Your peer review has been extended — now what?

The AICPA Peer Review Board (PRB) has granted CPA firms with original due dates between Jan. 1 and Sept. 30 a six-month peer review deadline delay option to provide them with relief during the coronavirus pandemic. If your firm was the beneficiary of this extension, you should have received an email from the peer review program. Be aware, though, that the delay is not a license to ignore peer review responsibilities.

Although the AICPA is encouraging firms to take advantage of the extra time if they need it, firms that don’t need it may be better off staying on schedule. That is exactly what Atkinson & Co. Ltd. in Albuquerque, N.M., plans to do, according to Barbara Lewis, CPA, CGMA, a partner in the firm of about 50 employees. Though the firm’s original peer review due date was Sept. 30, Lewis said it was more practical not to delay. The firm is planning to go ahead with the review being conducted in July.

Spring always is a busy time for the firm, and fall usually is jam-packed with wrapping up employee benefit plan audits and June 30 year-end not-for-profit and governmental engagements. So July remains the best time for her firm’s review.

“It’s a timing issue for us as well as just wanting to make sure that if there is anything in our practice that needs to be addressed, we’re able to do it as quickly as possible,” Lewis said.

The PRB and the AICPA Peer Review Program staff will continue monitoring the pandemic throughout the summer and will evaluate whether additional automatic extensions are appropriate for firms with due dates after Sept. 30.

Even firms that do plan to take advantage of the delay are being encouraged by the AICPA to contact their peer reviewers as soon as possible to schedule a mutually convenient time for their reviews. Liz Gantnier, CPA, a partner with DHG in Charlotte, N.C., and a member of the PRB, said some firms will need to take advantage of the delay because they have been working nonstop to help clients with Paycheck Protection Program applications and forgiveness issues while shifting to handle their normal duties in work-from-home mode.

“The message is, should you need it, the extension is there for you,” Gantnier said. “But take it only if you need it, and only take the time you do need. If you do that, you’ll get done on time.”

The AICPA Peer Review program staff recommends that if your firm’s review was extended and your peer reviewer hasn’t already reached out, you should contact your peer reviewer as soon as possible.

Reviewers’ firms also will be affected by the pandemic, so it’s important to get on their schedule in a timely fashion. Mike Manspeaker, CPA, CGMA, a peer reviewer as well as an audit and assurance services engagement partner for SEK in Hagerstown, Md., said he is hoping the firms he reviews will stick to their regular time frames.

His firm is trying to stay ahead of schedule on all its work out of concern that a second wave of the pandemic later this year could cause more disruption.

“We’ve kind of fallen into a schedule,” Manspeaker said. “And I know that my peer reviews complement the rest of my practice. If either part of that gets out of balance, we’re not going to stay current.”

Firms that have received an extension still need to submit information required to schedule their review. This is done by completing the firm’s Peer Review Information (PRI) form, which can be accessed in PRIMA’s “Action Items” section. Firms are encouraged to do this as soon as possible.

Firms that received an extension or outstanding remedial actions from their most recent peer review are strongly encouraged to complete them as soon as possible as well.

Regulatory implications

Firms that receive extensions are advised to check with their state board of accountancy (board) because some boards require notice of the extensions granted by the PRB and some require firms to obtain board concurrence.

If a board requires a copy of the extension letter, the firm can opt into Facilitated State Board Access (FSBA) in PRIMA and opt in to share additional peer review information either during or after completing their PRI form.

The board will immediately have access to the extension letter, so there will be no need for the firm to email or mail a copy. Be aware, though, that some boards do not have access to FSBA or otherwise require firms to send copies of their extension letters directly. Again, the AICPA Peer Review program staff recommends that you check with your board.

Gantnier, a former chair of the Maryland Board of Public Accountancy, warned that firms that make use of the delay need to make sure they don’t miss the extended deadline.

“As a former state board chair, telling me that you had an extra six months and you couldn’t get it done during the extra six months is likely going to not be perceived well,” Gantnier said.

Firms that perform audits under governmental auditing standards (Yellow Book) will not need to take any further action with the U.S. Government Accountability Office (GAO). The GAO indicated earlier this year that it will provide automatic concurrence for any AICPA extensions, granted in 2020 because of the pandemic, extending beyond 90 days from the firm’s due date.

Preparing for reviews

Peer review’s importance in the firm’s overall processes was an important factor in Regier Carr & Monroe LLP CPAs’ decision to stay on schedule with its peer review.

The firm, which has offices in Arizona, Kansas, and Oklahoma, incorporates its peer review into monitoring procedures in the year of the peer review. A delay in its peer review would put other processes off schedule with respect to monitoring the firm’s compliance with its quality control system.

“Anything that we can do to keep it moving along and hopefully flatten out that workload, we’re going to try to do,” said Bert Denny, CPA, the firm’s director of accounting and auditing and director of quality control.

Because of the pandemic, all or part of the reviews are likely to be held off-site this year. Although reviewers are not required to get prior approval from their peer review administering entity, they will need to determine whether they can effectively perform a firm’s review off-site.

An off-site review needs to be as effective as an on-site review, but it may not be as efficient, potentially leading to a higher cost. Firms can take the following actions to improve efficiency and hold down costs:

• Confirm that their peer review information in PRIMA accurately represents all engagements within the scope of their peer review that were performed during the peer review year.
• Block out time to ensure availability of pertinent staff during the review. In essence, pretend the peer reviewer is on-site conducting the review.
• Gain understanding of the technologies their peer reviewer will use, including portals to transmit files; teleconferencing platforms, such as Zoom; and collaboration software such as Microsoft Teams.
• Consider file security.

Although Lewis, who also is a member of the PRB and an active peer reviewer, has been encouraging the firms that she reviews to push ahead with their peer reviews, some of them have declined. She understands why they are not able to make the same decision that her firm did. She reviews a lot of smaller firms that don’t have a true separation between their accounting and auditing practices and their tax practices.

She said leaders of some of those firms are trying to manage both service lines, including the July 15 extended tax deadline, and are trying to help clients take advantage of the appropriate government resources during the pandemic. They are grateful for the delay.

“It just depends on the situation, and I’ve seen a mixed bag,” Lewis said. “I’m trying to encourage people to move forward and stick with their plan. But if they have to take advantage of the six-month extension, that’s totally, totally understandable.”

Questions about peer review can be emailed to prsupport@aicpa.org.

— Ken Tysiac (Kenneth.Tysiac@aicpa-cima.com) is the JofA’s editorial director.