Peer Review Extensions & Change in Year-End

Extensions

The firm may realize that it will be unable to complete its peer review or corrective action by the due date assigned.

All requests must be submitted in PRIMA.

Extensions will be considered on a case-by-case basis. Instructions for requesting an extension in PRIMA can be found here.

Acceptable reasons for requesting an extension:

  1. The firm is a new firm because of a merger or dissolution, or a dissolution is imminent.
  2. The firm needs a few months to complete a major engagement that is within the scope of the peer review.
  3. The firm is unable to have the review because of the absence, loss or turnover of personnel significant to the conduct of the review (applicable only to smaller firms).
  4. The firm’s records or offices have been severely damaged or destroyed because of a natural catastrophe.
  5. The firm needs more time because it has selected a reviewer that has a scheduling conflict and is unavailable to perform the review by the firm’s due date but is available to perform the review within one or two months.
  6. There is an incomplete engagement, which is an initial engagement, and there is no comparable engagement (PRC-210 .A19).
  7. Other extraordinary circumstance that, in the Peer Review Committee’s judgment, warrants an extension.

Unacceptable reasons for requesting for requesting an extension:

  1. Vacation schedules of either the individual(s) conducting the review or the firm’s personnel significant to the conduct of the review.
  2. The firm indicates it needs more time to prepare for the review or to implement new quality control policies and procedures.
  3. The firm is developing a quality control document.
  4. The firm is not ready for the review.
  5. The firm has added a new partner.
  6. The nature of the firm's accounting and auditing practice changes. For example: a firm with an audit practice when it enrolled was assigned a due date and later gave up its audit practice, and the firm has not performed an audit for a least a year. In addition, changes in a firm's practice after this year-end should not change the review type or due date of the review, unless those changes would result in a step-up review.

Oregon Firms must submit a copy of an approved extension request to the Oregon Board of Accountancy within 21 days of receiving an extension per OAR-801-050-0020(4)(g)


Hawaii Firms must notify the Hawaii Board of Public Accountancy within 20 days of approval of an extension request per HRS Section 466-34(f)

 

Please Note: If your firm performs engagements under Generally Accepted Government Auditing Standards (GAGAS), please note that the GAO does not automatically accept extensions beyond 3 months. While administrative entities, such as the Oregon Society of CPAs' Peer Review Committee, may grant extensions of more than 3 months, those firms must also request (and be approved for) an extension beyond 3 months from the GAO to avoid noncompliance with GAGAS. The firm should be able to provide the team captain with an approved extension from the GAO, if applicable.

To request an extension, please contact:

Government Auditing Standards
U.S. General Accounting Office
(202) 512-9535

If a firm is unable to complete its peer review by the assigned due date and has not been granted an extension, any Yellow Book audit engagements completed or issued during the period between a firm’s peer review due date and the date the peer review is completed (the date of the report) will be automatically considered to be substandard.

If an extension is approved by the GAO, the firm should notify the Peer Review staff in writing.

Change in Year-End

Firms may find that a major engagement routinely is not completed, or its review is due during its busy season, which causes the firm to request an extension. The firm should consider requesting a change in year-end. Please keep in mind a firm’s next peer review cannot cover a twelve month period that extends beyond three years from the last peer review.

For example: Firm ABC has an annual engagement for Firm XYZ for a December 31 year-end, which is also the last month in the peer review year. The firm’s peer review is due June 30 the following year. Firm XYZ routinely delays the start of the engagement until June or July, thus causing a delay in Firm ABC completing its review by the due date. Changing to a peer review year-end of September would shorten the period between peer reviews by three months. With a September 30 peer review year-end, Firm ABC’s review would be due March of the following year and for subsequent peer reviews.

Firms are encouraged to discuss a possible change in year-end with the peer reviewer and/or OSCPA Peer Review staff.

Requesting a change in year-end will be available in PRIMA. Please contact OSPCA Peer Review staff for guidance at peerreview@orcpa.org or 503-641-7200 / 800-255-1470 ext.5.

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