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Information for Reviewers
The current reviewer / team captain packages have been posted on the AICPA website.
If you do not currently have a subscription to the manual, you can order it at cpa2biz.com.
New Process for Submission of Peer Review Documents and Working Papers to the FICPA
As of April 2012, a new process for the submission of peer review documents and working papers is in effect in Florida. This applies to the peer reviews of all Florida-based firms. ShareFile, an internet based extranet program, has been determined to be a more secure method of sending files, including those that are too large to email. All reviewers are encouraged to transmit files electronically, and in doing so should use this new method.
All known FL reviewers were sent an email with a link to their individual FICPA ShareFile reviewer folder (established under each reviewers name), along with a beginning password. The password would be changed by the reviewer at the onset. It is suggested that reviewers bookmark the page in their web browsers in anticipation of continued use and also, there is a desktop setting you can download if you choose under the “My settings” tab. The FICPA ShareFile site is located at: https://ficpa.sharefile.com
Your reviewer folder will be used for you to upload (or submit) to the FICPA the peer review documents for the reviews you perform. You have the ability to create subfolders in your reviewer folder and you should create those subfolders using the name of the firm and the review number (i.e. ABC Company – Review # 123456). Then you may upload review documents to that subfolder. The FICPA will receive an upload notification that you have done such, and similarly, when we download (or receive) the documents, you will then receive a download notification that we have done such. After downloading the documents, we will delete the subfolder for you after several days.
If you have performed a peer review of a FL-based firm, and do not have a reviewer folder, or need assistance please contact Paul Brown at (850) 224-2727, ext. 251. Thank you for your cooperation in this important endeavor.
Peer Review Documentation and Retention Policy
24-1 Question—Paragraph .24 of the standards notes peer review documentation should be prepared in sufficient detail to provide a clear understanding of its purpose, source, and the conclusions reached. How should the peer review be documented to comply with this requirement?
Interpretation—Among other things, peer review documentation includes records of the planning and performance of the work, the procedures performed, and conclusions reached by the peer reviewer. This includes documenting the risk assessment, the understanding of the firm’s system of quality control, and tests of compliance (including checklists for the review of engagements and staff interviews when there are professional staff). The board has authorized the issuance of materials and checklists, including checklists for the review of engagements, to guide team captains, review captains, and other members of the review team in carrying out their responsibilities under these standards.
Ordinarily, materials and checklists developed and issued by the board are to be used by reviewers in carrying out their responsibilities under these standards. Based on its understanding of the reviewed firm’s system of quality control and its assessment of peer review risk, the review team should determine if materials and checklists issued by the board are not sufficiently comprehensive to use on the review. In this event, other materials and checklists may be used; however, they must include the same elements as, and must be more comprehensive than those versions issued by the board. Reviews conducted utilizing alternate materials and checklists will require advance notice to the administering entity and the review must be subject to on-site oversight. The electronic Matter for Further Consideration (MFC) and Disposition of Matter for Further Consideration forms provided by the board must be used for all peer reviews and alternative forms will not be accepted. It is the responsibility of the team captain or review captain to ensure that the materials and checklists used meet these standards. Failure to complete all relevant materials and checklists may create the presumption that the review has not been performed in conformity with these standards, and thus the administering entity should be consulted in advance of use of any equivalents to assist in reaching these conclusions.
25-1 Question—Paragraph .25 of the standards notes that all peer review documentation should not be retained for an extended period of time after the peer review’s completion, with the exception of certain documents that are maintained until the subsequent peer review’s acceptance and completion. What period of time should peer review documentation be retained and what documentation should be maintained until the subsequent peer review’s acceptance and completion?
Interpretation—Peer review documentation prepared during system and engagement reviews, with the exception of those documents described in the following paragraphs, should be retained by the reviewing firm, the administering entity, and the association in an association formed review team (if applicable) until 120 days after the peer review is completed (see Interpretation No. 25-2) or 42 months if firm is unenrolled or does not perform engagements requiring a peer review.
If the administering entity refers the firm to a hearing of the board due to non-cooperation, peer review documentation prepared during system and engagement reviews should be retained by the administering entity until the appeals period has ended. The appeals period ends 30 days from the date that the hearings process is completed (that is, the date of the decision notice letter, upon receipt of a plea of guilty by the firm, or the date of the administering entity’s request to stop the hearings process). Peer review documentation should be retained by the administering entity for an additional 120 days after the end of the appeals period. If the reason the firm is referred for non-cooperation is due to failing to submit documentation or requested revisions to the review team or the administering entity, the reviewing firm and the association in an association formed review team (if applicable) should also adhere to these retention guidelines.
If the firm appeals the hearings decision, the administering entity, reviewing firm (if applicable), and the association in an association formed review team (if applicable) should retain peer review documentation until 120 days after the Joint Trial Board decision.
The reviewing firm and administering entities should retain the following documents until the firm’s subsequent peer review has been completed:
a. Peer review report and the firm’s response, if applicable
If the firm received two consecutive pass with deficiency(ies) or fail peer review reports, the administering entity should retain both the prior and current peer review reports until the subsequent peer review has been completed.
Administering entities may also retain the following administrative materials until the firm’s subsequent peer review has been completed:
a. Engagement letters
The administering entity’s peer review committee or the board may indicate that any or all documentation for specific peer reviews should be retained for a longer period of time than specified in the preceding paragraphs because, for example, the review has been selected for oversight. All peer review documentation is subject to oversight or review by the administering entity, the board, or other bodies the board may designate, including their staff. All peer review documentation prepared by the administering entities is subject to oversight.
If a firm has been enrolled in an institute-approved practice-monitoring program but has not undergone a peer review in the last three years and six months since its last peer review because the firm has not performed engagements and issued reports requiring it to have a peer review, the documents previously noted should still be retained. The administering entity may also choose to retain the administrative documents noted, as applicable. The documents for a firm that has not been enrolled in an Institute-approved practice-monitoring program for the last consecutive three years and six months are not required to be retained.