Due Dates, Extensions, and Year-End Changes
A firm's due date for its initial peer review is ordinarily eighteen months from the date it's required to enroll in the program. The PICPA will consider the firm’s (or individual’s) practice, the year-ends of the firm’s client engagements, when the engagements were performed, and the number and type of engagements to be encompassed in the review to determine an appropriate due date. A firm's subsequent peer review ordinarily has a due date of three years and six months from the year-end of the firm’s most recent review.
Non-AICPA member firms licensed in Pennsylvania with fewer than three licensees may be eligible for a five-year cycle, provided they don't perform audits in accordance with Yellow Book standards.
The PICPA-assigned due date is not recognized by the PA State Board of Accountancy. The PA State Board of Accountancy requires a sole practitioner or firm to have a peer review performed and accepted by an approved administering entity (i.e. PICPA) within 18 months of when it issued its initial license, or 18 months of when it commences work on its initial audit or review engagement.
To allow adequate time for the PICPA to process, review, and accept the peer review, the peer review report should be submitted to the PICPA at least 60 days prior to the license renewal deadline. This processing time is only an estimate and does not guarantee your firm’s peer review will be accepted prior to the licensing deadline.
Firms receive significant advance notice of their due dates. If your due date falls within your busy season, you should plan to submit your review earlier. Firms that wish to accelerate their due date may contact the PICPA. Firms may also permanently change its peer review year-end to a more convenient time of year.
Approximately 5-7 months before your firm’s PICPA-assigned due date, your firm will receive materials from PRIMA to begin scheduling your firm’s peer review. If you need that information earlier to comply with licensing requirements, you should contact the PICPA and specifically request the materials.
A firm may find it cannot have its peer review completed by the due date assigned. In these situations, a firm should request an extension in PRIMA. Ordinarily, extension requests, citing the reasons why the firm cannot complete its review on time, should be submitted least 60 days prior to the due date. Except in rare circumstances, extensions requested after the due date will not be granted.
Pennsylvania License Renewal
Any extension requests to meet Pennsylvania license renewal requirements should be directed in writing to the Pennsylvania State Board of Accountancy
(PA SBOA). The PA SBOA does not recognize extensions granted by PICPA.
Government Auditing Standards
Government Auditing Standards require a firm to have a peer review every three years. The U.S. General Accounting Office (GAO) is not required to recognize extensions granted by PICPA.
The peer review year end is mutually agreed upon by the reviewer and the reviewed firm during the firm’s initial review. After a firm's initial review, the year-end is expected to remain the same for subsequent peer reviews. Circumstances (e.g., changes in practice composition, etc.) may arise that could influence the ongoing appropriateness of a firm’s peer review year-end. A firm is allowed to request a temporary or permanent change to its peer review year-end. However, changes a firm’s peer review year-end must be approved by the PICPA prior to the commencement of the review. Please submit any year-end change requests in writing to the Professional & Technical Standards Team.