Compliance is not performance

Dear Editor,
The author of the letter titled “Bhagwandin’s letter betrays his authority as a qualified auditor or accountant” fails to appreciate the core contention of SphereX’s critical review of the National Drainage and Irrigation Authority’s (NDIA) performance audit – namely, that the audit does not speak to the effectiveness of the NDIA in fulfilling its statutory mandate.
Our position remains that the report in question is not a performance audit as defined by INTOSAI standards, but rather a compliance or administrative audit. This distinction is fundamental to audit classification and cannot be dismissed by rhetorical labeling.
Importantly, our review did not in any way seek to defend the NDIA, nor did it dispute the audit’s factual findings. It was not, as the author suggests, an attack on the Audit Office. Rather, it is a methodological critique – a professional examination of scope and classification in relation to the stated objective of the audit.
The author’s attempt to question my authority, while unfortunate, is misplaced. The issue here is not about “authority” – perceived or otherwise – but about the logic of methodology. Lacking the ability to credibly rebut our analytical argument, the author resorted to labeling the review as “academic” and “theoretical.” Ironically, that admission implicitly acknowledges that our critique is intellectually sound and grounded in principle.
If one wishes to speak of practicality, then let us be practical. The stated objective of the audit, as outlined in its introduction, was to determine whether NDIA effectively achieved its mandate. Yet, upon reading the body of the report – its findings and recommendations – it becomes evident that it fails entirely to address that objective. It audits compliance systems and administrative controls, but not performance outcomes.
That is the essence of our critique, and I reaffirm it unequivocally. It is not an attack, but a respectful, evidence-based assessment calling for the Auditor General to align methodology and scope with the audit’s stated performance objective.
Now, to another of the author’s misinformed assertions – that the Key Performance Indicators (KPIs) identified in our review are “futuristic.” That notion is, quite frankly, fatally amusing. The audit itself covered the period January 2021 to June 2024 – a period during which NDIA operated, received subventions from the national treasury, and executed its drainage and irrigation mandate.
It is therefore self-evident that data ought to exist for that period – data on assets managed, drainage canals maintained, irrigation structures rehabilitated, and communities served. To describe these metrics as “futuristic” betrays either a misunderstanding of the audit’s timeframe or a lack of familiarity with performance auditing practice.
In fact, credit must be given to the audit report for acknowledging that NDIA has not defined its KPIs. It is precisely for this reason, and understandably so, that what should have been a performance audit devolved into a compliance audit. But this does not absolve the auditors of responsibility. They could have – and should have – defined provisional KPIs drawn from the NDIA’s statutory mandate and then measured performance within that framework. That is what a competent performance audit does.
The contention, therefore, is not about the absence of data, but about the absence of methodological rigor. To suggest otherwise is to excuse the very deficiency the audit itself identifies.
From the perspective of practicality and public accountability, the performance audit is a report to the shareholders of the State, the people of Guyana. The majority of citizens are not auditors or accountants. They do not need to be. What they need is clarity on how effectively their tax dollars are being used to deliver tangible outcomes.
The question every taxpayer ought to ask is simple: Did the NDIA achieve its objectives in drainage and irrigation, and what measurable impact was achieved for the resources expended? Unfortunately, this audit report tells the public little about that. It tells us much about internal administrative deficiencies, but nothing about actual performance – kilometers of canals maintained, structures rehabilitated, acres irrigated, or communities protected from flooding.
In short, compliance is not performance. And even if the NDIA failed to meet those tangible outcomes in so far as performance is concerned, then let the findings show that to the taxpayer. That is precisely the point of a performance audit – to assess effectiveness, not to shield or to indict, but to inform. This reinforces that our critique is not a defence of NDIA, but a call for the Auditor General to conduct a true performance audit that measures and reports outcomes as they are.
Finally, since the author made much of “authority” and sought to cast aspersions on the credibility of my firm, allow me to clarify, through evidence, the nature and practicality of our work.
SphereX Professional Services has a proven track record of forensic and investigative audit work that has produced tangible enforcement outcomes. For example, in 2024, our firm was retained by a local business partner in a joint venture investigation. The findings uncovered breaches of the Income Tax Act, the Local Content Act, and the Companies Act, involving over G$100 million in diverted revenue, money laundering, and corporate fraud.
Our investigation revealed that payments from clients in Guyana – including a major state-owned enterprise – had been diverted to foreign accounts, thereby evading local taxation. Evidence of these transactions was presented to the Guyana Revenue Authority and the Local Content Secretariat. The authorities acted promptly, resulting in the seizure of assets and the recovery of unpaid taxes exceeding G$100 million.
That is the level of practical audit work SphereX undertakes – real, evidence-based, and consequential.
Therefore, to dismiss our review as “academic” betrays not our authority, but the author’s unfamiliarity with the breadth of what we do.
SphereX stands firmly by its review. We reaffirm that the NDIA audit is misclassified in methodological terms and falls short of the standards of a true performance audit. Our critique was never an assault on the Auditor General but a call to elevate audit quality and public accountability.

Respectfully,
Joel Bhagwandin