by the controller. A test of the control’s operating effectiveness was conducted at interim. No exceptions were noted.

© 2018 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 741662

were noted.

The second control requires the credit department at Helio to conduct a detailed credit check for all

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Roll-forward period

By the end of the third quarter of 2017, sales revenue for the company’s premier surgical implant was still lagging far behind expectations. To help ensure that Helio delivered impressive fourth quarter revenue numbers, the entire sales team, led by the SVP and the regional sales managers, began to exert pressure on a number of distributors in an attempt to improve sales in 2017. This effort seemed to be paying off as the sales team successfully persuaded more than a dozen distributors to purchase product in advance of final customer demand.

These circumstances presented a problem for the Company, because the distributors began to ask for concessions from Helio. For example, in order to persuade the distributors, the Company agreed to hold the inventory in their own warehouse.

The SVP’s actions led to a dramatic increase in revenue for the fourth quarter of 2017. In fact, sales increased year-over-year by 214 percent for the fourth quarter alone. The upward trajectory of sales revenue helped the Company raise the much-needed investment capital as Helio issued more than 10 million shares of common stock for $40 million in early 2018.

1. [5 points] Based on your understanding of fraud risk assessment and material:
   • Identify at least three (3) specific fraud risk factors related to Helio.

Answer 1

Based on my understanding of fraud risk assessment the three specific fraud risk factors related to helio as identified after analysing the case are :

1) Unrealistic Sales Targets creating excessive pressure :

The first risk factor is the setting of aggressive sales targets at almost unreachable levels which created intense pressure to management and sales personnel to meet these extraordinary targets and market expectations. This can prove to be a fraud risk factor as it poses the risk of exploitation and pressure on employees affecting their health.

2) Ineffective Management Practices and Monitoring :

The management control philosophy is also aggressive in nature and takes only speed and efficiency into consideration without giving any due concern to limited potential or capabilities. Attitude rationalization due to disregard of internal controls and inadequate internal control.

3) The management rarely hires external consultants as they consider hiring external consultants too expensive resulting in discriminatory hiring practice not giving opportunities to external candidates and often following a conservative approach resulting in inefficiency.

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