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Peer Review Extensions and Change in Year-end

by AICPA | Jul 16, 2019
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A firm may request an extension of time to complete its peer review under certain circumstances. This is a reminder of the procedures in place to make those requests.

Extensions

If a firm realizes that it will be unable to complete its peer review by the due date assigned, it must first contact the Peer Review Administrator, Julie Phipps, at 425.586.1132. Including a valid reason, the request must be made in PRIMA.

Extensions are considered on a case-by-case basis. To request an extension, access PRIMA and click on "For Firms" located on the top-right of the screen, then click on the orange button labeled "Request Extension/PR Year End Change.

Acceptable reasons for requesting an extension:

  1. A merger or dissolution is involved.
  2. Time is needed to complete a major engagement.
  3. The timing of the review or corrective action conflicts with the firm’s busy season.
  4. Absence or loss of key individuals significant to the conduct of the review or corrective action.
  5. Firm’s records or offices have been severely damaged or destroyed because of a natural catastrophe.
  6. Firm needs more time because it has selected a reviewer that has a scheduling conflict and is unavailable to perform the review by the firm’s due date but is available to perform the review within one or two months.
  7. One of the firm’s partners has a family or medical emergency (applicable only to smaller firms).
  8. Other extraordinary circumstance that, in the Peer Review Committee’s judgment, warrant an extension.

Unacceptable reasons for requesting an extension:

  1. Vacation schedules of either the individual(s) conducting the review or the firm’s key individuals significant to the conduct of the review or corrective action(s).
  2. Firm’s needs more time to prepare for the review or to implement new quality control policies and procedures.
  3. Firm is developing a quality control document.
  4. Firm is relocating or renovating its offices.
  5. Nature of the firm’s accounting and auditing practice changes (for example, a firm with an audit practice when it enrolled was assigned a due date and later gave up its audit practice, and the firm has not performed an audit for at least a year).

Please Note: If your firm performs engagements under Government Auditing Standards, extensions of due dates beyond three months for peer review of firms performing Yellow Book audits can only be granted by the GAO and should only be requested for extraordinary circumstances. To request an extension, please contact:

Government Auditing Standards
U.S. General Accounting Office
202.512.9535

If a firm is unable to complete its peer review by the assigned due date and has not been granted an extension, any Yellow Book audit engagements completed or issued during the period between a firm’s peer review due date and the date the peer review is completed (the date of the report) will be automatically considered to be substandard.

If an extension is approved by the GAO, the firm should notify the Peer Review Administrator in writing at peerreview@wscpa.org.

Change in Year-End

Firms may find that a major engagement routinely is not completed, or its review is due during its busy season, which causes the firm to request an extension. The firm should consider requesting a change in year-end. Please keep in mind a firm’s next peer review cannot cover a 12-month period that extends beyond three years from the last peer review.

For example: Firm ABC has an annual engagement for Firm XYZ for a December 31 year-end, which is also the last month in the peer review year. The firm’s peer review is due June 30 the following year. Firm XYZ routinely delays the start of the engagement until June or July, thus causing a delay in Firm ABC completing its review by the due date. Changing to a peer review year-end of September would shorten the period between peer reviews by three months. With a September 30 peer review year-end, Firm ABC’s review would be due March of the following year and for subsequent peer reviews.

Firms are encouraged to discuss a possible change in year-end with the peer reviewer and/or WSCPA Peer Review Administrator.

Requesting a change in year-end will be available in PRIMA. Please contact WSCPA Peer Review Administrator for guidance at peerreview@wscpa.org or 425.586.1132.

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