MINIMUM OVERSIGHT REQUIREMENTS
In December 2004, the AICPA released enhanced oversight procedures that every peer review administering entity must follow. The minimum that we are required to oversight annually are:
- On-site oversight of system reviews, which may include firm “must-select” engagement oversight – at least 2 per year, rotated among our four states.
- Off-site oversight – at least 2 system reviews, which may include firm “must-select” engagement oversight) and 4 engagement reviews per year, rotated among our four states.
- Reviewer résumé verification – all reviewer resumes must be verified at least every three years.
NEPR is also subject to different types of oversight. See the page discussing AICPA Oversight for further details.
We believe oversight to be a vital component in ensuring the integrity of the Peer Review Program. NEPR will not consider a waiver from an oversight unless a firm is able to substantiate extreme and/or justifiable circumstances.
If you believe this to be the case, please send a letter to NEPR, detailing the circumstances. Each waiver request is evaluated on a case-by-case basis.
oversight of peer reviews and reviewers
NEPR's Peer Review Committee is solely responsible for monitoring and evaluating peer reviews of those firms whose main offices are located in its states. Administering entities are required to submit their oversight policies and procedures to the Peer Review Board(PRB) on an annual basis. In conjunction with the NEPR personnel, the committee establishes oversight policies and procedures that at least meet the minimum requirements established by the PRB to provide reasonable assurance that:
- Reviews are administered in compliance with the administrative procedures established by the PRB.
- Reviews are being conducted and reported upon in accordance with the Standards.
- Results of reviews are being evaluated on a consistent basis.
- Information disseminated by NEPR is accurate and timely.
Throughout the year, NEPR selects various peer reviews for oversight. The selections can be on a random or targeted basis. The oversight may consist of doing a full working paper review off-site, after the review has been performed (off-site oversight), but prior to presenting the peer review documents to the committee. The oversight may also consist of having a committee member or designee actually visit the firm while the peer review team is performing the review (on-site oversight). As part of its oversight process, the NEPR Committee oversights both firms being reviewed as well as reviewers performing reviews.
The selection of firms to be reviewed is based on a number of factors, including, but not limited to, random selection, the types of peer review reports the firm has previously received, whether it is the firm’s first system review (after previously having an engagement or report review), and whether the firm conducts engagements in high risk industries.
All peer reviewers are subject to oversight and they may be selected based on a number of factors, including random selection, frequent submission of unmodified reports without a letter of comments, conducting a significant number of reviews for firms with audits in high risk industries, performance of their first peer review, or performing high volumes of reviews.
Annual Verification of Reviewers’ Resumes
Ensuring that reviewers’ resumes are updated annually and are accurate is a critical element in determining if the reviewer or review team has the appropriate knowledge and experience to perform a specific peer review. NEPR must verify information within a sample of reviewers’ resumes on an annual basis. All reviewer resumes are verified over a three-year period.
Verification includes the reviewers’ qualifications and experience related to engagements performed under GAGAS, audits of employee benefit plans under ERISA, and audits of insured depository institutions subject to FDICIA. Verification procedures may include requesting copies of their license to practice as a certified public accountant; continuing professional education (CPE) certificate from a qualified reviewer training course; CPE certificates to document the required 48 CPE credits related to accounting and auditing to be obtained every three years with at least 8 hours in one year; and CPE certificates to document qualifications to perform Yellow Book audits, if applicable. NEPR also verifies whether the reviewer is a partner or manager in a firm enrolled in a practice monitoring program and whether the reviewer’s firm received an unmodified report on its most recently completed peer review.