Facilitated State Board Access in Michigan


Frequently Asked Questions

1.
Question: What is Facilitated State Board Access?

It is a process created by the American Institute of Certified Public Accountants (AICPA) to help keep up with the evolving changes in the business and regulatory environments and to address the demand for greater peer review transparency.

2.
Question: How does my firm benefit from this Facilitated State Board Access (FSBA) process?

The process is intended to create a nationally uniform system through which CPA firms can satisfy state board or licensing body peer review information submission requirements, increase transparency and retain control over their peer review results. The AICPA and CPA state societies are working together to allow this process to become the primary means by which all State Boards of Accountancy (BOAs) obtain peer review results. Over time, this process has become helpful in making submission of your firm’s peer review information easier.

View Michigan’s submission requirements here.

3.

Question: Which firms in Michigan will be affected by the FSBA process?

Firms with their main office located in Michigan that had their peer reviews administered by the Michigan Association of Certified Public Accountants (MICPA) and had their review accepted on or after September 30, 2008.

4.
Question: Will a firm’s peer review information be made public as a result of this process?

No, a firm’s peer review information will not be made available to the public as a result of this process. A firm’s peer review results will be posted to a secure BOA access-only website that will only be available to authorized state board representatives. 

However, many firms already make their peer review results available as part of their AICPA membership or a Government Accountability Office (GAO) or BOA requirement. In addition, many firms make their peer review results available upon client request as it demonstrates a firm’s commitment to quality.

5.

Question: Will my firm’s peer review information that is posted to the secure BOA website be shared with others?

That is not the intention of this process; however, each BOA’s laws and regulations govern this matter. In addition, due to the Freedom of Information Act (FOIA), legislation that applies in some instances, BOAs may share information with others once they have obtained it.

6.

Question: Why Facilitated State Board Access?

After careful evaluation, stakeholders determined that the best way to address user demands for greater peer review transparency, while considering member and state CPA society concerns, was to use the existing peer review process to facilitate the voluntary disclosure of peer review results to BOAs. The intent of this process is to create a nationally uniform system through which CPA firms can satisfy state board peer review information submission requirements, increase transparency and retain control over their peer review results.

7.

Question: When was Facilitated State Board Access implemented?

Michigan began the FSBA process for firms that had their review accepted in the fall of 2008 and after.

8.

Question: How does this process work?

FSBA uses an opt-out process that allows peer review results to be made available to select BOAs on a voluntary firm basis, using a secure, BOA access-only website that is only available to authorized state board representatives. During the scheduling process, firms will be given the opportunity to opt into the process. For firms whose main office is located in Michigan, their peer review administering entity is the Michigan Association of CPAs (MICPA). Firms that are not members of the AICPA Employee Benefit Plan Audit Quality Center, Governmental Audit Quality Center or Private Companies Practice Section will be given an opportunity to opt out of the process. 

When they are available, the Peer Review Integrated Management Application (PRIMA), the AICPA’s new peer review operations system, will post applicable peer review information related to a firm’s most recently accepted peer review to this website unless the firm requests that its information be excluded.  The firm will be notified when access to the firm’s posted peer review documents has been given.

Firms can request that their results be made available to more than one BOA, as long as the BOAs require peer review and are not prohibited from obtaining access to peer review information. It is important to note, however, that firms are required to notify LARA directly within 30 days of receipt of a Fail report or a second consecutive report of Pass with Deficiencies. “Opting in” to the FSBA submission process does not satisfy this requirement. A firm’s failure to notify LARA independently may result in fines from $1,000.00 to $25,000.00.

9.
Question: When can I expand access to other BOAs?

Firms will be provided with the opportunity to select additional BOAs for expanded access. However, access will not be granted until the selected state or states participate in the FSBA process.

Firms will be notified by the MICPA when the BOAs they have selected for expanded access participate in FSBA. This will remind firms of their selection and provide them with the opportunity to change their decision regarding expanded access.

10.

Question: What peer review information will be posted by the MICPA to the secure BOA website for firms that do not opt out?

The following documents will be posted, as applicable to the secure BOA website. The number of documents posted for each firm can vary based upon the results of the peer review. It is important to note that unless a firm opts out, all applicable documents will be posted even if it is not a state requirement. A firm that does not opt out will not choose which documents to post as each of those applicable (based on the results of its peer review) will be posted.
  • Peer Review Report
  • Letter of Response (if applicable)
  • Acceptance Letter
  • Letter(s) signed by the reviewed firm indicating that the peer review documents have been accepted with the understanding that the reviewed firm agrees to take certain actions (if applicable)
  • Letter notifying the reviewed firm or individual that certain required actions have been completed (if applicable)
11.
Question: What if my firm changes its mind and wants to opt out after the information has been posted?

A firm that is not a member of the AICPA Employee Benefit Plan Audit Quality Center, Governmental Audit Quality Center or Private Companies Practice Section may opt out at any time by notifying the MICPA in writing. Once the MICPA has been notified, the access to information will be removed from the website, however, certain information (which is currently publicly available) will remain posted to the secure BOA website.

12.

Question: What happens if my firm decides to opt out?

If a firm chooses to opt out, it is important to note that the information listed below (which is currently publicly available) will remain on the secure BOA website. This information will help us to maintain a complete database of all firms in the Peer Review Program. This includes:
  • The firm’s name and address
  • The firm’s enrollment in the Peer Review Program
  • The date of acceptance and the period covered by the firm’s most recently accepted peer review
  • Whether the firm’s enrollment in the program was terminated. Beginning January 1, 2009, effective with the revised Standards, this also includes firms that have been dropped
13.

Question: What if my firm is required to sign its Acceptance Letter agreeing to take certain actions (as a condition of peer review acceptance), but my firm has not acknowledged the acceptance letter in PRIMA?

There may be situations where a time lapse occurs between the Administering Entity (AE) receiving acknowledgement of the Acceptance Letter and the firm’s decision to opt out.  Access will not be provided to the firm’s peer review information on the secure BOA web site unless it has received acknowledgement of the Acceptance Letter because a review is not considered accepted until the firm agrees to take the actions required.

14.

Question: Isn’t this an example of how rules imposed on large firms can cascade down to small firms?

No. There is growing demand for increased transparency in all facets of business; this demand is driven by marketplace and regulatory trends that affect firms of all sizes. Many state boards of accountancy either mandate peer review as a condition of licensure or have announced plans to do so, and a number of those states already require some form of submission of peer review information as a condition for renewal of a license.

Your firm will be unable to opt out from providing access to the Michigan State Board of Accountancy but will receive an email (or letter via regular mail if email is unavailable) from PRIMA informing you that your peer review results have been posted to the secure BOA website and giving you the opportunity to make your peer review results available to other eligible BOAs.

Email the MICPA Peer Review Department

Or Call Us

David Pickering
Peer Review Senior Manager
248.267.3751

Karen Guerra
Peer Review Specialist
248.267.3718