Harbor & Pine, LLP has a new mix of A&A work on the calendar and a peer review year end already set. The practical question is not abstract. It is whether the firm has to be enrolled now and, if it is enrolled, whether the calendar supports finishing the peer review by the due date instead of slipping into a compressed review window that drives staffing pressure and late submissions.
The case facts we will use stay fixed throughout. Harbor & Pine, LLP has 6 CPAs. Its last peer review year end was 12/31/2023 and its next peer review year end is 12/31/2026. Over 2024 to 2026 the firm performs 2 audit engagements, 1 SSAE examination, 6 SSARS reviews, and 14 SSARS compilations with reports. A peer review year end of 12/31/2026 means the firm is measuring what it did in the year ending on that date and then planning backward so the administering entity receives complete, timely documentation for committee consideration and acceptance. Use the timeline to orient to the engagement mix and the review year end:
Before we name any rule, we decide what Harbor & Pine actually did that could bring it into the peer review program. The firm issued reports on audits, a SSAE examination, SSARS reviews, and SSARS compilations with reports. Those are the types of services that are commonly within the scope of peer review standards when a firm issues reports that purport to be in accordance with AICPA professional standards, which is the practical trigger that moves a firm from “no A&A practice” to an A&A practice for practice monitoring purposes. Getting this determination wrong has a concrete outcome. A firm can be late to enroll, which can force an accelerated due date and create a compliance problem with membership or licensing expectations.
The enrollment decision we have to make is binary. Based on the engagement mix given, does Harbor & Pine have an A&A practice that requires participation in a practice monitoring program? The AICPA practice monitoring requirement is stated in the Peer Review Program Q&A. AICPA members active in public practice must be associated with a firm that participates in an AICPA practice monitoring program if the firm performs services within the scope of the peer review standards and issues reports purporting to be in accordance with AICPA professional standards. The same guidance also explains that a firm is not required to enroll if it does not have an accounting and auditing practice, which makes the engagement mix the key fact pattern to resolve first. Commit to the “must enroll” or “does not have to enroll” conclusion here: