Two deadlines to keep in mind if your peer review didn’t go well

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If your peer review resulted in anything other than a pass report there are a couple of deadlines you need to remember if you are in California.

Keep in mind you are responsible for your compliance with regulations. Here are a few tips to point you in the right direction. These comments discuss the regs in California. If you are in another state, you really ought to check out what your board of accountancy has to say. I’ll guess there is some comparable reporting requirement when a peer review does not turn out well.

Notification requirement for reports less than pass — 45 days

If you received either a pass with deficiency or a fail report, you need to be in touch with the California Board of Accountancy (CBA).

Within 45 days of the pass with deficiency or fail report being formally accepted by CalCPA’s Peer Review Committee, you need to send a copy of the peer review report to CBA.

You can tell when that clock starts ticking because you will receive a letter saying the PRC has accepted your report on a specific date.

You also need to send a copy of any corrective actions imposed by the PRC and any documents showing you have complied.

The CBA regulations have the following requirements in article 6, section 46. Since this is a public document I will quote it in part:

Document Submission Requirements

(a) A firm receiving a peer review report issued under Section 48(b)(1)(C) or (b)(2)(C) shall submit a copy of the peer review report to the Board including any materials documenting the prescription of remedial or corrective actions imposed by a Board-recognized peer review program provider within 45 days of the peer review report being accepted by a Board-recognized peer review program provider. A firm shall also submit to the Board, within the same 45-day reporting period, any materials, if available, documenting completion of any or all of the prescribed remedial or corrective actions.

The references of 48(b)(1)(C) or (b)(2)(C) refer to a pass with deficiency or fail report. Please look it up yourself.

Notification requirement for expulsion from peer review program — 30 days

Firms going through peer review are required to obtain a pass report in at least one of the two latest reviews. This means if you get two reports in a row of less than pass, you may be referred for a hearing to consider whether you will be kicked out of the peer review program. It is my perception you should assign a probability of getting a hearing referral somewhere in the range of it’s-gonna-happen.

I don’t understand that hearing process or the criteria for expelling a firm from the peer review program. If you’re headed down that path, I seriously suggest you get yourself educated really fast. The far better approach is to do sufficiently good work that you get pass reports on a routine basis.

About that requirement…

If you are kicked out of the peer review program you are required to notify CBA within 90 days along with the reason for expulsion.

You can find this requirement in Article 6 Section 44 of the CBA regulations, which I will quote:

Notification of Expulsion

A firm that is expelled by a Board-recognized peer review program shall notify the Board in writing within 30 days and provide the name of the Board-recognized peer review program and reason(s) given to the firm by the peer review program for the expulsion.

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