The selection of the peer reviewer(s) is a critical step in ensuring that a
firm's peer review is efficient, cost-effective, and adds value to the firm's
quality control policies and procedures. Firms that approach this decision with
due care are likely to receive the optimal benefits of the process.
This selection process should begin well in advance of the firm's peer review
due date. Reviews are administered by approved state CPA societies and other
approved entities (both referred to as administering entities) in accordance
with policies and procedures established by the AICPA Peer Review Board. The
administering entities send out requests for scheduling information to firms
approximately six to nine months before the review is due. Firms may want to
begin the reviewer selection process even before the request is received.
Organization of Peer Review Teams
Most peer review "teams" only consist of one reviewer. On
some larger system reviews, a team of more than one person may be involved in
the review. The lead peer reviewer on a system review is called the team captain
and other reviewers are known as team members. The AICPA maintains a database of
individuals interested in serving as reviewers. All reviewers complete a
"resume" containing information that is listed in the database. The information
includes the reviewer's firm, the last peer review training course attended, the
industries in which the individual has expertise and how that expertise was
obtained, and other information. The AICPA Standards for Performing and
Reporting on Peer Reviews
sets the minimum requirements that team captains and
peer reviewers must possess, including experience, continuing professional
education, peer review training, etc. All reviewers are expected to update their
resume every year and the information is available to the administering entities
for assembling committee-appointed review teams (CARTs) and for verifying the
qualifications of firm-on-firm and association reviewers.
The most common way a peer review team is formed is known as a firm-on-firm
review (FOF). The firm to be reviewed directly engages another firm to perform
the review. The fees associated with the actual peer review are negotiated
between the two firms.
Some administering entities offer CARTs. In this second method of organizing
the review team, a firm requests its administering entity to choose the reviewer
from a pool of qualified reviewers. The selection is made based on information
the firm submits about its size, industry specialization, and geographic
restrictions. For example, some firms are unable to locate a peer reviewer in
their area or do not want a review team from their local area. The administering
entity makes its selection based on the firm's requirements, but the firm has
the right to reject the team once it is appointed and ask the administering
entity to select another team. The review team's billing rates are set by the
administering entity. Not all administering entities offer CART reviews.
Another way a review team may be formed is by an association of CPA
firms. If a firm is a member of an association of CPA firms that is
authorized by the AICPA Peer Review Board to organize review teams, it may
request its association to select the review team similar to a CART review.
Whichever method the firm uses to select its review team, the firm must
notify the administering entity of all the peer reviewers and the administering
entity must approve all of them prior to the start of any aspect of the peer
review.
Members of the peer review team must be independent in fact and in appearance
with respect to the firm. If the firm is unsure as to its independence
status with respect to any members of the peer review team, the matter should be
discussed with the administering entity.
Selecting the Right Firm-on-Firm (FOF) Review
Team
Firms engaging their own peer reviewers have greater control over the
process, cost of the review and any value-added benefits it would like to derive
from the review. As a result, most firms favor FOF reviews.
Where possible, a firm should find a reviewer whose practice is similar to
their own in terms of size and industry specialization. In addition, the
reviewer should have significant experience in all of the key areas in which the
firm operates. Requests for proposals and telephone interviews with prospective
reviewers can be a key component to a successful process.
There are several ways to learn about prospective
reviewers. Administering entities and associations of CPA firms often have lists
of firms that perform reviews, some of which are on their web sites. Many
reviewers advertise in CPA periodicals and newsletters. Partnering for CPA
Practice Success, the AICPA Alliance for CPA firms (PCPS) has a Firm-on-Firm
Review Directory
available on
its web site which lists many firms that perform peer reviews and includes
information on firm specialization by industry and size. Firms can also consult
other CPAs with similar practices, in order to find out which reviewers they
might recommend.
Once firms have the names of potential reviewers, they can send out requests
for proposals (RFP) about six to nine months prior to the review taking place.
Firms will then have time to evaluate responses, and call those reviewers they
might consider as potential peer reviewers and pose specific questions to
them.
Requests For Proposal (RFP) and Telephone
Interviews
The RFP should contain information about the firm's accounting (not
bookkeeping) and auditing hours, specialization, personnel, and peer review
history. This document should also address the firm's interest in other possible
practice management/value-added type engagements and any other information the
reviewer should consider in the proposal. Upon receipt of the proposals, firms
can begin to conduct telephone interviews to learn more about each of the
potential reviewers, as this is often the best way to gauge their expertise as
well as their communication skills and general past peer review experiences.
Team captains should be very familiar with and experienced in a firm's most
important areas of specialization. Team captains generally familiar with
standards in certain industries may not have the same depth of expertise as a
practitioner who specializes in these industries. Firms often find their best
peer reviewers are those that are truly peers.
There are several
questions a firm may wish to ask prospective reviewers in determining whether
they are a peer and obtaining an overall level of comfort with the
reviewer. How does the reviewer's firm's size compare in terms of billings
and number of personnel? What size are its clients? Does it specialize in the
same industries and have the same depth of knowledge in those areas? Does it
perform similar kinds of other engagements? The firm may even want to ask the
reviewer for a copy of his or her firm's most recent peer review report, and if
applicable, letter of comment and letter of response. The firm should be certain
that the potential review team has a personal understanding of the firm's unique
practice issues in order to perform the best job possible.
The firm does not always have to select a peer reviewer whose firm is the
same size. Firms that are exactly the same size sometimes struggle with
similar issues as the firm under review. Slightly larger firms may have a
different insight and solutions to offer regarding practice problems, since they
may have already solved these issues within their own firm. In addition, firms
that are seeking to expand can learn from a reviewer whose firm has already
experienced growth.
As part of the selection process, firms may want to ask potential reviewers
what value-added insights it could offer as an extension of the peer review.
Firms may want to take advantage of the peer review process by hiring a reviewer
who can compliment traditional peer review with value-added services. Firms hire
outside consultants to analyze partner compensation, hiring practices, human
resource matters, billing, collection, technology issues and other important
practice management matters. Many firms that take greater care in the selection
of their peer review team are also able to contract with them to perform some of
these value-added services. These types of value-added services are planned and
billed separately from the peer review. An experienced review team does offer
valuable advice as part of the traditional peer review and can make observations
about efficiencies and best practices observed at other firms it has
reviewed.
Cost is obviously a consideration in selecting a peer reviewer. The average
direct expense of a system review is between $2,000 and $4,000 depending on the
size, nature and complexity of the firm's accounting and auditing practice. The
average direct expense of an engagement or report review is between $400
and $900. On a FOF review these expenses are negotiable between the
reviewing and reviewed firms. Administering entities also charge an
"administrative" fee, which is structured somewhat differently at each entity,
with an average of approximately $300 over each three-year peer review cycle.
Although it is often important to minimize costs, firms should not use price
as the only criteria when selecting a review team. Review teams that cost a
little more may be able to help firms by not only performing the peer review,
but offer suggestions that may lower the firm's expenses or increase
productivity. In addition, review teams that promise to complete the engagement
quickly may be performing the absolute minimum or cutting corners that could
reduce the value of the process. This is why it is very important for the firm
to take great care in questioning the potential reviewers.
Therefore, the selection of the peer review team should not be taken lightly.
There are many matters to be considered when selecting the review team and a
firm that takes the time and special care during this process is more likely to
get the most out of its peer review.
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