1. What is Facilitated State Board Access?
It is a process that the American Institute of CPAs (AICPA) created to help address the evolving changes in the business and regulatory environments and to address the demand for greater peer review transparency.
2. How does my firm benefit from this new Facilitated State Board Access process?
This new process is intended to create a nationally uniform system through which CPA firms can satisfy state board or licensing body peer review information submission requirements, increase transparency, and retain control over their peer review results. The AICPA and CPA state societies are working together to allow this process to become the primary means by which all State Boards of Accountancy (BOAs) obtain peer review results. This new process will help to make submission of your firm’s peer review information easier. It will be important that you are familiar with the SBOA peer review rules of the states in which you are licensed to understand the impact of this process on your firm. Please visit http://www.aicpa.org/yellow/ypsboa.htm for links to each state board of accountancy’s web site.
3. Will a firm’s peer review information be made public as a result of this new process?
No, a firm’s peer review information will not be made available to the public as a result of this process. A firm’s peer review results will be posted to a secure BOA access-only web site that will only be available to authorized state board representatives. However, many firms already make their peer review results available as part of their AICPA membership or a Government Accountability Office (GAO) or BOA requirement. In addition, many firms make their peer review results available upon client request as it demonstrates a firm’s commitment to quality.
4. Will my firm’s peer review information that is posted to the secure BOA website be shared with others?
That is not the intention of this process; however, each BOA’s laws and regulations govern this matter. In addition, due to the Freedom of Information Act (FOIA) legislation that applies in some instances, BOAs may share information with others once they have obtained it.
5. How does this affect my firm’s peer review information submission requirements?
Until further notification, this new process WILL NOT replace the current peer review information submission requirements of the State Board of Accountancy in the state where your home office is located. Therefore, firms will need to follow the State Board of Accountancy requirements of the state in which its home office is located, and other states it is licensed with, until notified differently.
6. What states are participating in the Facilitated State Board Access program as of early 2009?
- Alabama
- Arkansas
- Colorado
- Connecticut
- Delaware
- The District of Columbia
- Florida
- Georgia
- Guam
- Hawaii
- Idaho
- Iowa
- Kansas
- Kentucky
- Louisiana
- Maryland
- Massachusetts
- Michigan
- Minnesota
- Mississippi
- Missouri
- Montana
- Commonwealth of Northern Mariana Islands
- New Jersey
- New Mexico
- New York
- North Carolina
- North Dakota
- Ohio
- Oklahoma
- Oregon
- Pennsylvania
- South Carolina
- South Dakota
- Tennessee
- Texas
- Virginia
- Virgin Islands
- Washington
- West Virginia
- Wisconsin.
As of the last quarter 2010, all states participate in FSBA.
7. How does this process work?
As outlined below, the process is tailored differently for states that
- require peer review for licensure and the BOA is not prohibited from access to peer review information, and
- require peer review for licensure but have prohibitions on accessing results or do not require peer review for licensure. FSBA entails an opt out process that allows firms to choose whether or not to provide access to their peer review results to select BOAs, using a secure web site that is available only to authorized state board representatives.
8. What peer review information will be posted by the NPRC to the secure BOA website for firms that do not opt out?
The following documents will be posted, as applicable, to the secure BOA web site. The number of documents posted for each firm can vary based upon the results of the peer review. It is important to note that unless a firm opts out, all applicable documents will be posted even if it is not a state requirement. A firm that does not opt out will not choose which documents to post as each of those applicable (based on the results of its peer review) will be posted.
- Peer review report
- Letter of comments
- Letter of response
- Acceptance letter
- Letter(s) signed by the reviewed firm indicating that the peer review documents have been accepted with the understanding that the reviewed firm agrees to take certain actions
- Letter notifying the reviewed firm or individual that certain required actions have been completed
9) What if the firm changes its mind and wants to opt out after the information has been posted?
A firm that is not a member of the AICPA EPBAQC, GAQC or PCPS may opt out at any time by notifying the NPRC in writing. Once the NPRC has been notified, the information will be removed from the web site, however, certain information (which is currently publicly available) will remain posted to the secure BOA web site. Please refer to question #14 for more information.
10. What happens if the firm decides to opt out?
If a firm chooses to opt out, it is important to note that certain information (which is currently publicly available) will be posted to the secure BOA web site. This information will help us to maintain a complete database of all firms in the peer review program. This includes:
- The firm’s name and address
- The firm’s enrollment in the Peer Review Program
- The date of acceptance and the period covered by the firm’s most recently accepted peer review
- Whether the firm’s enrollment in the program was terminated. Beginning January 1, 2009, effective with the revised Standards, this also includes firms that have been dropped.
11. Who may I contact if I have questions?
You may email nprc@aicpa.org. In addition, you may contact the Peer Review Hotline at 919-402- 4502.