Peer Review FAQ

Who needs to be enrolled in the peer review program?

All firms in public accounting need to be enrolled in the peer review program. This is a requirement for MNCPA membership, and is also required by the Minnesota Board of Accountancy as a condition for obtaining a firm permit for firms that perform attest and/or compilation engagements.

Do I still need to be enrolled if my firm doesn't perform any audit or accounting engagements?

Firms that do not perform any reviewable engagements (audits, reviews, compilations with or without disclosures or other attest engagements) still need to be enrolled in the program. However, they do not need to pay any fees associated with the program. They must annually confirm this status with the MNCPA by returning the confirmation letter that is sent out in June.

How do I enroll?

A firm needs to complete and return the peer review enrollment form to the MNCPA.

Non-AICPA Enrollment form
AICPA Enrollment form

When is my firm's initial peer review?

A firm's initial peer review is due 18 months after the year-end of the firm's first reviewable engagement. A peer review covers a 12-month period, and the firm is given six months to complete the peer review. For example, if a firm's initial engagement has a year-end of December 31, 2007, the firm's peer review would be due June 30, 2009.

My peer review due date is coming up this year. What do I need to do?

Approximately six to nine months prior to a firm's due date, the MNCPA will send out a scheduling form (PDF) that needs to be completed and returned. The firm will also need to complete the reviewing firm information, such as the name of the peer reviewer, and the commencement and exit conference date of the peer review.

The firm needs to make arrangements with the peer reviewer directly. A list of qualified peer reviewers is available.

Upon receipt of the completed form, the MNCPA will enter the information into the electronic peer review system, which will determine if the peer reviewer is qualified to perform the review. If the reviewer is qualified, an acceptance letter is sent to the firm and the peer reviewer authorizing the peer review to take place. A peer review can not be performed without the acceptance letter stating the peer reviewer is qualified.

How does my firm select a peer reviewer?

A list of qualified peer reviewers is available on the MNCPA website. Many firms select as a peer reviewer a firm that is similar in size and practice. The firm needs to make certain that the peer reviewer is qualified to review any specialized area of its practice, such as governmental audits. CPA colleagues can also be a good referral source for selecting a peer reviewer. In addition, the AICPA has an article on tips for selecting a peer reviewer.

What are the two types of peer reviews and what type does my firm need?

There are two types of peer reviews: System reviews and Engagement reviews. The type of services performed by your firm will determine what type of peer review your firm is required to have.

What is a system review?

A System review includes determining whether the firm's system of quality control for its accounting and auditing practice is designed and complied with to provide the firm with reasonable assurance of performing and reporting in conformity with applicable professional standards, including SQCS No. 7, in all material respects. This type of review is for firms that perform engagements under the Statement on Auditing Standards (SASs), the Government Auditing Standards (Yellow Book) or examinations of prospective financial information under the Statement on Standards for Attestation Engagements (SSAEs) or audits of non-SEC issuers performed pursuant to the standards of the PCAOB.

Approximately 14,000 firms nationwide are likely to have a system review over the next three years. The scope of the peer review does not encompass other segments of a CPA practice, such as tax services or management advisory services, except to the extent they are associated with financial statements, such as reviews of tax provisions and accruals contained in financial statements.

In a system review, the reviewer will study and evaluate a CPA firm's quality control policies and procedures that were in effect during the peer review year. This includes interviewing firm personnel and examining administrative files. To evaluate the effectiveness of the system and the degree of compliance with the system, the reviewer will test a reasonable cross-section of the firm's engagements with a focus on high-risk engagements, in addition to significant risk areas where the possibility exists of engagements being performed and/or reported on that are not in accordance with professional standards in all material respects. The majority of the procedures in a System review should be performed at the reviewed firm's office.

What is an engagement review?

This type of review is for firms that are not required to have a system review and only perform services under SSARS or services under the SSAEs not included in the System reviews. The objective of an Engagement review is to evaluate whether engagements submitted for review are performed on in conformity with applicable professional standards in all material respects. An Engagement review consists of reading the financial statements or information submitted by the reviewed firm and the accountant's report thereon, together with certain background information and representations and, except for compilation engagements performed under SSARS, the applicable documentation required by professional standards.

This type of review does not cover the firm's system of quality control, so the reviewer cannot express an opinion on the firm's compliance with its own quality control policies and procedures or compliance with AICPA quality control standards.

Engagement reviews should improve the quality of engagements and should protect the public that uses and relies on those reports without imposing any additional burden on reviewed firms. Nationally, more than 14,000 firms are likely to have an engagement review over the next three years.

What is the impact on my firm's peer review when my firm completes its first audit engagement after the completion of my engagement review?

When a firm, subsequent to the year-end of its engagement review, performs an engagement under the SASs, Government Auditing Standards or examination of prospective financial statements under the SSAEs, or an audit of a non-Securities and Exchange Commission issuer performed pursuant to the standards of the PCAOB that would have required the firm to have a System review, the firm should (a) immediately notify the administering entity and (b) undergo a System review. The System review will ordinarily be due 18 months from the year-end of the engagement (for financial forecasts and projections 18 months from the date of report) requiring a System review or by the firm's next scheduled due date, whichever is earlier. However, the administering entity will consider the firm's practice, the year-ends of engagements and when the procedures were performed, and the number of engagements to be encompassed in the review, as well as use its judgment to determine the appropriate year-end and due date. Firms that fail to immediately inform the administering entity of the performance of such an engagement will be required to participate in a System review with a peer review year-end that covers the engagement. A firm's subsequent peer review ordinarily will be due three years and six months from this peer review year-end.

Which engagements will my peer reviewer select for my type of peer review?

The reviewer will send an engagement letter to the firm prior to the commencement of the peer review. He/she will select the types of engagements based on the type of review.

System review selections
The AICPA Peer Review Program Standards require engagements selected for review should provide a reasonable cross section of the reviewed firm's accounting and auditing practice, with greater emphasis on those engagements in the practice with higher assessed levels of peer review risk. Examples of the factors considered when assessing peer review risk at the engagement level include size, industry area, level of service, personnel (including turnover, use of merged-in personnel, or personnel not routinely assigned to accounting and auditing engagement), communications from regulatory, monitoring, or enforcement bodies; extent of non-audit services to audit clients, significant clients' fees to a practice office(s) and a partner(s) and initial engagements. In addition, at least  one of each type of engagement subject to Government Auditing Standards (GAS), Employment Retirement Income Security Act (ERISA), the Federal Deposit Insurance Corporation Improvement Act (FDICIA), or of carrying broker dealers must be selected for review.

Engagement review selections
The review captain or the administering entity ordinarily should select the types of engagements to be submitted for review in accordance with the following guidelines:

a. One engagement should be selected from each of the following areas of service performed by the firm:

  1. Review of historical financial statements (performed under SSARS)
  2. Compilation of historical financial statements, with disclosures (performed under SSARS)
  3. Compilation of historical financial statements that omits substantially all disclosures (performed under SSARS)
  4. Engagements performed under the SSAEs other than examinations of prospective financial statements

One engagement should be selected from each partner, or individual of the firm, if not a partner, responsible for the issuance of reports listed in item (a). Ordinarily, at least two engagements should be selected for review.

The preceding criteria are not mutually exclusive. One of every type of engagement that a partner, or individual if not a partner, responsible for the issuance of the reports listed in item (a) in the previous list performs does not have to be reviewed as long as, for the firm taken as a whole, all types of engagements noted in item (a) in the previous list performed by the firm are covered.

My peer review is complete. What do I do next?

After the peer review is completed, the reviewer will mail a written report to the reviewed firm. If the firm receives a rating of either pass with deficiencies or fail, the firm must submit a copy of the report and a letter of response to address those issues to the MNCPA. The firm does not have to submit a copy of the report if the rating is pass.

Why does my review need to go to a technical reviewer?

When the peer review has been completed and the report and letter of response, if applicable, are submitted to the MNCPA, all reviews are sent to a technical reviewer for review. This is to ensure that the review was performed in accordance with the AICPA Standards for Performing and Reporting on Peer Reviews (PDF).

What is the peer review acceptance process?

The review is ready for acceptance upon completion of the technical review. All reviews are presented for consideration at the Peer Review Committee RAB (Report Acceptance Body) meeting made up of peer review committee members. The RAB committee meets once a month from May through January to consider reviews for acceptance. The committee will decide, based on the findings of the peer review and technical review, whether to accept the review or request follow-up action. If the review is accepted by the committee, the review is closed and a final acceptance letter is sent to the firm. The firm's next review will be due in three years and six months from the firm's most recent peer review year-end.

If the committee decides follow-up action is appropriate, a letter will be sent to the firm outlining the follow-up actions and the due date by which these actions must be completed. The firm will submit the documents upon completion of these follow-up actions and it will be presented once again for committee acceptance. Once the committee finds these steps have been successfully completed and implemented, the review will be closed and an acceptance letter sent to the firm. If the firm does not successfully complete the required follow-up actions the first time, the committee will request additional follow-up until it has been successfully completed.

My firm received the RAB acceptance letter. What do I need to send to the State Board?

  • Acceptance letter
  • Letter specifying any follow-up action (if applicable)
  • Peer Review Report
  • Letter of response (if applicable)

Send the required documents to:

Minnesota Board of Accountancy
85 E. Seventh Place Ste. 125
St. Paul, MN  55101