March 2018 Peer Review Update

Follow up on paragraph 146-3 of the AICPA Standards for Performing and Reporting on Peer Reviews

You may recall from February’s State Regulatory Update that the AICPA recently shared a Q&A with executive directors that details the additional information peer review administering entities (AEs) can provide to state boards with written authorization from the firm. Here are some additional questions we’ve received:

Q. Will the AICPA continue to perform and report on the biennial AE Oversight visits?

A. Yes, the visits will continue as will posting of the reports and letters of observation to the website. Although the OTF and Peer Review Board (PRB) have not yet addressed specifics, we anticipate some form of reporting on benchmark compliance will be included in the reports. Beginning in 2019, the annual oversight report will likely report on benchmarks on a national level.

For AEs in which a board has an active Peer Review Oversight Committee (PROC), the PROC will have complete access to benchmark reporting throughout the year and can inform the affected state board(s) about the AEs’ compliance.

Q. What if a board changed its rules and regulations to require all firms to provide complete access to their peer review information from the AE?

While theoretically a board could do so, it would be an inefficient way to increase transparency. Rather, we suggest continuing with the current process which entails a firm emailing the AE (or sending letter via US post), requesting the AE provide the board with an item of specific, objective and determinable information. We believe this process will continue to meet the boards’ needs and cause minimal resource stress on both boards and AEs.

For more information on paragraph 146-3 or a copy of the Q&A, email

Using Facilitated State Board Access (FSBA)

Available in PRIMA, the new system that administering entities, peer reviewers and firms are now using for peer review, the AICPA created the secure FSBA web site to facilitate your licensees’ compliance with peer review document submission licensing requirements. Available only to board-authorized personnel or PROC members, this site was designed to enable boards to:

  • Access the peer review documents of any firm, located or practicing in your state, that has allowed its AE to post its accepted peer review documents in this searchable file
  • View publicly available information regarding your licensees’ that have opted out or firms in other states whose board is not permitted access to peer review documents

To view instructions on how to navigate FSBA (including how to run reports) log in to PRIMA and in the Instructions navigation on the right side of your screen, click on “Instructions for Board of Accountancy." After clicking on this link, you will find Knowledge Base articles such as FSBA Search and FSBA Reports that further specify (with the help of screenshots) how to use FSBA.