It is a process that the American Institute of CPAs (AICPA) has created to help keep up with the evolving changes in the business and regulatory environments and to address the demand for greater peer review transparency.

This 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 Accountany (BOAs) obtain peer review results. Over time, this process will help make submission of your firm's peer review information eaiser.  Visit the Minnesota Office of the Revisor of Statutes website for additional information on Minnsota's peer review information submission requirements.

Firms with their main office in Minnesota that have their peer reviews administered by the Minnesota Society of CPAs and have their review accepted on or after October 2, 2008 will participate in the FSBA process.

This includes firms that already allow their peer review results to be posted to the existing public file as a condition of membership in the Governmental Audit Quality Center (GAQC), Employee Benefit Plan Audit Quality Center (EBPAQC) or Private Companies Practice Section (PCPS).

 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 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.

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.

Until our national goal is reached, this process WILL NOT replace the current peer review information submission requirements of the Minnesota Board of Accountancy, which licenses firms practicing in Minnesota. Therefore, firms will need to follow the current Minnesota Board of Accountancy requirements until notified differently. Visit the Minnesota Office of the Revisor of Statutes website for additional information on Minnesota's peer review information submission requirements.

After careful evaluation of the various options, stakeholders determined that the best way to address the user demands for greater peer review transparency, while considering member and state CPA society concerns, was to use the existing peer review process to facilitate the voluntary disclosure of peer review results to BOAs. The intent of this process is to create a nationally uniform system through which CPA firms can satisfy state board peer review information submission requirements, increase transparency, and retain control over their peer review results.

Minnesota began the FSBA process for firms that had their reviews accepted October 2, 2008 and after. Full national implementation was May 2009 in connection with the acceptance of new peer review reports issued under the revised AICPA Standards for Performing and Reporting on Peer Reviews(Standards).

FSBA uses an opt-out process that allows peer review results to be made available to select BOAs on a voluntary firm basis, using a secure, BOA access-only web site that will only be available to authorized state board representatives. Firms will receive instructions, either in their review scheduling form or along with their acceptance letter, that notifies them of the Minnesota Society of CPAs intent to post their peer review information to the secure BOA web site. Firms that are not members of the AICPA Employee Benefit Plan Audit Quality Control Center, Government Audit Quality Center or Private Companies Practice Section will be given an opportunity of opt out of the process. Below are the details of how the process will work.

In Minnesota, the process will entail:

• Making peer review results available to select BOAs on a voluntary firm basis, using a secure, BOA access-only web site that will be available only to authorized state board representatives. The Minnesota Society of CPAs will post applicable peer review information related to a firm's most recently accepted review to this secure BOA web site unless the firm requests that its information be excluded.
• Once the Minnesota Society of CPA posts the information, the firm's managing partner and peer review contact will receive a confirmation via email (or regular mail if email is not available) informing them that the results have been posted to the site and a reminder that the firm has 30 days from the date of the acceptance letter to opt-out of the process. The email also provides the partner and peer review contact the opportunity to make the  firm's results available to additional select BOAs.
• After 30 days, if the firm does not opt out, the firm's peer review results will be available to authorized BOA representatives via a secure BOA web site. It is anticipated that this option will be beneficial, over time, to firms with multi-state practices.

Firms can request that their results be made available to more than one BOA, as long as the BOAs require peer review and are not prohibited from obtaining access to peer review information.

 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 the peer review) will be posted.

• Peer review report
• Letter of comments (applicable only to reviews performed prior to 1/1/09)
• 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

A firm that is not a member of the AICPA Employee Benefit Plan Audit Quality Center, Governmental Audit Quality Center or Private Companies Practice Section may opt out at any time by notifying the Minnesota Society of CPAs in writing. Once the Minnesota Society of CPAs 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.

 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 will also include firms that have been dropped.

There may be situations where a time lapse occurs between the AE receiving the signed acceptance letter and the 30 days to opt out. An AE will not post the firm's peer review information to the secure BOA web site unless it has received the signed acceptance letter because a review is not considered accepted until the firm agrees in writing to take the action required. For firms that ultimately elect not to opt out, the peer review information would be posted the later of 30 days after the date of the acceptance letter or the date the acceptance letter is signed by the firm.

No. There is growing demand for increased transparency in all facets of business; this demand is driven by marketplace and regulatory trends that affect firms of all sizes. Currently, 47 out of 54 state boards of accountancy either mandate peer review as a condition of licensure or have announced plans to do so, and about half of those states already require some form of submission of peer review information as a condition for renewal of a license.

Because the information is already in the public file as a condition of membership, your firm will automatically have its peer review results posted to the secure BOA web site.

Your firm will not be able to opt out from providing access to the Minnesota Board of Accountancy, but will receive a letter from the Minnesota Society of CPAs informing you that your peer review results have been posted to the secure BOA web site and giving  the opportunity to make your peer review results available to other eligible BOAs. If you request the Minnesota Society of CPAs to do so, it will grant access to the authorized state board representatives in the state(s) you specify.

Contact Jill McGuire, Peer Review Coordinator with the MNCPA, or you can contact Gary Freundlich, CPA, Director of Peer Review at the AICPA at gfreundlich@aicpa.org.