Peer Review Guide

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Peer Review Guide > Standards for Performing and Reporting on Peer Reviews > History

History of
Standards for Performing and Reporting on Peer Reviews

The Standards for Performing and Reporting on Peer Reviews are established by the AICPA Peer Review Board (the Board). These standards apply to all peer review performed under the AICPA Peer Review program (AICPA PRP).


1999 Revisions to the Standards
     System review
     Engagement review
     Report review

2004 Revisions to the Standards

1999 Revisions to the Standards

In October 1999, the American Institute of Certified Public Accountants (AICPA) Peer Review Board adopted revisions to the AICPA Standards for Performing and Reporting on Peer Reviews. The revised standards that became effective January 1, 2001. Early implementation was not permitted. In summary, the revised standards created the following three levels of peer reviews:

System Review

This became the name of the existing on-site peer review and applied to firms that performed engagements under: :

  • Statements on Auditing Standards (SASs)
  • Government Auditing Standards (the yellow book), issued by the U.S. General Accounting Office, or
  • Examinations of prospective financial information under the Statements on Standards for Attestation Engagements (SSAEs)

Firms eligible for engagement review or a report review could elect to have a system review. In considering the change in name from an on-site peer review to a system review, the AICPA Peer Review Board considered the comments received during the exposure draft’s comment period and concluded that the new terminology more accurately described the type of peer review since the reviewer expresses an opinion on the firm’s system of quality control.

Like the previous on-site review, a system review includes a separate report, letter of comments (if applicable), letter of response, technical review, committee acceptance, and monitoring actions (if considered appropriate.) A system review is intended to provide the reviewer with a reasonable basis for expressing an opinion whether—for the year under review—the reviewed firm:

  • Has designed its system of quality control for its accounting and auditing practice in accordance with AICPA quality control standards.

Engagement Review

This level of peer review replaced the existing off-site review with two basic exceptions: :

  • Firms that performed only compilation engagements that omit substantially all disclosures are subject only to a report review, which is described below. (Although inclusion of selected disclosures for financial statements that otherwise omit substantially all disclosures are still subject to an engagement review.)
  • Second, an engagement review carry an additional objective to assess whether working paper documentation conformed with the requirements of SSARS and SSAEs, as applicable to those engagements. An engagement review provides no opinion on the reviewed firm’s system of quality control and therefore the reviewer is not opining on the firm’s compliance with its own quality control policies and procedures or with AICPA quality control standards, just conformity with SSARS and the SSAEs.

Since an engagement review does not require a firm to document any work other than that required by the SSARS or SSAEs, the peer reviewer only expresses limited assurance on whether the firm’s documentation conforms with those standards. Some examples of the documentation that a reviewer would consider in his or her procedures include:

  • Management representation letter on review engagements
  • Documentation of the matters covered in the accountant’s inquiry and analytical procedures in a review engagement.
  • Documentation as may be required by SSAEs, such as might have been the case in a WebTrust engagement.

As with a system review and the former off-site review, an engagement review still included a report, letter of comments (if applicable), letter of response, technical review, committee acceptance, and monitoring actions (if considered appropriate.)

Report Review

This type of review applies only to firms that perform compilations that omit substantially all disclosures. There is one exception to this general rule. If the firm compiles financial statements that include, as referred in the SSARSs, “selected information—substantially all disclosures required are not included,” then the firm must undergo an engagement review. At its option, a firm required to have only a report review, may elect to have either a system review or an engagement review.

At the conclusion of the report review, the reviewer gives the firm a report listing comments and recommendations based on whether the financial statements and the related accountant’s reports appear to conform with the requirements of professional standards in all material respects. The change in the process was designed to be a more informal process as compared with the mechanism under the off-site approach for those firms that performed only compilations that omitted substantially all disclosures.

A report review remained subject to a technical review, and was still subject to possible acceptance by the administering entity’s Report Acceptance Body. In addition, the Report Acceptance Body can impose monitoring actions on the firm and/or reviewer.

The AICPA's expectation for these types of reviews was that by streamlining the process, including not requiring a formal response, the technical reviewer would be able to accept 85% or more of report reviews on the committee’s authority within 30 days of receiving the signed peer review report. Prior to this change, the process often took between three and six months.

 

2004 Revisions to the Standards

In 1998, the Board began a two-phase reevaluation process of the validity and objectives of the AICPA A PRP to ensure the PRP was continuing to enhance the quality of accounting and auditing practices of public accounting firms. The Board recognized that protecting the public interest was an equally important objective of the PRP. Phase I of the process was completed in 1999. Among other changes to the Peer Review Standards that became effective in 2001, this phase created the current three-tiered approach to peer review consisting of system, engagement and report reviews.

Phase II began in 2001. The Board’s goal was to reevaluate and analyze the objectives, performance, reporting, transparency, administration and overall effectiveness of system reviews to determine whether they were still relevant, efficient, modern and valid. Among the factors that the Task Force considered were changing regulatory and practice environments. The Board solicited comments from the National Association of State Boards of Accountancy (NASBA), state boards of accountancy (BOAs), General Accounting Office (GAO), Department of Labor (DOL), reviewers, administrators and other interested parties.

In 2003, the Board issued an exposure draft (ED) on revised standards. Later that year, after taking into account written responses to the ED, the Board approved the final standards. These standards and new interpretations were issued in 2004 and are effective for peer reviews commencing on or after January 1, 2005.

Standards for Performing and Reporting on Peer Reviews

Interpretations No. 1 - 13

Interpretation No. 14
Ethics Interpretation No. 101-3 and its Effects on Peer Review

Summary of Statements on Quality Control Standards


Peer Review Guide > Standards for Performing and Reporting on Peer Reviews > History