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ACCEPTED
15-25-00227-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
12/9/2025 9:33 PM
CHRISTOPHER A. PRINE
CLERK
FILED IN
IN THE FIFTEENTH COURT OF APPEALS
15th COURT OF APPEALS
AUSTIN, TEXAS
AT AUSTIN, TEXAS 12/9/2025 9:33:51 PM
CHRISTOPHER A. PRINE
Clerk

Case No. 15-25-00227 - CV
(Transferred from the Third Court of Appeals)

IN RE CEDRIC M. SCOTT, PhD
Relator, Pro Se

GENERAL LAND OFFICE OF THE STATE OF TEXAS
Real Party of Interest

Original Proceeding from the 250th Judicial District Court
of Travis County, Texas
Trial Court Cause No. D-1-GN-25-000006

RELATOR’S MOTION TO EXPEDITE CONSIDERATION OF
PENDING PETITION FOR WRIT OF MANDAMUS
TO THE HONORABLE FIFTEENTH COURT OF APPEALS:

Relator, Cedric M. Scott, PhD1, respectfully moves the Court to expedite

consideration of her Petition for Writ of Mandamus, which the Clerk accepted for

filing on December 8, 2025. The mandamus presents substantial constitutional,

procedural, and administrative defects that have halted the judicial process for

nearly a year. The absence of a successor judge since November 21, 2025, the

presence of void orders entered by a constitutionally disqualified trial judge, the

missing Court reporter’s record, and the systemic prejudice to Relator warrant

accelerated review.

Relator continues to suffer irreparable harm—including blacklisting, loss of

comparable employment since December 3, 2024, ongoing procedural paralysis,

and the inability to advance her claims due to the trial court’s inability to act.

Expedited consideration is necessary to prevent further harm and restore lawful

judicial process.

I. PROCEDURAL DEFECTS REQUIRING MANDAMUS
INTERVENTION

A. Constitutional Disqualification Rendered All Orders Void

Judge Cory R. Liu previously represented GLO in HUD-related matters.

1
Plaintiff’s first name is pronounced See-Drick and not Said-Drick. Gender is female, and pronouns are
she, her, and hers.

2
Under Tex. Const. art. V, § 11, this created constitutional disqualification. Orders

issued by a disqualified judge are void ab initio. Buckholts I.S.D. v. Glaser, 632

S.W.2d 146, 148–49 (Tex. 1982).

B. No Successor Judge Has Been Appointed

Judge Liu recused on November 21, 2025. As of today, no successor judge

has been assigned. Void orders remain uncorrected. Time-sensitive filings cannot

be ruled on. The trial court is unable to act. This constitutes the type of “stalled

judicial machinery” mandamus is designed to correct. In re Patel, 619 S.W.3d 651,

654 (Tex. 2021).

C. GLO Continues to Benefit From Procedural Paralysis

GLO has not answered the live petition, has not disputed the findings of its

own Internal Audit Report No. 25-01, and continues to benefit from the procedural

standstill created by the constitutional disqualification and lack of a successor

judge. Relator, by contrast, remains unable to obtain judicial review of void orders

or advance her claims.

This breakdown functions as a litigation shield for GLO. The agency avoids

responding to filings, avoids addressing corroborated compliance failures, and

avoids scrutiny of its inconsistent representations. With no judge in place, these

issues cannot be addressed. This one-sided paralysis is precisely the type of

structural defect a mandamus exists to remedy.

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II. SIGNIFICANCE OF THE MISSING 10/29/2025 TRANSCRIPT

Relator filed a Motion to Preserve the Record before filing her mandamus.

The transcript, due November 21, 2025, has not been filed. It contains:

1. GLO’s counsel inferring the non-existence of the internal audit report,

2. Statements bearing on Relator’s credibility, and

3. The context surrounding void orders entered by a disqualified judge.

Despite Relator’s motion for preservation of the hearing transcription, its

absence further prejudices Relator and heightens the need for expedited relief.

III. INTERNAL AUDIT REPORT 25-01 CORROBORATES
RELATOR’S PROTECTED DISCLOSURES

GLO’s Internal Audit Report No. 25-01, completed in sometime in

September 2025 and transmitted to the Office of the Governor, the Legislative

Budget Board, the State Auditor’s Office, and not shared to Relator documents

systemic deficiencies, including:

• Inadequate training

• Documentation failures

• Monitoring noncompliance

• Procurement irregularities

• Weak internal controls

• Undefined roles and responsibilities

4
The above findings mirror the deficiencies Relator documented and shared

with Grant Management and Internal Audit Director prior to her termination

summarized in TAB J and TAB K referenced in her pending mandamus. Those

materials were also submitted to the trial court with Relator’s Second Amended

Petition, which GLO has refused to answer the petition.

IV. ADDITIONAL GROUNDS DEMONSTRATING THE NEED FOR
EXPEDITED REVIEW

A. GLO’s Litigation Position Conflicts With Mandatory Audit Standards
and Its Own QAIP Framework

Relator provides this additional context to demonstrate why expedited

review is necessary and why GLO’s litigation posture is inconsistent with its own

internal-audit obligations.

1. Audit Standards (AS) 1311 Requires Internal Self-Assessments and
Ongoing Monitoring

The FY2023 Internal Audit Quality Assurance and Improvement Program

(QAIP) Report, addressed to Commissioner Dawn Buckingham on October 9,

2023, confirms that GLO is required to conduct ongoing internal-audit monitoring

and periodic self-assessments. Exhibit 1- FY2023 QAIP Report at pages 1–4, where

the report describes:

a. Continuous monitoring of internal audit activities;

b. Periodic internal self-assessments;

5
c. Evaluation of conformance with internal-audit standards;

d. Documentation of internal processes and audit performance; and

e. Communication of periodic assessment results to GLO leadership.

Critically, page 4 of the QAIP Report expressly restates the requirements of the

Institute of Internal Audit Attribute Standard 1311, confirming that internal

assessments “must include ongoing monitoring of the performance of the internal

audit activity” and “periodic self-assessment or assessments by other persons

within the organization with sufficient knowledge of internal audit practices.”

2. GLO’s QAIP Reports Acknowledge and Operationalize AS 1311
Requirements

Across pages 1–6, the FY2023 and FY2022 QAIP Reports demonstrates that GLO:

a. Performs internal self-assessments annually;

b. Conducts ongoing monitoring through weekly meetings with audit teams;

c. Tracks performance, documentation, audit plans, and fieldwork;

d. Uses formal internal-audit policies and procedures; and

e. Performs post-audit analyses and status reporting.

These processes mirror the specific internal-audit functions that Relator

repeatedly reported as deficient within CDR Grant Management—specifically

documentation, oversight, internal controls, and monitoring. Exhibit 1- FY2023

and Exhibit 2 - QAIP Reports

6
3. GLO’s Interrogatory Response Contradicts These Published
Requirements

In sworn discovery responses, GLO claimed that CDR–Grant Management

personnel were “not required” to conduct internal self-assessments. This is

contradictory with:

• AS 1311’s explicit requirement for periodic self-assessments;

• GLO’s own published QAIP processes confirming the same; and

• The responsibilities assigned to CDR oversight personnel, including senior

management, regional managers, and senior grant managers.

The contradiction is not minor. It demonstrates that GLO’s litigation

narrative—framing deficiencies as performance issues or managerial

disagreement—is incompatible with:

• External audit standards (AS 1311),

• Internal agency publications (FY2023 QAIP Report), and

• GLO’s Internal Audit Report No. 25-01’s conclusion that the deficiencies

were systemic, and not performance issues.

4. These Contradictions Reinforce Why Expedited Review Is Necessary

The inconsistencies between GLO’s sworn assertions and its own QAIP

framework:

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• Confirm Relator’s disclosures were accurate and grounded in established

audit expectations;

• Demonstrate that deficiencies were structural and agency-wide, not

individual;

• Show that GLO’s litigation posture is at odds with its documented practices;

• Reinforce that continued delay allows GLO to benefit from procedural

paralysis; and

• Support expedited review because the underlying issues are no longer

factually disputed.

Together, these contradictions underscore why Relator faces ongoing

prejudice and why void-order issues must be addressed promptly2.

Required TRAP 52.7 Disclaimer

Relator does not submit these publicly available QAIP publications as

evidence for purposes of the mandamus record. They are referenced solely to

demonstrate inconsistencies in GLO’s litigation posture and the systemic nature of

the deficiencies corroborated by GLO’s Internal Audit Report No. 25-01.

2
Internal Audit Report No. 25-01 identifies systemic deficiencies in documentation, monitoring,
and internal controls—each of which corresponds to the exact oversight functions that AS 1311-
required internal assessments are designed to evaluate. See FY2023 QAIP Report, pp. 3–4
(detailing ongoing monitoring, self-assessment requirements, documentation review, audit-status
monitoring, and continuous quality-review procedures). These alignment points further
corroborate Relator’s disclosures and contradict GLO’s sworn assertion that no such oversight
duties applied to CDR personnel.
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V. PRAYER

Relator respectfully prays that the Court grant this Motion to Expedite,

expedite consideration of the pending Petition for Writ of Mandamus, and grant

such other relief to which Relator may be justly entitled.

Respectfully submitted,

/s/ Cedric M. Scott

Cedric M. Scott, PhD
Relator, Pro Se
Email: cedricscott41@gmail.com

Date: December 9, 2025

9
CERTIFICATE OF CONFERENCE

Pursuant to Texas Rule of Appellate Procedure 10.1(a)(5), Relator certifies

that a conference regarding this Motion to Expedite was impracticable because this

is an original mandamus proceeding and the Respondent Judge does not participate

in such matters. Additionally, the relief sought is procedural and time-sensitive, and

the Real Party in Interest has not answered Relator’s Second Amended Petition

which raises additional issues requiring judicial resolution, and the underlying case

remains unable to proceed due to the absence of a successor judge; therefore,

consultation would not eliminate the need for court intervention. Accordingly, this

motion is submitted without conference.

s/ Cedric M. Scott
Cedric M. Scott, PhD
Relator, Pro Se

10
CERTIFICATE OF SERVICE

I certify that a true and correct copy of the foregoing Relator’s Motion to Expedite

Consideration of Pending Petition for Writ of Mandamus was served on counsel

for the Real Party in Interest, in accordance with Texas Rule of Appellate Procedure

9.5, on December 9, 2025 by electronic service (e-Filing).

Counsel for the General Land Office

Sara Labashosky
State Bar No. 24129467
slabashosky@bickerstaff.com

Gunnar P. Seaquist
State Bar No. 24043358
gseaquist@bickerstaff.com

Bickerstaff Heath Delgado Acosta LLP
3711 S. MoPac Expressway
Building One, Suite 300
Austin, Texas 78746
(512) 472-8021

/s/ Cedric M. Scott
Cedric M. Scott, PhD
Relator, Pro Se

11
IN THE FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS

Case No. 15-25-00227-CV
(Transferred from the Third Court of Appeals)

IN RE CEDRIC M. SCOTT, PhD, Relator, Pro Se

Original Proceeding from Cause No. D-1-GN-25-000006
250th Judicial District Court, Travis County, Texas

EXHIBIT 1 - GLO FY2023 INTERNAL AUDIT QUALITY ASSURANCE
AND IMPROVEMENT PROGRAM (QAIP) REPORT

(Referenced in Section IV of Relator’s Motion to Expedite)
Submitted by:
Cedric M. Scott, PhD
Relator, Pro Se
Date: October 31, 2022

To: George P. Bush, Commissioner
Mark Havens, Chief Clerk

From: Tracey Hall, Chief Auditor

Subject: 2022 Annual Report on the Internal Audit, Quality Assurance and Improvement
Program
______________________________________________________________________________

The following report is presented in accordance with the Institute of Internal Auditors’(IIA)
International Standards for the Professional Practice of Internal Auditing (Standards) and with
the U.S. Government Accountability Office’s Government Auditing Standards, commonly
referred to as generally accepted government auditing standards (GAGAS), both of which require
internal audit divisions to develop and maintain a Quality Assurance and Improvement Program
(QAIP) that includes both internal and external assessments of internal audit.

The objective of the internal and external assessments is to evaluate the internal audit activity’s
conformance with the definition of internal auditing, the Standards, and the IIA Code of Ethics.
The Standards require the results of these periodic assessments to be communicated to those
charged with governance at least annually.

The Office of Internal Audit, for the Texas General Land Office (GLO) and Veterans Land Board
(VLB), maintains an ongoing QAIP and performs ongoing monitoring of the quality of internal
audit activities as well as periodic reviews performed through self-assessment and external quality
assessment reviews.

This report and the detailed results that follow are intended to satisfy both sets of Standards by
demonstrating that an internal assessment was performed, listing all the relevant IIA and GAO
requirements, and indicating the evidence of compliance with each requirement. The Office of
Internal Audit successfully passed its external quality assessment in June 2021. The Office of
Internal Audit will undergo its next external quality assessment in 2024 (see Appendix for excerpts
from the 2021 External Quality Assurance Review).

If you have questions or comments about this report, please contact me at (512) 463-6078.

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DETAILED RESULTS:

Standard No. Requirement(s) Evidence of Compliance
and Title

IIA AS 1300 1, The chief audit executive (CAE, also referred to as  The Internal Audit (IA) Policies and Procedures Manual has been developed
Quality the Chief Auditor) must develop and maintain a and maintained on the IA shared drive. It is updated as needed, at a minimum
Assurance and quality assurance and improvement program that of at least every three years with the most recent revision conducted in July
Improvement covers all aspects of the internal audit activity. 2022.
Program
 A General Audit Program that consists of detailed procedures for ensuring
compliance with the Standards, GAGAS, IA policies and procedures, and
applicable legal and regulatory requirements are utilized during every audit
engagement.

 A Quality Control (QC) Reviewer, an auditor external to the project, is
assigned to every audit and performs review of all audit work papers to
ensure their integrity, compliance, and satisfaction of the Standards, GAGAS
and audit objectives.

 The Chief Auditor reviews and approves audit objectives, plans, testing
programs, and reports for all audit engagements.

 In its Annual Report on the GLO Internal Audit – QAIP, IA staff reviews the
Standards and GAGAS for any updates to ensure the department’s QAIP is
current and complies with all applicable requirements.

1 The Institute of Internal Auditors’ (IIA) International Professional Practices Framework (IPPF, commonly referred to as the Red Book) is the conceptual framework that organizes authoritative

guidance promulgated by the IIA. Conformance with The IIA’s International Standards for the Professional Practice of Internal Auditing (Standards) is essential in meeting the responsibilities of
internal auditors and the internal audit activity. The structure of the Standards is divided between Attribute and Performance Standards. Attribute Standards (AS) address the attributes of organizations
and individuals performing internal auditing. The Performance Standards (PS) describes the nature of internal auditing and provides quality criteria against which the performance of the services can
be measured. The Attribute and Performance Standards are provided to apply to all internal audit services.

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Standard No. Requirement(s) Evidence of Compliance
and Title

IIA AS 1310, The quality assurance and improvement program must  A QC Reviewer is assigned to every engagement to perform an internal
Requirements include both internal and external assessments. review of all work papers to ensure adherence to the Standards, GAGAS,
of the Quality and applicable legal and regulatory requirements.
Assurance and
Improvement  The Chief Auditor reviews and approves key audit plans, documents and
Program samples of the QC work performed.

 An external Quality Assurance Review (QAR) 2 is obtained every 3 years
and performed by peers of the IA function. The QAR was last completed in
June 2021 (see Appendix for excerpts from the 2021 External Quality
Assurance Review). IA will undergo its next QAR in 2024.

2 The IIA's International Professional Practices Framework (IPPF), the U.S. Government Accountability Office’s (GAO) Government Auditing Standards (known as the Yellow Book), commonly

referred to as generally accepted government auditing standards (GAGAS), and the Texas Internal Auditing Act (the Act) require that IA functions obtain external quality assurance reviews to assess
compliance with Standards and the Act and to appraise the quality of their operations. GAGAS require these reviews at least every three years. A periodic external quality assurance review, or peer
review, of the IA function is an essential part of a comprehensive quality assurance program. If the QAR is successfully fulfilled (passed) the Chief Auditor may state that the internal audit activity
conforms with the International Standards for the Professional Practice of Internal Auditing only if the results of the quality assurance and improvement program support such a statement (IIA AS
1321).
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Standard No. Requirement(s) Evidence of Compliance
and Title

IIA AS 1311, Internal assessments must include:  The QC Reviewer for each audit reviews and signs off on every audit
Internal working paper to ensure completeness and compliance with the Standards.
 Ongoing monitoring of the performance of the
Assessments
internal audit activity.
 The Chief Auditor meets with each audit team at least monthly or as needed
 Periodic self-assessment or assessments by other
to discuss the status of the audit and potential issues.
persons within the organization with sufficient
knowledge of internal audit practices.
 Time and resources for each audit are tracked by audit phase regarding to
planning the audit, performing fieldwork, reporting, and quality control and
supervisory review.

 Auditors communicate to management through a project status report and
with the Chief Auditor on an ongoing basis throughout the audits,
identifying work performed and potential audit issues.

 The Chief Auditor monitors the status of the Annual Internal Audit Plan
and notifies the Deputy Land Commissioner/Chief Clerk of any deviations
or recommended changes.

 At the conclusion of every project, auditors complete a post audit analysis
to communicate the quality of ongoing performance and any follow-up
action needed to ensure appropriate improvements are implemented within
the audit process.

 The Chief Auditor reviews key documents, including the audit plan,
objectives, audit program, summary memo, and draft report.

 The Chief Auditor reviews a sample of work for each audit to ensure the
quality of the QC review function.

 Customer Surveys are distributed to auditee management and other
employees by the Chief Auditor immediately following the issuance of each
audit report.

 A comparison of budget-to-actual hours spent is conducted for all audits.

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Standard No. Requirement(s) Evidence of Compliance
& Title

IIA AS 1312, External assessments must be conducted at least once  The Texas Internal Auditing Act (Act) requires internal auditors to comply
External every five years by a qualified, independent assessor with the Act as well as IIA and GAO Standards, including the IIA Code of
Assessments or assessment team from outside the organization. The Ethics. IA follows the more restrictive requirement for external peer reviews,
chief audit executive must discuss with the board: which is every three years.
 The form and frequency of external assessment.
 The engagement letter for the external Quality Assurance Review (QAR),
 The qualifications and independence of the
signed by the Deputy Land Commissioner/Chief Clerk, addresses the
external assessor or assessment team, including
qualifications and independence of the external review team members,
any potential conflict of interest.
including any potential conflicts of interest.

IIA AS 1320, The chief audit executive must communicate the  The Chief Auditor prepares a report on the results of the Quality Assurance
Reporting on results of the quality assurance and improvement and Improvement Program (QAIP) annually and distributes it to the
the Quality program to senior management and the board. Commissioner and the Deputy Land Commissioner/Chief Clerk.
Assurance and Disclosure should include:
Improvement  The results of the Quality Assurance and Improvement Program include the
 The scope and frequency of both the internal and
Program results of both internal and external assessments.
external assessments.
 The qualifications and independence of the
 An external Quality Assurance Review (QAR) is obtained every 3 years and
assessor(s) or assessment team, including
performed by peers of the IA function. The QAR was last completed in June
potential conflicts of interest.
 Conclusions of assessors. 2021 (see Appendix for excerpts from the 2021 External Quality
 Corrective action plans. Assurance Review). IA will undergo its next QAR in 2024.

 The final report on the external Quality Assurance Review (QAR) is
communicated to the Commissioner, the reporting authority of the Chief
Auditor, and to the Deputy Land Commissioner/Chief Clerk. The 2021 QAR
report was provided to them in June 2021.

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Standard No. Requirement(s) Evidence of Compliance
and Title

IIA AS 1321, Use Indicating that the internal audit activity conforms  The IA activities conform with the IIA Code of Ethics and the Standards.
of “Conforms with the International Standards for the Professional
with the Practice of Internal Auditing is appropriate only if  The results of the Quality Assurance and Improvement Program include the
International supported by the results of the quality assurance and results of both internal and external assessments (see Standard No. IIA AS
Standards for the improvement program. 1320 for details).
Professional
Practice of
Internal
Auditing”

IIA AS 1322, When nonconformance with the Code of Ethics or  The IA activities conform with the IIA Code of Ethics and the Standards.
Disclosure of the Standards impacts the overall scope or operation
Nonconformance of the internal audit activity, the chief audit executive  The results of the Quality Assurance and Improvement Program include the
must disclose the nonconformance and the impact to results of both internal and external assessments of which any non-
senior management and the board. conformance was addressed. (see Standard No. IIA AS 1320 for details).

GAGAS 5.02, An audit organization conducting engagements in  The Chief Auditor has established a system of quality control designed to
Quality Control accordance with GAGAS must establish and provide reasonable assurance of compliance with the Standards, and legal
and Assurance maintain a system of quality control that is designed and regulatory requirements (see Standard No. IIA AS 1300 for details).
to provide the audit organization with reasonable
assurance that the organization and its personnel  An external Quality Assurance Review (QAR) is obtained every 3 years
comply with professional standards and applicable and performed by peers of the IA function. The QAR was last completed in
legal and regulatory requirements. June 2021 (see Appendix for excerpts from the 2021 External Quality
Assurance Review). IA will undergo its next QAR in 2024.

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Standard No. Requirement(s) Evidence of Compliance
& Title

GAGAS 5.04, An audit organization should document its quality  The IA Policies and Procedures Manual includes sections on:
System of control policies and procedures and communicate
Quality those policies and procedures to its personnel. The  Rules and Regulations that IA is required to follow
Control audit organization should document compliance with  Internal Auditing Standards (IIA and GAO, including the IIA Code of
its quality control policies and procedures and Ethics)
maintain such documentation for a period of time  Working Paper Standards
sufficient to enable those performing monitoring  Principles and Rules of Conduct
procedures and peer reviews to evaluate the extent to  Independence and Objectivity
which the audit organization complies with its quality  Conflict of Interest
control policies and procedures.  Confidentiality

 IA completes an annual assessment of its Quality Assurance and
Improvement Program (QAIP). The resulting report is provided to Executive
Management.

 All internal auditors are required to complete annual independence
statements that include any possible impairment to their independence
regarding any auditable program of the agency.

 Each individual audit requires all assigned audit team members to complete
an independence statement, assess and report on any actual and potential
independence issues.

 All evidence of quality control reviews is documented by signoffs and
coaching notes within the audit in the TeamMate auditing software.

 The IA Policies and Procedures Manual requires all working papers for
audits and other projects to be retained in accordance with the State of Texas
Records Retention Schedule for a period of seven fiscal years after the final
report is issued.

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Standard No. Requirement(s) Evidence of Compliance
and Title

GAGAS 5.05, The audit organization should establish policies and  The IA Policies and Procedures Manual provides detailed information about
Leadership procedures on leadership responsibilities for quality how to perform and document audit planning, fieldwork, and reporting.
Responsibilities within the audit organization that include designating
for Quality responsibility for quality of engagements conducted
 The IA shared drive and TeamMate Team Store contain many forms and
within the in accordance with GAGAS and communicating
templates for internal auditors to use to help ensure engagements are
Audit policies and procedures relating to quality.
performed in accordance with the Standards, and legal and regulatory
Organization
requirements.

GAGAS 5.06, The audit organization should establish policies and  The IA Policies and Procedures Manual state that all Internal audit members
Leadership procedures designed to provide reasonable assurance are expected to maintain an appropriate certification, such as Certified
Responsibilities that those assigned operational responsibility for the Public Accountant (CPA), Certified Internal Auditor (CIA), Certified
for Quality audit organization’s system of quality control have Information Systems Auditor (CISA), Certified Fraud Examiner (CFE) or
within the sufficient and appropriate experience and ability, and Certified Government Auditing Professional (CGAP).
Audit the necessary authority, to assume that responsibility.
Organization  All IA members have relevant experience and degrees and/or professional
certifications.

 The IA Policies and Procedures Manual includes requirements from the Texas
Internal Auditing Act (Texas Government Code 2102.006(b)) that the Chief
Audit Executive must be a Certified Public Accountant or Certified Internal
Auditor and have at least three years of auditing experience.

GAGAS 5.08, The audit organization should establish policies and  The IA Policies and Procedures Manual section on the IA Quality Assurance
Independence, procedures on independence and legal and ethical and Improvement Program details many of the components that help ensure
Legal, and requirements that are designed to provide reasonable auditors perform quality work and specifies that the QC Reviewer and the
Ethical assurance that the organization and its personnel Chief Auditor monitor the quality of their work.
Requirements maintain independence and comply with applicable
legal and ethical requirements.  All internal auditors are required to complete annual independence
statements that include any possible impairment to their independence
regarding any auditable program of the agency.

 The Chief Auditor considers any potential conflicts of interest in
determining audit assignments.

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Standard No. Requirement(s) Evidence of Compliance
and Title

GAGAS 5.09, At least annually, the audit organization should obtain  All internal auditors are required to complete annual independence
Independence, written affirmation of compliance with its policies and statements that include any possible impairment to their independence
Legal, and procedures on independence from all of its personnel regarding any auditable program of the agency.
Ethical required to be independent.
Requirements  Each individual audit requires all assigned audit team members to complete
an independence statement to assess and report on any actual and potential
independence issues.

 The Chief Auditor considers any potential conflicts of interest in
determining audit assignments. The Chief Auditor will determine the
appropriate actions to maintain independence in conducting internal audit
work. Possible actions include but are not limited to assigning the auditor
only to projects where independence is not an issue, reassigning the auditor
to another project or to other tasks within the project, or increased
supervision. The Chief Auditor must document these actions.

GAGAS 5.12, The audit organization should establish policies and  IA ensures current policies and procedures for the initiation, acceptance and
Initiation, procedures for the initiation, acceptance, and continuance of audits are designed to provide reasonable assurance that the
Acceptance, continuance of engagements that are designed to IA function will continually conduct only audits in which it can ensure
and provide reasonable assurance that the organization compliance with professional standards, legal requirements, and ethical
Continuance of will undertake engagements only if it: principles and that it is acting within the legal mandate or authority of the
Engagements audit organization.
a. complies with professional standards, applicable
legal and regulatory requirements, and ethical
 The IA function performs an extensive risk assessment process of the
principles;
agency programs annually in order to select relevant audits that add value to
b. acts within its legal mandate or authority; and
the agency having been identified by areas of potential risk. An annual audit
c. has the capabilities, including time and resources,
plan is developed from the risk assessment which takes into consideration
to do so.
the available audit resources. IA has developed and maintained an IA
Policies and Procedures Manual. All IA members have relevant experience
and degrees and/or professional certifications.

 Time budgets are established during the scoping phase of the audit and
budget-to-actual-hours reports are completed during all audits.

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Standard No. Requirement(s) Evidence of Compliance
and Title

GAGAS 5.15, The audit organization should establish policies and  The IA Policies and Procedures Manual state that all Internal audit members
Human procedures for human resources that are designed to are expected to maintain an appropriate certification, such as Certified
Resources provide the organization with reasonable assurance Public Accountant (CPA), Certified Internal Auditor (CIA), Certified
that it has personnel with the competence to conduct Information Systems Auditor (CISA), Certified Fraud Examiner (CFE) or
GAGAS engagements in accordance with Certified Government Auditing Professional (CGAP).
professional standards and applicable legal and
regulatory requirements.  All IA members have relevant experience, degrees and/or professional
certifications.

GAGAS 5.16, The audit organization should establish policies and  The IA Policies and Procedures Training Policy requires auditors to
Human procedures to provide reasonable assurance that complete 80 hours of continuing professional education (CPE) within a two-
Resources auditors who are performing work in accordance with year period, with at least forty hours completed each year. Of the eighty
GAGAS meet the continuing professional education hours required for a two-year period, twenty-four hours should be in
(CPE) requirements, including maintaining government-related subjects, and two hours of Ethics.
documentation of the CPE completed and any
exemptions granted. (Due to COVID-19 pandemic  All Internal Auditors track CPE hours utilizing the Training Tracking Sheet
GAGAS issued a CPE exception alert.) 3 to ensure each employee completes required hours of CPE each year.

GAGAS 5.22, The audit organization should establish policies and  The IA Policies and Procedures Manual includes detailed requirements for
Engagement procedures for engagement performance, work papers, documentation and reporting to be in conformance with the
Performance documentation, and reporting that are designed to Standards and GAGAS.
provide the audit organization with reasonable
assurance that engagements are conducted and reports  Audits are reviewed at each stage of the audit, and the audit report is
are issued in accordance with professional standards approved by the Chief Auditor prior to issuance.
and applicable legal and regulatory requirements.

3 COVID-19: GAGAS CPE Alert effective February 29, 2020: https://www.gao.gov/yellowbook/overview

The GAO provides three exceptions to the GAGAS CPE requirements for circumstances related to the COVID-19 pandemic and clarification of an existing exemption: (1) For 2-year CPE periods that
end February 29, 2020 through December 31, 2020, auditors who have not completed the 80-hour or the 24-hour CPE requirements for the 2-year period may have up to 6 months immediately
following the 2-year period to make up the deficiency; (2) Auditors are not required to complete at least 20-hours of CPE for a 1-year CPE period that ends February 29, 2020 through December 31,
2020; and (3) From the audit organization’s 2-year period in effect on February 29, 2020, auditors may carry over up to 40 hours of CPE, in excess of the 80-hour requirement, to the next CPE
measurement period. For 2-year CPE measurement periods ending after December 31, 2020, only CPE hours earned through December 31, 2020 may be carried over. Clarification of Existing
GAGAS CPE Exemption: If the auditor is working, including teleworking, audit organizations and auditors may not use the exemption outlined in paragraph 4.29.
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Standard No. Requirement(s) Evidence of Compliance
and Title

GAGAS 5.23, If auditors change the engagement objectives during  The IA Policies and Procedures Manual include procedures on determining
Engagement the engagement, they should document the revised audit objectives, staffing requirements, scheduling, time budgets, areas to be
Performance engagement objectives and the reasons for the covered, detailed tests to be performed, and the extent to which a detailed
changes. examination is to be conducted during the initial planning phase. Each audit
requires an Audit Plan which identifies the objectives and scope of the
engagement.

 If there is a change in audit scope or objectives, the Chief Audit Executive
will issue a “memo to file” to Executive Management and the program area
being audited. The memo will provide justification for any changes in scope
or objective. Any changes to an audit objective detailed in the Annual
Internal Audit Plan require approval from the Commissioner.

GAGAS 5.24, The audit organization should establish policies and  The IA Policies and Procedures Manual contains procedures on conducting
Engagement procedures designed to provide it with reasonable consulting, management assistance, and special project engagements. The
Performance assurance that: Chief Auditor will obtain approval from the Chief Clerk for projects that
may require a significant number of hours to impact the projects in the
a. appropriate consultation takes place on difficult
Annual Audit Plan. If a report is applicable to the special project or
or contentious issues that arise among
consultation engagement, the Chief Auditor will provide the requestor a
engagement team members in the course of
report detailing the information gathered or observations made and will
conducting a GAGAS engagement;
provide the report to executive management as appropriate.
b. both the individual seeking consultation and the
individual consulted document and agree upon
the nature and scope of such consultations; and
c. the conclusions resulting from consultations are
documented, understood by both the individual
seeking consultation and the individual
consulted, and implemented.

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Standard No. Requirement(s) Evidence of Compliance
and Title

GAGAS 5.25, If an engagement is terminated before it is completed  If an engagement is terminated before it is completed and an audit report is
Engagement and an audit report is not issued, auditors should not issued, the Chief Audit Executive will issue a “memo to file” to
Performance document the results of the work to the date of Executive Management and the program area being audited. The memo will
termination and why the engagement was terminated. provide justification for terminating the engagement. Any changes to an
audit objective detailed in the Annual Internal Audit Plan must be approved
by the Commissioner.

GAGAS 5.36, The audit organization should establish policies and  The IA Policies and Procedures Manual contains detailed Quality Control
Engagement procedures that require engagement team members Review procedures required for each audit and establishes criteria for
Performance with appropriate levels of skill and proficiency in acceptable working papers.
Supervision auditing to supervise engagements and review work
performed by other engagement team members.  A QC Reviewer is assigned to every engagement to perform an internal
review of and sign off on all work papers to ensure adherence to the
Standards and applicable legal and regulatory requirements.

 The Chief Auditor reviews and signs off on key working papers, including,
but not limited to, the audit plan, audit program, and referenced draft report.

 All IA members have relevant experience and degrees and/or professional
certifications.

 IA’s standard audit program in TeamMate includes a planning step in which
management and the Chief Auditor selects audit team members based on an
evaluation of team competencies and qualifications required to perform
assigned roles for each project.

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Standard No. Requirement(s) Evidence of Compliance
and Title

GAGAS 5.37, The audit organization should assign responsibility  The Chief Auditor is assigned responsibility for each engagement and
Engagement for each engagement to an engagement partner or reviews and signs off on key working papers, including, but not limited to,
Performance director with authority designated by the audit the audit plan, audit program, and referenced draft report. The final report
Supervision organization to assume that responsibility and should and management responses to corrective actions are reviewed and approved
establish policies and procedures requiring the by the Chief Auditor.
organization to:
 The Chief Auditor meets with each audit team weekly to discuss the status
a. communicate the identity and role of the
of the audit and potential issues.
engagement partner or director to management
and those charged with governance of the audited
entity and
b. clearly define the responsibilities of the
engagement partner or director and communicate
them to that individual.

GAGAS 5.42, The audit organization should establish policies and  The IA function has policies and procedures that ensure the continued
Monitoring of procedures for monitoring its system of quality monitoring of quality within the work performed by the IA function.
Quality control.
 This annual QAIP report constitutes the results of the annual internal quality
assessment.

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Standard No. Requirement(s) Evidence of Compliance
and Title

GAGAS 5.43, The audit organization should perform monitoring  The IA function has policies and procedures that ensure the continued
Monitoring of procedures that enable it to assess compliance with monitoring of quality within the work performed by the IA function.
Quality professional standards and quality control policies
and procedures for GAGAS engagements. Individuals  This annual QAIP report constitutes the results of the annual internal quality
performing monitoring should have sufficient assessment.
expertise and authority within the audit organization.
 An external Quality Assurance Review (QAR) is obtained every 3 years and
performed by peers of the IA function. The QAR was last completed in June
2021 (see Appendix for excerpts from the 2021 External Quality
Assurance Review). IA will undergo its next QAR in 2024.

 The IA Policies and Procedures Manual state that all Internal audit members
are expected to maintain an appropriate certification, such as Certified
Public Accountant (CPA), Certified Internal Auditor (CIA), Certified
Information Systems Auditor (CISA), Certified Fraud Examiner (CFE) or
Certified Government Auditing Professional (CGAP).

 All IA members have relevant experience and degrees and/or professional
certifications.

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Standard No. Requirement(s) Evidence of Compliance
and Title

GAGAS 5.44, The audit organization should analyze and summarize  The IA function has policies and procedures that ensure the continued
Monitoring of the results of its monitoring process at least annually, monitoring of quality within the work performed by the IA function.
Quality with identification of any systemic or repetitive issues
needing improvement, along with recommendations  This annual QAIP report constitutes the results of the annual internal quality
for corrective action. The audit organization should assessment. Process improvement recommendations noted in the QAIP
communicate to the relevant engagement partner or report will be considered during the next update of the IA Policies and
director, and other appropriate personnel, any Procedures Manual.
deficiencies noted during the monitoring process and
recommend appropriate remedial action. This
communication should be sufficient to enable the
audit organization and appropriate personnel to take
prompt corrective action related to deficiencies, when
necessary, in accordance with their defined roles and
responsibilities. Information communicated should
include the following:
a. a description of the monitoring procedures
performed;
b. the conclusions reached from the monitoring
procedures; and
c. when relevant, a description of systemic,
repetitive, or other deficiencies and of the actions
taken to resolve those deficiencies.

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Standard No. Requirement(s) Evidence of Compliance
and Title

GAGAS 5.45, The audit organization should evaluate the effects of  During its annual Quality Assurance and Improvement Program assessment,
Monitoring of deficiencies noted during monitoring of the audit IA evaluates existing policies, procedures, and processes to note any
Quality organization’s system of quality control to determine deficiencies and review compliance with professional standards and
and implement appropriate actions to address the applicable legal and regulatory requirements. Process improvement
deficiencies. This evaluation should include recommendations noted in the QAIP report will be considered during the
assessments to determine if the deficiencies noted next update of the IA Policies and Procedures Manual.
indicate that the audit organization’s system of
quality control is insufficient to provide it with  The IA function has policies and procedures that ensure the continued
reasonable assurance that it complies with monitoring of quality within the work performed by the IA function.
professional standards and applicable legal and
regulatory requirements, and that accordingly the  An external Quality Assurance Review (QAR) is obtained every 3 years and
reports that the audit organization issues are not performed by peers of the IA function. The QAR was last completed in June
appropriate in the circumstances. 2021 (see Appendix for excerpts from the 2021 External Quality
Assurance Review). IA will undergo its next QAR in 2024.

GAGAS 5.46, The audit organization should establish policies and  The IA Policies and Procedures Manual requires all working papers for
Monitoring of procedures that require retention of engagement audits and other projects to be retained in accordance with the State of
Quality documentation for a period of time sufficient to Texas Records Retention Schedule for a period of seven fiscal years after
permit those performing monitoring procedures and the final report is issued.
peer review of the organization to evaluate its
compliance with its system of quality control or for a
longer period if required by law or regulation.

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Standard No. Requirement(s) Evidence of Compliance
and Title

GAGAS 5.60, Each audit organization conducting engagements in  An external Quality Assurance Review (QAR) is obtained every 3 years and
External Peer accordance with GAAS must obtain an external peer performed by peers of the IA function. The QAR was last completed in June
Review review conducted by reviewers independent of the 2021 (see Appendix for excerpts from the 2021 External Quality
audit organization being reviewed. The peer review Assurance Review). IA will undergo its next QAR in 2024.
should be sufficient in scope to provide a reasonable
basis for determining whether, for the period under
review, (1) the reviewed audit organization’s system
of quality control was suitably designed and (2) the
organization is complying with its quality control
system so that it has reasonable assurance that it is
performing and reporting in conformity with
professional standards and applicable legal and
regulatory requirements in all material respects.

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APPENDIX:

Excerpts of the 2021 External Quality Assurance Review of the Texas General Land Office, Office of Internal Audit

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IN THE FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS

Case No. 15-25-00227-CV
(Transferred from the Third Court of Appeals)

IN RE CEDRIC M. SCOTT, PhD, Relator, Pro Se

Original Proceeding from Cause No. D-1-GN-25-000006
250th Judicial District Court, Travis County, Texas

EXHIBIT 2 - GLO FY2022 INTERNAL AUDIT QUALITY ASSURANCE
AND IMPROVEMENT PROGRAM (QAIP) REPORT

(Referenced in Section IV of Relator’s Motion to Expedite)
Submitted by:
Cedric M. Scott, PhD
Relator, Pro Se
Date: October 9, 2023

To: Dawn Buckingham, M.D., Commissioner

From: Tracey Hall, Chief Auditor

cc: Jennifer Jones, Deputy Land Commissioner
Mark Havens, Chief Clerk

Subject: 2023 Annual Report on the Internal Audit Quality Assurance and Improvement
Program
______________________________________________________________________________

The Office of Internal Audit for the Texas General Land Office (GLO) and Veterans Land Board
(VLB) maintains an ongoing QAIP and performs continuous monitoring of the quality of internal
audit activities, as well as periodic reviews conducted through self-assessment and external quality
assessment reviews.

This report and the detailed results included are intended to satisfy both sets of Standards by
demonstrating that an internal assessment was performed, listing all the relevant IIA and GAO
requirements, and indicating the evidence of compliance with each requirement. The Office of
Internal Audit successfully passed its external quality assessment in June 2021. The Office of
Internal Audit will undergo its next external quality assessment in 2024 (see Appendix for excerpts
from the 2021 External Quality Assurance Review).

If you have questions or comments about this report, please contact me at (512) 463-6078.

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DETAILED RESULTS:

Standard No. Requirement(s) Evidence of Compliance
and Title

IIA AS 1300 1, The chief audit executive (CAE, also referred to as  The Internal Audit (IA) Policies and Procedures Manual has been developed
Quality the Chief Auditor) must develop and maintain a and maintained on the IA shared drive. It is updated as needed, at least every
Assurance and quality assurance and improvement program that three years, with the most recent revision conducted in July 2022.
Improvement covers all aspects of the internal audit activity.
Program  A General Audit Program comprising detailed procedures for ensuring
compliance with the Standards, GAGAS, IA policies and procedures, and
applicable legal and regulatory requirements are utilized during every audit
engagement. These procedures include:

o Audit Team Competencies
o Independence Statements
o Project Planning Summaries
o Project Risk Assessments and
o Fieldwork programs

 The Chief Auditor reviews and approves audit objectives, plans, testing
programs, and reports for all audit engagements.

1 The Institute of Internal Auditors’ (IIA) International Professional Practices Framework (IPPF, commonly referred to as the Red Book) is the conceptual framework that organizes authoritative

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Standard No. Requirement(s) Evidence of Compliance
and Title

IIA AS 1310, The quality assurance and improvement program must  The IA Manager reviews all audit work papers to ensure their integrity,
Requirements include both internal and external assessments. compliance, and satisfaction with the Standards, GAGAS, and audit
of the Quality objectives.
Assurance and
Improvement  The IA Manager and the Chief Auditor review and approve key audit plans,
Program documents, and samples of the QC work performed.

 An external Quality Assurance Review (QAR) 2 is obtained every three years
and performed by peers of the IA function. The QAR was last completed in
June 2021 (see Appendix for excerpts from the 2021 External Quality
Assurance Review). IA will undergo its next QAR in 2024.

2 The IIA's International Professional Practices Framework (IPPF), the U.S. Government Accountability Office’s (GAO) Government Auditing Standards (known as the Yellow Book), commonly

referred to as generally accepted government auditing standards (GAGAS), and the Texas Internal Auditing Act (the Act) require that IA functions obtain external quality assurance reviews to assess
compliance with Standards and the Act and to appraise the quality of their operations. GAGAS require these reviews at least every three years. A periodic external quality assurance review, or peer
review, of the IA function is an essential part of a comprehensive quality assurance program. If the QAR is successfully fulfilled (passed) the Chief Auditor may state that the internal audit activity
conforms with the International Standards for the Professional Practice of Internal Auditing only if the results of the quality assurance and improvement program support such a statement (IIA AS
1321).
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Standard No. Requirement(s) Evidence of Compliance
and Title

IIA AS 1311, Internal assessments must include:  The IA Manager for each audit reviews and signs off on every audit
Internal working paper to ensure completeness and compliance with the Standards.
 Ongoing monitoring of the performance of the
Assessments
internal audit activity.
 The Chief Auditor and IA Manager meet with each audit team weekly,
 Periodic self-assessment or assessments by other
based on the Agile audit process, to discuss the audit status and potential
persons within the organization with sufficient
issues.
knowledge of internal audit practices.
 Time and resources for each audit are tracked by the audit phase regarding
planning the audit, assessing risk, performing fieldwork, reporting, and
quality control and supervisory review.

 Auditors communicate to management through a project status report and
with the Chief Auditor continuously throughout the audits, identifying work
performed and potential audit issues.

 The Chief Auditor monitors the status of the Annual Internal Audit Plan
and notifies the Commissioner and Chief Clerk of any deviations or
recommended changes.

 After every project, auditors complete a post-audit analysis to communicate
ongoing performance quality and any follow-up action needed to
implement appropriate improvements within the audit process.

 The Chief Auditor and IA Manager review key documents, including the
audit plan, objectives, audit program, summary memo, and draft report.

 The Chief Auditor and IA Manager review work for each audit to ensure
the quality of the QC review function.

 Customer Surveys are distributed to auditee management and other
employees by the Chief Auditor immediately following the issuance of each
audit report.

 A comparison of budget-to-actual hours spent is conducted for all audits.

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Standard No. Requirement(s) Evidence of Compliance
& Title

IIA AS 1312, External assessments must be conducted at least once  The Texas Internal Auditing Act (Act) requires internal auditors to comply
External every five years by a qualified, independent assessor with the Act and IIA and GAO Standards, including the IIA Code of Ethics.
Assessments or assessment team from outside the organization. The IA follows the more restrictive requirement for external peer reviews every
chief audit executive must discuss the following with three years.
the board:
 The engagement letter for the external Quality Assurance Review (QAR),
 The form and frequency of external assessment.
signed by the Chief Clerk, addresses the qualifications and independence of
 The qualifications and independence of the
the external review team members, including any potential conflicts of
external assessor or assessment team, including
interest.
any potential conflict of interest.

IIA AS 1320, The chief audit executive must communicate the  The Chief Auditor annually prepares a report on the Quality Assurance and
Reporting on results of the quality assurance and improvement Improvement Program (QAIP) results and distributes it to the Commissioner
the Quality program to senior management and the board. and Chief Clerk.
Assurance and Disclosure should include:
Improvement  The results of the Quality Assurance and Improvement Program include the
 The scope and frequency of both the internal and
Program results of both internal and external assessments.
external assessments.
 The qualifications and independence of the
 An external Quality Assurance Review (QAR) is obtained every three years
assessor(s) or assessment team, including
and performed by peers of the IA function. The QAR was last completed in
potential conflicts of interest.
 Conclusions of assessors. June 2021 (see Appendix for excerpts from the 2021 External Quality
 Corrective action plans. Assurance Review). IA will undergo its next QAR in 2024.

 The final report on the external Quality Assurance Review (QAR) is
communicated to the Commissioner and Chief Clerk, the reporting authority
of Internal Audit. The 2021 QAR report was provided to them in June 2021.

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Standard No. Requirement(s) Evidence of Compliance
and Title

IIA AS 1321, Use Indicating that the internal audit activity conforms  The IA activities conform with the IIA Code of Ethics and the Standards.
of “Conforms with the International Standards for the Professional
with the Practice of Internal Auditing is appropriate only if  The Quality Assurance and Improvement Program results include internal
International supported by the results of the quality assurance and and external assessments (see Standard No. IIA AS 1320 for details).
Standards for the improvement program.
Professional
Practice of
Internal
Auditing”

IIA AS 1322, When non-conformance with the Code of Ethics or  The IA activities conform with the IIA Code of Ethics and the Standards.
Disclosure of the Standards impacts the overall scope or operation
Nonconformance of the internal audit activity, the chief audit executive  The Quality Assurance and Improvement Program includes the results of
must disclose the nonconformance and the impact to internal and external assessments of which any non-conformance was
senior management and the board. addressed. (See Standard No. IIA AS 1320 for details).

GAGAS 5.02, An audit organization conducting engagements in  The Chief Auditor has established a system of quality control designed to
Quality Control accordance with GAGAS must establish and provide reasonable assurance of compliance with the Standards and legal
and Assurance maintain a system of quality control that is designed and regulatory requirements (see Standard No. IIA AS 1300 for details).
to provide the audit organization with reasonable
assurance that the organization and its personnel  An external Quality Assurance Review (QAR) is obtained every three
comply with professional standards and applicable years and performed by peers of the IA function. The QAR was last
legal and regulatory requirements. completed in June 2021 (see Appendix for excerpts from the 2021
External Quality Assurance Review). IA will undergo its next QAR in
2024.

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Standard No. Requirement(s) Evidence of Compliance
& Title

 IA completes an annual assessment of its Quality Assurance and
Improvement Program (QAIP). The resulting report is provided to Executive
Management.

 All internal auditors must complete annual independence statements that
include any possible impairment to their independence regarding any
auditable program of the agency.

 Each audit requires all assigned audit team members to complete an
independence statement assessing and reporting on any actual and potential
independence issues.

 Signoffs and coaching notes document all evidence of quality control
reviews within the audit in the TeamMate auditing software.

 The IA Policies and Procedures Manual requires all working papers for
audits and other projects to be retained per the State of Texas Records
Retention Schedule for seven fiscal years after the final report is issued.

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Standard No. Requirement(s) Evidence of Compliance
and Title

GAGAS 5.05, The audit organization should establish policies and  The IA Policies and Procedures Manual provides detailed information about
Leadership procedures on leadership responsibilities for quality performing and documenting audit planning, fieldwork, and reporting.
Responsibilities within the audit organization that include designating
for Quality responsibility for quality of engagements conducted
 The IA shared drive and TeamMate Team Store contains many forms and
within the in accordance with GAGAS and communicating
templates for internal auditors to use to help ensure engagements are
Audit policies and procedures relating to quality.
performed in accordance with the Standards and legal and regulatory
Organization
requirements.

GAGAS 5.06, The audit organization should establish policies and  The IA Policies and Procedures Manual states that all Internal audit
Leadership procedures designed to provide reasonable assurance members are expected to maintain an appropriate certification, such as
Responsibilities that those assigned operational responsibility for the Certified Public Accountant (CPA), Certified Internal Auditor (CIA),
for Quality audit organization’s system of quality control have Certified Information Systems Auditor (CISA), Certified Fraud Examiner
within the sufficient and appropriate experience and ability, and (CFE) or Certified Government Auditing Professional (CGAP).
Audit the necessary authority to assume that responsibility.
Organization  All IA members have relevant experience, degrees, and professional
certifications.

GAGAS 5.08, The audit organization should establish policies and  The IA Policies and Procedures Manual section on the IA Quality Assurance
Independence, procedures on independence and legal and ethical and Improvement Program details many components that help ensure
Legal, and requirements designed to provide reasonable auditors perform quality work and specifies that the IA Manager and the
Ethical assurance that the organization and its personnel Chief Auditor monitor the quality of their work.
Requirements maintain independence and comply with applicable
legal and ethical requirements.  All internal auditors are required to complete annual independence
statements that include any possible impairment to their independence
regarding any auditable program of the agency.

 The Chief Auditor considers any potential conflicts of interest in
determining audit assignments.

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Standard No. Requirement(s) Evidence of Compliance
and Title

GAGAS 5.09, At least annually, the audit organization should obtain  All internal auditors are required to complete annual independence
Independence, written affirmation of compliance with its policies and statements that include any possible impairment to their independence
Legal, and procedures on independence from all of its personnel regarding any auditable program of the agency.
Ethical required to be independent.
Requirements  Each audit requires all assigned audit team members to complete an
independence statement to assess and report on any actual and potential
independence issues.

 The Chief Auditor considers any potential conflicts of interest in
determining audit assignments. The Chief Auditor will determine the
appropriate actions to maintain independence in conducting internal audit
work. Possible activities include but are not limited to assigning the auditor
only to projects where independence is not an issue, reassigning the auditor
to another project or other tasks within the project, or increased supervision.
The Chief Auditor must document these actions.

GAGAS 5.12, The audit organization should establish policies and  IA ensures current policies and procedures for the initiation, acceptance, and
Initiation, procedures for the initiation, acceptance, and continuance of audits are designed to provide reasonable assurance that the
Acceptance, continuance of engagements that are designed to IA function will continually conduct only audits in which it can ensure
and provide reasonable assurance that the organization compliance with professional standards, legal requirements, and ethical
Continuance of will undertake engagements only if it: principles and that it is acting within the legal mandate or authority of the
Engagements audit organization.
a. complies with professional standards, applicable
legal and regulatory requirements, and ethical
 The IA function performs an extensive risk assessment process of the
principles;
agency programs annually to select relevant audits that add value to the
b. acts within its legal mandate or authority; and
agency having been identified by areas of potential risk. An annual audit
c. has the capabilities, including time and resources,
plan is developed from the risk assessment, which considers the available
to do so.
audit resources. IA has developed and maintained an IA Policies and
Procedures Manual. All IA members have relevant experience degrees and
professional certifications.

 Time budgets are established during the scoping phase of the audit, and
budget-to-actual-hours reports are completed during all audits.

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Standard No. Requirement(s) Evidence of Compliance
and Title

GAGAS 5.15, The audit organization should establish policies and  The IA Policies and Procedures Manual states that all Internal audit
Human procedures for human resources designed to provide members are expected to maintain an appropriate certification, such as
Resources the organization with reasonable assurance that it has Certified Public Accountant (CPA), Certified Internal Auditor (CIA),
personnel with the competence to conduct GAGAS Certified Information Systems Auditor (CISA), Certified Fraud Examiner
engagements in accordance with professional (CFE) or Certified Government Auditing Professional (CGAP).
standards and applicable legal and regulatory
requirements.  All IA members have relevant experience, degrees, and professional
certifications.

GAGAS 5.16, The audit organization should establish policies and  The IA Policies and Procedures Training Policy requires auditors to
Human procedures to provide reasonable assurance that complete 80 hours of continuing professional education (CPE) within two
Resources auditors who are performing work in accordance with years, with at least 40 hours completed each year. Of the eighty hours
GAGAS meet the continuing professional education required for two years, twenty-four hours should be in government-related
(CPE) requirements, including maintaining subjects and two hours of Ethics.
documentation of the CPE completed and any
exemptions granted. (Due to COVID-19 pandemic  All Internal Auditors track CPE hours utilizing the Training Tracking Sheet
GAGAS issued a CPE exception alert.) 3 to ensure each employee completes the required hours of CPE each year.

GAGAS 5.22, The audit organization should establish policies and  The IA Policies and Procedures Manual includes detailed requirements for
Engagement procedures for engagement performance, work papers, documentation, and reporting to be in conformance with the
Performance documentation, and reporting that are designed to Standards and GAGAS.
provide the audit organization with reasonable
assurance that engagements are conducted, and  Audits are reviewed at each stage of the audit, and the audit report is
reports are issued in accordance with professional approved by the Chief Auditor prior to issuance.
standards and applicable legal and regulatory
requirements.

3 COVID-19: GAGAS CPE Alert effective February 29, 2020: https://www.gao.gov/yellowbook/overview

The GAO provides three exceptions to the GAGAS CPE requirements for circumstances related to the COVID-19 pandemic and clarification of an existing exemption: (1) For 2-year CPE periods that
end February 29, 2020 through December 31, 2020, auditors who have not completed the 80-hour or the 24-hour CPE requirements for the 2-year period may have up to 6 months immediately
following the 2-year period to make up the deficiency; (2) Auditors are not required to complete at least 20-hours of CPE for a 1-year CPE period that ends February 29, 2020 through December 31,
2020; and (3) From the audit organization’s 2-year period in effect on February 29, 2020, auditors may carry over up to 40 hours of CPE, in excess of the 80-hour requirement, to the next CPE
measurement period. For 2-year CPE measurement periods ending after December 31, 2020, only CPE hours earned through December 31, 2020 may be carried over. Clarification of Existing
GAGAS CPE Exemption: If the auditor is working, including teleworking, audit organizations and auditors may not use the exemption outlined in paragraph 4.29.
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Standard No. Requirement(s) Evidence of Compliance
and Title

GAGAS 5.23, If auditors change the engagement objectives during  The IA Policies and Procedures Manual includes procedures on determining
Engagement the engagement, they should document the revised audit objectives, staffing requirements, scheduling, time budgets, areas to be
Performance engagement objectives and the reasons for the covered, detailed tests to be performed, and the extent to which a thorough
changes. examination is to be conducted during the initial planning phase. Each audit
requires an Audit Plan which identifies the objectives and scope of the
engagement.

GAGAS 5.24, The audit organization should establish policies and  The IA Policies and Procedures Manual contains procedures for conducting
Engagement procedures designed to provide it with reasonable consulting, management assistance, and special project engagements. The
Performance assurance that: Chief Auditor will obtain approval from the Chief Clerk for projects that
may require a significant number of hours to impact the projects in the
a. appropriate consultation takes place on difficult
Annual Audit Plan. If a report is applicable to the particular project or
or contentious issues that arise among
consultation engagement, the Chief Auditor will provide the requestor a
engagement team members in the course of
report detailing the information gathered or observations made and will
conducting a GAGAS engagement;
provide the report to executive management as appropriate.
b. both the individual seeking consultation and the
individual consulted document and agree upon
the nature and scope of such consultations; and
c. the conclusions resulting from consultations are
documented, understood by both the individual
seeking consultation and the individual
consulted, and implemented.

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Standard No. Requirement(s) Evidence of Compliance
and Title

GAGAS 5.36, The audit organization should establish policies and  The IA Policies and Procedures Manual contains detailed Quality Control
Engagement procedures that require engagement team members Review procedures required for each audit and establishes criteria for
Performance with appropriate levels of skill and proficiency in acceptable working papers.
Supervision auditing to supervise engagements and review work
performed by other engagement team members.  The IA Manager performs an internal review of and sign off on all work
papers for every engagement to ensure adherence to the Standards and
applicable legal and regulatory requirements.

 The Chief Auditor, along with the IA Manager, reviews and signs off on
key working papers, including, but not limited to, the audit plan, audit
program, and referenced draft report.

 All IA members have relevant experience, degrees, and professional
certifications.

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Standard No. Requirement(s) Evidence of Compliance
and Title

GAGAS 5.37, The audit organization should assign responsibility  The Chief Auditor is assigned responsibility for each engagement and
Engagement for each engagement to an engagement partner or reviews and signs off on key working papers, including, but not limited to,
Performance director with authority designated by the audit the audit plan, audit program, and referenced draft report. The Chief Auditor
Supervision organization to assume that responsibility and should reviews and approves the final report and management responses to
establish policies and procedures requiring the corrective actions.
organization to:
 The Chief Auditor and IA Manager meets with each audit team weekly to
a. communicate the identity and role of the
discuss the audit status and potential issues.
engagement partner or director to management
and those charged with governance of the audited
entity and
b. clearly define the responsibilities of the
engagement partner or director and communicate
them to that individual.

GAGAS 5.42, The audit organization should establish policies and  The IA function has policies and procedures that ensure the continued
Monitoring of procedures for monitoring its quality control system. monitoring of quality within the work performed by the IA function.
Quality
 This annual QAIP report constitutes the results of the annual internal quality
assessment.

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Standard No. Requirement(s) Evidence of Compliance
and Title

GAGAS 5.43, The audit organization should perform monitoring  The IA function has policies and procedures that ensure the continued
Monitoring of procedures that enable it to assess compliance with monitoring of quality within the work performed by the IA function.
Quality professional standards and quality control policies
and procedures for GAGAS engagements. Individuals  This annual QAIP report constitutes the results of the annual internal quality
performing monitoring should have sufficient assessment.
expertise and authority within the audit organization.
 An external Quality Assurance Review (QAR) is obtained every three years
and performed by peers of the IA function. The QAR was last completed in
June 2021 (see Appendix for excerpts from the 2021 External Quality
Assurance Review). IA will undergo its next QAR in 2024.

 The IA Policies and Procedures Manual states that all Internal audit
members are expected to maintain an appropriate certification, such as
Certified Public Accountant (CPA), Certified Internal Auditor (CIA),
Certified Information Systems Auditor (CISA), Certified Fraud Examiner
(CFE) or Certified Government Auditing Professional (CGAP).

 All IA members have relevant experience, degrees, and professional
certifications.

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Standard No. Requirement(s) Evidence of Compliance
and Title

GAGAS 5.44, The audit organization should analyze and summarize  The IA function has policies and procedures that ensure the continued
Monitoring of the results of its monitoring process at least annually, monitoring of quality within the work performed by the IA function.
Quality with the identification of any systemic or repetitive
issues needing improvement, along with  This annual QAIP report constitutes the results of the annual internal quality
recommendations for corrective action. The audit assessment. Process improvement recommendations noted in the QAIP
organization should communicate to the relevant report will be considered during the next update of the IA Policies and
engagement partner or director and other appropriate Procedures Manual.
personnel any deficiencies noted during the
monitoring process and recommend appropriate
remedial action. This communication should be
sufficient to enable the audit organization and
appropriate personnel to take prompt corrective action
related to deficiencies, when necessary, in accordance
with their defined roles and responsibilities.
Information communicated should include the
following:
a. a description of the monitoring procedures
performed;
b. the conclusions reached from the monitoring
procedures; and
c. when relevant, a description of systemic,
repetitive, or other deficiencies and of the actions
taken to resolve those deficiencies.

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Standard No. Requirement(s) Evidence of Compliance
and Title

GAGAS 5.45, The audit organization should evaluate the effects of  During its annual Quality Assurance and Improvement Program assessment,
Monitoring of deficiencies noted during monitoring of the audit IA evaluates existing policies, procedures, and processes to note
Quality organization’s system of quality control to determine deficiencies and review compliance with professional standards and
and implement appropriate actions to address the applicable legal and regulatory requirements. Process improvement
deficiencies. This evaluation should include recommendations noted in the QAIP report will be considered during the
assessments to determine if the deficiencies noted next update of the IA Policies and Procedures Manual.
indicate that the audit organization’s system of
quality control is insufficient to provide it with  The IA function has policies and procedures that ensure the continued
reasonable assurance that it complies with monitoring of quality within the work performed by the IA function.
professional standards and applicable legal and
regulatory requirements and that, accordingly, the  An external Quality Assurance Review (QAR) is obtained every three years
reports that the audit organization issues are not and performed by peers of the IA function. The QAR was last completed in
appropriate in the circumstances. June 2021 (see Appendix for excerpts from the 2021 External Quality
Assurance Review). IA will undergo its next QAR in 2024.

GAGAS 5.46, The audit organization should establish policies and  The IA Policies and Procedures Manual requires all working papers for
Monitoring of procedures that require retention of engagement audits and other projects to be retained in accordance with the State of
Quality documentation for a period of time sufficient to Texas Records Retention Schedule for a period of seven fiscal years after
permit those performing monitoring procedures and the final report is issued.
peer review of the organization to evaluate its
compliance with its quality control system or for a
longer period if required by law or regulation.

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Standard No. Requirement(s) Evidence of Compliance
and Title

GAGAS 5.60, Each audit organization conducting engagements in  An external Quality Assurance Review (QAR) is obtained every three years
External Peer accordance with GAAS must obtain an external peer and performed by peers of the IA function. The QAR was last completed in
Review review conducted by reviewers independent of the June 2021 (see Appendix for excerpts from the 2021 External Quality
audit organization being reviewed. The peer review Assurance Review). IA will undergo its next QAR in 2024.
should be sufficient in scope to provide a reasonable
basis for determining whether, for the period under
review, (1) the reviewed audit organization’s system
of quality control was suitably designed and (2) the
organization is complying with its quality control
system so that it has reasonable assurance that it is
performing and reporting in conformity with
professional standards and applicable legal and
regulatory requirements in all material respects.

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APPENDIX:

Excerpts of the 2021 External Quality Assurance Review of the Texas General Land Office, Office of Internal Audit

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Page 19 of 19
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
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certificate of service that complies with all applicable rules.

Envelope ID: 108914138
Filing Code Description: Motion - Exempt
Filing Description: REVISED_Relator's Motion to Expedite
Status as of 12/10/2025 7:28 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Honorable Cory R.Liu 250.submission@traviscountytx.gov 12/9/2025 9:33:51 PM SENT

Jeffrey Moore jmoore@bickerstaff.com 12/9/2025 9:33:51 PM SENT

Sara Labashosky slabashosky@bickerstaff.com 12/9/2025 9:33:51 PM SENT

Gunnar Seaquist gseaquist@bickerstaff.com 12/9/2025 9:33:51 PM SENT

In Re Cedric M. Scott, PhD v. the State of Texas

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