Peer Review FAQ

Who needs to be enrolled in the peer review program?

All firms in public accounting that perform accounting and auditing services within the scope of the AICPA practice monitoring standards and issue reports purporting to be in accordance with AICPA professional standards need to be enrolled in the peer review program. This is a requirement under both AICPA and MNCPA bylaws 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.

Does my firm need to be enrolled in the peer review program if the firm does not have an audit and accounting practice?

If a firm does not perform accounting and auditing services that include issuing reports purporting to be in accordance with AICPA professional standards, it is not required to enroll in the peer review program. An accounting and auditing practice is defined as all of a CPA firm’s engagements performed under Statements on Auditing Standards (SASs), Statements on Standards for Accounting and Review Services (SSARS), Statements on Standards for Attestation Engagements (SSAEs), Government Auditing Standards (the Yellow Book), and engagements under PCAOB standards that are not subject to PCAOB permanent inspection.

Does my firm have to enroll in a peer review program if it only performs preparation engagements under AR-C section 70?

If a firm performs preparation engagements as its highest level of service, the firm is not required to enroll in the peer review program. However, if the firm chooses to be enrolled in the peer review program, a peer review is required even if preparation engagements are the only engagements performed.

If a firm no longer performs engagements that require the firm to be enrolled in peer review, how does the firm unenroll from the program?

A firm unenrolls in PRIMA by:
  • Updating and submitting the firm’s Peer Review Information (PRI),
  • Completing the “Resign My Firm” section and submitting.

When is my firm's initial peer review?

A peer review covers a 12-month period, and the firm is given six months in which to have a review and submit it to the administering entity. A firm’s due date for its initial peer review is ordinarily 18 months from the date it enrolled in the program, or should have enrolled, whichever date is earlier. The firm should enroll in the program by the report date of the initial engagement. The peer review administering entity (AICPA or MNCPA) will provide guidance on the due date for the initial review. The firm and the firm’s peer reviewer should determine the peer review year end for the firm. Each subsequent peer review ordinarily has a due date of three years and six months from the year-end of the previous review.

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 is designed to provide a peer reviewer with a reasonable basis for expressing an opinion on whether, during the year under review:

  1. The reviewed firm’s system of quality control for its accounting and auditing practice has been designed in accordance with quality control standards established by the AICPA and
  2. The reviewed firm’s quality control policies and procedures were being complied with to provide the firm with reasonable assurance of performing and reporting in conformity with applicable professional standards in all material respects.

This type of review is for firms that perform engagements that are under the Statements on Auditing Standards (SASs,) the Government Auditing Standards (Yellow Book), examinations under the Statements on Standards for Attestation Engagements (SSAEs), or engagements under the PCAOB standards as their highest level of service.   

Example procedures in a System Review include, but are not limited to:

  • interviewing firm personnel,
  • examining CPE records,
  • examining outside consultations regarding A&A matters,
  • examining independence representations,
  • testing a reasonable cross-section of the firm’s engagements with a focus on high-risk engagements and significant risk areas.

The majority of the procedures in a System Review should be performed at the reviewed firm’s office. A reviewer can request the administering entity’s approval to perform the review at a location other than the reviewed firm’s office if an on-site peer review is cost prohibitive or extremely difficult to arrange, or both.

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.

What is an engagement review?

The objective of an Engagement Review is to evaluate whether engagements submitted for review are performed and reported on in conformity with applicable professional standards in all material respects. 

Enrolled firms that only perform services under SSARSs or services under the SSAEs that do not require System Reviews are eligible to have Engagement Reviews.

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 the applicable documentation required by professional standards. 

An Engagement Review does not provide the review captain with a basis for expressing any form of assurance on the firm’s system of quality control for its accounting practice. However, firms eligible for an Engagement Review may elect to have a System Review.

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

The firm’s Peer Review Contact will be notified via email 220 days before its peer review due date to log in to the Peer Review Integrated Management Application (PRIMA) and complete its Peer Review Information (PRI) form. Submission of the PRI is the first of multiple steps that the firm will be prompted to complete in PRIMA.

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

How does my firm select a peer reviewer?

A list of qualified peer reviewers is available on the MNCPA website. The AICPA also has a robust search function to find a peer reviewer [AICPA Reviewer Search] 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.

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 to 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.

The AICPA Peer Review Program Standards require engagements selected for review to 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; the results of reviews or inspections performed by regulatory or governmental entities; 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 of the following types of engagement should be selected for review:

  • Engagements subject to Government Auditing Standards (GAS),
  • Audit subject to Employment Retirement Income Security Act (ERISA),
  • Engagements subject to the Federal Deposit Insurance Corporation Improvement Act (FDICIA),
  • Audits of broker dealers, and
  • Examinations of service organizations (SOC 1 and SOC2 engagements).

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

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
  5. Preparation engagements in defined circumstances.

One engagement should be selected from each partner, or individual of the firm, if not a partner, responsible for the issuance of reports listed. 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 above does not have to be reviewed as long as, for the firm taken as a whole, all types of engagements performed by the firm are covered.

My peer reviewer has completed his or her work. What do I do next?

After the peer review is completed, the firm’s Peer Review Contact should watch for email notifications to log in to PRIMA and complete any additional steps such as responding to any Matters or Findings noted by the reviewer. 

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

When the peer review has been completed and all required documents have been uploaded into PRIMA, the review is 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.

What is the peer review acceptance process?

At completion of the technical review, a review is ready for consideration at a Peer Review Committee RAB (Report Acceptance Body) meeting made up of volunteer peer review committee members. The RAB will evaluate, based on the work of the peer reviewer and technical reviewer, whether to accept the review as complete or request the firm to complete corrective action.

If the review is accepted by the committee as complete, the review is closed and the firm’s Peer Review Contact will receive email notification to log into PRIMA to acknowledge and download the peer review acceptance letter. 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 RAB decides corrective action is appropriate, the firm’s Peer Review Contact will log in to PRIMA to download a letter outlining the required corrective actions and the due date by which these actions must be completed. The firm must first acknowledge in PRIMA its agreement to the required actions. When the actions have been completed, the firm will upload to PRIMA documents supporting completion of the actions. The documents are sent to a technical reviewer for review and may be presented to a RAB for acceptance. Once it is determined that the firm has completed the required corrective action, the review will be closed and a letter sent to the firm through PRIMA. If the firm does not successfully complete the required follow-up actions the first time, the RAB may 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?

  • Peer Review Report (including the firm’s letter of response, if applicable)
  • RAB acceptance letter (signed by the firm if the letter specified corrective action)
  • RAB letter accepting corrective action as complete (if applicable)

Send the required documents to:

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

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 that would have required the firm to have a system review, the firm should (a) immediately notify the administering entity by updating its enrollment information in PRIMA 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 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.