Does my firm have to enroll in a peer review program if it does not have an accounting and auditing practice?

If a firm does not perform services that include issuing reports purporting to be in accordance with AICPA professional standards it is not required to enroll in a practice-monitoring program. Firms should consult with their State Board of Accountancy (SBOA) to determine if the SBOA rules require enrollment in a practice monitoring program even if your firm does not perform services that include issuing reports.

For purposes of the AICPA Standards for Performing and Reporting on Peer Reviews (Standards), an accounting and auditing practice is defined as all of a CPA firm’s engagements performed under the Statements on Auditing Standards (SASs), Statements on Standards for Accounting and Review Services (SSARS)*, Statements on Standards for Attestation Engagements (SSAEs), Government Auditing Standards (the Yellow Book) issued by the U.S. Government Accountability Office (GAO) and engagements under PCAOB standards. Engagements covered in the scope of the Program are those included in the firm’s auditing and accounting practice that are not subject to PCAOB permanent inspection.

* SSARS that provide an exemption from those standards in certain situations are excluded from the definition of an accounting and auditing practice for peer review purposes.

Does my firm have to enroll in a peer review program if the only engagements it performs are engagements to prepare financial statements under AR-C section 70?

For purposes of complying with AICPA membership requirements, a firm that only performs engagements to prepare financial statements under AR-C section 70 is not required to enroll in a peer review program. For firms already enrolled in the Program, engagements to prepare financial statements would fall within the scope of peer review. Independent of AICPA requirements, please note that some SBOAs require firms that only perform these engagements to enroll in peer review as a licensing requirement. You should check with the SBOA(s) where you perform such engagements to determine whether you need to enroll in peer review.

When should my firm enroll in the AICPA Peer Review Program?

When an individual becomes an AICPA member, and the services provided by his or her firm (or individual) fall within the scope of the AICPA’s practice-monitoring standards, and the firm (or individual) issues reports purporting to be in accordance with AICPA Professional Standards, the firm should enroll in the Program by the report date of the initial engagement.

How can my firm enroll in the AICPA Peer Review Program?

A firm should log in to PRIMA and submit its enrollment information. For information on how to log into PRIMA, see Getting Started in PRIMA on AICPA.org. By enrolling, a firm agrees to have a peer review of its accounting and auditing practice once every three years subsequent to its initial peer review. A firm’s initial review is ordinarily due 18 months from the date it enrolled (or should have enrolled) in the Program. A firm seeking to enroll in the Program should be in compliance with the Council resolution concerning form of organization (see AICPA, Professional Standards, ET Appendix B).

Once enrolled, when should my firm expect to have its first peer review?

A firm's due date for its initial peer review is ordinarily eighteen months from the date it enrolled in the Program, or should have enrolled, whichever date is earlier. A firm's subsequent peer review ordinarily has a due date of three years and six months from the year-end of the previous review. Firms should also check with their state board of accountancy for any peer review requirements. In determining the appropriate due date, the firm’s AE will consider the firm’s (or individual’s) practice, the year-ends of their engagements, when the engagements were performed and the number and type of engagements to be encompassed in the review. If a firm resigns from the Program and subsequently performs an engagement that requires a peer review within three years and six months of its prior peer review year-end, the firm should re-enroll in the program. The due date for the firm’s current review is the later of the due date originally assigned or 90 days after re-enrolling.

If a firm resigns from the Program and subsequently performs an engagement that requires peer review after its next due date has passed, the firm’s current peer review is due 18 months from the year-end of the engagement (for financial forecasts, projections, and agreed upon procedures 18 months from the date of report).

Can my firm change its peer review year-end?

A firm is expected to maintain the same year-end on subsequent peer reviews. Circumstances may arise that may cause a firm to want to change its year-end. For instance, the nature of the firm’s practice may change, or the firm may reevaluate their current year-end and determine that a different year-end is more practical. In such situations, a firm may change its year-end only with prior, written approval of the AE.

Find more answers to your questions about the AICPA Peer Review Program in the full Frequently Asked Questions (FAQs) document, here.

If you have additional questions, contact Julie Phipps, WSCPA Manager of Practice Quality, at jphipps@wscpa.org.