The draft SOP is being issued in response to request for clarity on data/record access as intimated by field offices and as recommended by TF II of the 29th AG conference. Comments of the CTO have also been received. It is hoped that the draft SOP addresses most concerns experienced in the field. If not, please do revert with suggested changes or issues that we need to address. You are requested to send in your comments by 20 January 2020.
Two concerns that have been so far flagged is that while chapter 13 of the Regulations gives an impression that data will be requested when the audit team goes to the audited entity for an audit, we need to get data well in advance of the field audit of an audited entity. Data obtained during field audit should only supplement data collected in advance. This understanding is crucial for interpreting existing guidance. Secondly, issues that perhaps remain to be addressed are lack of enforce-ability in access to records and a possible curtailment of time of three months given to the Executive to report action taken by them in cases of denial of access (Regulation 186).