An optional delay in peer review is one of the many events that have occurred because of the COVID-19 pandemic. In June, the AICPA Peer Review Board gave CPA firms whose peer reviews were due between Jan. 1 and Sept. 30 the option of taking a six-month peer review deadline delay. If you’re not sure whether the extension is right for your firm, here are some questions to consider.
Would it be a relief to stick with what you have? One of the first questions firms should ask is whether the delay is worth taking. This has been a year of disruption, with the postponement of the tax season deadline knocking many firms’ normal timelines and procedures off course. Add to that the tremendous demand for CPA expertise in navigating the evolving rules for Paycheck Protection Program loans, as well as other client needs during an uncertain economy and a public health crisis. Just when practitioners have a chance to take a breath, they also need to prepare for the October 15 due date, the employee benefit plan audits due in October and the 2021 filing season. If you already have a peer review preparation schedule in place with your original deadline, it might be easier to stick to it rather than create a new plan.
What steps are necessary if you take the extension? First, be sure that you and your firm members set aside time to create a new schedule and preparation steps that fit realistically into your current workload. Those who take an extension must also still submit the required information to schedule their review by completing the firm’s Peer Review Information (PRI) form. You can find it in PRIMA’s “Action Items” section, and I recommend doing this as soon as possible. It’s also important to think about your required monitoring, which you may have to shift.
Before each peer review year ended, my former six-person firm took the AICPA course, “Are you ready for your peer review?” It covers the steps in the peer review process, best ways to prepare, how to get the most value from your peer review and common areas where firms fail to comply with professional standards. This year especially, it’s a good refresher to help you be mentally ready for your review. Even if this is not your first review, it’s a good update that can help you avoid any unwanted surprises.
Have assurance engagements been delayed? In a normal year, firms would have been able to pull many assurance engagements that were completed in the winter or spring, but some of these may not yet be completed because of the delays associated with the pandemic. If that’s your situation, an extension may be best. Firms may also want to consider extensions if the pandemic and remote auditing or other issues have created documentation or internal control challenges that have yet to be addressed. For more information on related issues, turn to Audit Matters and Auditor Reporting Issues Related to COVID‐19 or visit the AICPA COVID-19 Audit and Assurance site.
Can the firm maintain efficiency in an off-site review? As this Journal of Accountancy article notes, there are a number of steps that firms can take to hold down costs and retain efficiency in an off-site review:
- Make sure the information in PRIMA about engagements that fall during the peer review period is accurate and up to date.
- Check that the appropriate staff are available during the review.
- Find out what kinds of technologies—portals, teleconferencing and collaboration software—the reviewer will use.
- Review the adequacy of file security.
During the review, I recommend that instead of waiting until the end of the process, you schedule a check-in with your peer reviewer at the end of each day. Find out if they need any help or information from your team, want any engagements pulled or have identified any issues you can address. Knowing what they need each day will keep things moving more efficiently than if you wait until the end of the process.
Does the firm have other deadlines to submit peer review results? The Government Accountability Office has indicated that it will not require concurring approval for any COVID-19-related peer review extensions, but if your work involves other regulators, find out their requirements. If your firm does Yellow Book audits, your clients may require a copy of your most recent peer review before they engage you for the 2020 year end. These clients may require documentation of the extension, so confirm with them that your proof of extension is sufficient. Check in, too, with your state board of accountancy to see if they require notice of any extension you receive.
After a demanding few months, it’s a relief for many firms to know they have options when it comes to scheduling peer review. Choosing a timeframe that works for your firm and your peer reviewer can allow for a smoother process for everyone.
For more information, see “Top strategy for a delayed peer review? Plan it now.” In addition, the AICPA peer review program site includes information for reviewers and firms, including details on the delay.
Carl Peterson, CPA, CGMA is the Association’s Vice President of Small Firm Interests. Have questions for Carl? Contact him directly at email@example.com or 651-252-4618. And be sure to sign up for Carl’s Small Firm Update webcasts. The next one will take place on December 3 at 2:00 to 3:00 PM ET.