Peer Review & Quality Control Document Guidance 

The AICPA Peer Review Program is dedicated to enhancing the quality of accounting, auditing and attestation services. The Program is a systemic evaluation whose value in serving the public interest and firms lies in its educational and remedial nature. The Program will review a selection of engagements completed by firms, however, it is not intended to assure that firms will perform all engagements, in all industries, in accordance with professional standards. Findings and deficiencies noted in peer reviews sometimes result in implementation plans and/or corrective actions; however, these are not intended to be punitive measures. All involved stakeholders should fully understand, accept, engage, and promote the Peer Review Program and its value.

Stay ahead of the curve in your firm’s peer review process.  The AICPA provides a list of common trouble spots you can review to help your firm avoid roadblocks on its path to quality.

Additionally, as part of the AICPA's Enhancing Audit Quality Initiative, we've identified new industries, industries with rising risks, audit areas of increased risk or areas that have increased inspection matters. Review the emerging industries and risk areas to ensure your firm is looking ahead.

Your firm might also want to consider performing peer reviews. Explore the benefits of providing this valuable service through this AICPA Insights blog and video featuring Michael Brand, CPA.

Peer Review Process and Requirements for PCPS Member Firms:

Since PCPS and its member firms strive for commitment to quality, a membership requirement of PCPS member firms is that they must:

  1. Be enrolled in an approved AICPA practice monitoring program. 
  2. Have their peer reviews performed under the AICPA Standards for Performing and Reporting on Peer Reviews. 
  3. Upon request, provide PCPS their peer review results which are posted to the AICPA Peer Review Public File and include the firm's most recent peer review report, letter of response (if applicable) and acceptance letter,

Peer review results are uploaded (and are automatically available in the Public File) by the entity administering the firm’s peer review within 30 days of the acceptance of that review.

Note 1: Not all AICPA member firms peer review results are posted to the AICPA Peer Review Public File. Posting is only required for member firms of certain sections within the AICPA (e.g., PCPS, EBPAQC and GAQC).

Note 2: If your firm does not have an accounting and auditing practice and therefore does not perform services that include issuing reports purporting to be in accordance with AICPA professional standards, this requirement does not apply to your firm.

Find out more about the AICPA Peer Review Program and how to become a peer reviewer.

 Determine your peer review requirements with the Peer Review Decision Tree

Firms that are active in the practice of public accounting fall under this peer review requirement as follows (source: AICPA Standards for Performing and Reporting on Peer Reviews):

 Type and Requirements Description Get Started! 
System Review - Firms that perform engagements under the SASs (i.e. audits), Government Auditing Standards, examinations of prospective financial statements under the SSAEs, examinations of a service organization’s controls likely to be relevant to user entities’ internal control over financial reporting under the SSAEs, or audits of non-SEC issuers performed pursuant to the standards of the PCAOB including audits of carrying broker-dealers, have peer reviews called System Reviews. 
  • A System Review includes determining whether the firm’s system of quality control for its accounting and auditing practice is designed and complied with to provide the firm with reasonable assurance of performing and reporting in conformity with applicable professional standards, including SQCS No. 8, in all material respects. 
  • The majority of the procedures in a System Review should be performed at the reviewed firm’s office. 
Engagement Review - Firms that only perform services under SSARS (i.e. reviews and/or compilations) or services under the SSAEs not included in System Reviews have peer reviews called Engagement Reviews. These firms are responsible to develop a quality control system, however, this is not subjected to peer review in an Engagement Review.
  • The objective of an Engagement Review is to evaluate whether engagements submitted for review are performed and reported on in conformity with applicable professional standards in all material respects. 
  • An Engagement Review consists of reading the financial statements and other information submitted by the reviewed firm and the accountant’s report thereon, together with certain background information and representations and, the applicable documentation required by professional standards. 
  • Engagement Reviews are normally performed at a location other than the reviewed firm’s office. 

Firms that are enrolled in an AICPA approved practice-monitoring program are obligated to adhere to quality control standards established by the AICPA.

Quality Control Standards and Quality Control Document Guidance: 

Statement on Quality Control Standards (SQCS) No. 8, A Firm's System of Quality Control (Redrafted) (AICPA, Professional Standards, vol. 2, QC sec. 10), requires every CPA firm, regardless of its size, to have a system of quality control for its accounting and auditing practice. To better understand and apply Statements on Quality Control Standard (SQCS) No. 8, refer to the AICPA Audit and Accounting Practice Aid Establishing and Maintaining a System of Quality Control for a CPA Firm’s Accounting and Auditing Practice. SQCS No. 8 is included as appendix A of this Practice Aid. 

Quality Control Document Steps  Resource
Questionnaire Approach

The peer review questionnaire (next column) that a firm may fill out (in lieu of or in addition to providing the firm’s own quality control document) guides a small firm through the necessary questions in developing its system of quality control in accordance with SQCS No. 8. Through December 31, 2016, the completed document can then serve as the firm’s documentation as required by the standard (note that it must be in place at the beginning of the period). Effective January 1, 2017, firms will no longer be permitted to use the questionnaire. Additional resources will be made available to assist firms with developing quality control systems.

Practice Manual Approach  Suggested Steps in Updating your Quality Control Document (Practice Manual Approach)


© 2017 Association of International Certified Professional Accountants. All rights reserved.