
On March 15, 2018, the NYSSCPA will hand off its peer review administration responsibilities to the Pennsylvania Institute of CPAs (PICPA). As of that date, the PICPA will become the administering entity (AE) for New York state CPA firms that are required to undergo peer review, meaning all firms that perform attest services, as well as firms that include members of the American Institute of CPAs (AICPA) and perform work for which that organization requires peer review.
“The administration of the PRP [Peer Review Program] requires a significant investment of Society resources, particularly going forward to meet the requirements of the new AICPA administrative proposals,” wrote NYSSCPA Executive Director and CEO Joanne S. Barry and Brenda K. Santoro, chair of the Society’s Peer Review Committee, in a Sept. 25 letter to firms and peer reviewers.
Instead of expending resources on an administrative function that could be absorbed by another state society executing the same program, they added, eliminating the peer review program will allow the NYSSCPA to play a stronger advocacy role for those firms required to undergo peer review by increasing education and peer review resources to firms.
The Society’s decision was the result of a two-year process of analysis and discussion undertaken by its Board of Directors, Executive Committee and staff about the demands of the administration process.
What that means for New York CPA firms and reviewers is that there will ultimately be more resources available for the administration of the AICPA’s PRP, as the PICPA will have the benefit of its own resources and those of the NYSSCPA’s Peer Review Committee, which will continue its work after the transition. Members of the NYSSCPA’s Peer Review Committee will work with the PICPA Peer Review Committee and participate on that committee’s Report Acceptance Bodies (RAB).
The AICPA set forth its administrative proposals in a publication titled “Proposed Evolution of Peer Review Administration,” released in January 2017. In it, the AICPA lays out benchmarks that AEs must meet, many of them new and formidable. Complying with these new benchmarks would have meant ramping up the NYSSCPA’s Peer Review administrative function through additional staff and other investments. It might also have required the NYSSCPA to absorb another AE in order to amass additional resources.
Complying with the new AICPA benchmarks would have significantly raised the costs to the Society of administering peer review. Further, the NYSSCPA’s peer review function has its own budget and is required to break even. Because the pool of New York firms needing peer review has been shrinking, if the Society continued to serve as an AE, that would have meant that fewer firms would have had to bear the burden of the rising cost of the annual administrative fee.
As stated in the Sept. 25 letter, the NYSSCPA selected the PICPA as the new AE based on “a number of factors, including the comparability of the size of the firms they administer to New York firms and that they have dedicated, experienced full-time staff who can offer the kind of assistance to New York firms that you have come to expect.”
The NYSSCPA chose March 15 as the date of transition because it tends to be a slower time for peer reviews, when the inventory of reviews is lower, which will allow the transition to be as smooth as possible.
At whatever stage of peer review that firms and reviewers are in on March 15—from notification that a peer review is due through filling out the information form, selecting a reviewer, selecting a date, the peer review itself, the AE’s technical review, and the ultimate decision by the RABs—the PICPA will begin to take over all responsibilities of the AE from the NYSSCPA.
At least a dozen members of the NYSSCPA’s Peer Review Committee have already committed to participating in the PICPA Peer Review Committee’s RABs. In fact, the PICPA will be holding some RAB meetings in locations in New York state. A blended complement of NYSSCPA and PICPA Peer Review Committee members will conduct the RAB process.
Among the benefits of the new arrangement is that an out-of-state AE can provide New York firms with a broader perspective. In addition, the presence of Pennsylvania CPAs on the RABs can mitigate concerns about reviews being looked at by local competitors.
There will be a few exceptions to the transition set to take place on March 15. The NYSSCPA will retain a degree of responsibility for a very small number of peer reviews that are undergoing appeals.
Firms or reviewers with questions about the transition process can contact the NYSSCPA peer review team at peerreview@nysscpa.org or 212-719-8300, or they can contact Allison M. Henry, vice president—professional and technical standards at the PICPA, at ahenry@picpa.org or 215-972-6187.