VSCPA Comments on Virginia Board of Accountancy Peer Review Oversight Committee Proposal

July 16, 2010

 

Tyrone E. Dickerson, CPA 

Chair, Virginia Board of Accountancy

9960 Mayland Drive, Suite 402                                    
Richmond, VA 23233                                                    

 

Wade Jewell

Executive Director, Virginia Board of Accountancy
9960 Mayland Drive, Suite 402

Richmond, VA 23233

 

Dear Mr. Dickerson and Mr. Jewell:

 

On behalf of the Virginia Society of CPAs (VSCPA), I would like to thank you for the opportunity to review and comment on the Virginia Board of Accountancy (VBOA) “Draft Document for Adoption of Peer Review Oversight Committee (PROC),” as adopted at the VBOA meeting held on June 30, 2010.

 

The VSCPA had the opportunity to provide input and feedback regarding the proposal and appreciates that the changes requested were made. After observing the discussion regarding the process by which members will be appointed to the PROC, the VSCPA has the following additional feedback we would like to present:

 

  • A nominations process to identify and evaluate individuals to be considered for the PROC is an important component for the VBOA to consider. This process would entail some form of interview, which could even be in the form of a written questionnaire. A nominations process would ensure due care is taken so that PROC appointees have appropriate experience and expertise, as well as an objective mindset. For example, candidates could be asked if they have ever been sanctioned as a peer reviewer for performance deficiencies.
  • There was some discussion at the June 30 meeting about the VBOA appointing a chair for the PROC and delegating the authority for appointing additional members to the chair. The VSCPA believes, however, that all members of the PROC should be appointed by the VBOA. This would ensure that all members of the PROC are independently-minded individuals who are accountable to the VBOA, as well as independent of each other.
  • The composition of the PROC should include at least three members and, if possible, should be representative of the firms required to undergo peer review as administered by the VSCPA. Of the 965 Virginia firms currently enrolled in the Peer Review Program, more than 500 are sole proprietors and more than 850 have 10 or fewer professionals. Therefore, the VSCPA recommends having a diverse PROC with representation from firms of various sizes.

 

The VSCPA understands the VBOA’s rationale for establishing a PROC and applauds the VBOA for its commitment to upholding the spirit in which the Peer Review Program was established, i.e. educational and remedial. As such, it is critical that the PROC be established in a fair, transparent manner.

 

Thank you again for the opportunity to comment on this important process. If you have questions or would like to discuss any of these comments further, please contact Emily Walker at (804) 612-9428 or ewalker@vscpa.com.

 

Sincerely,

 

Bradford R. Jones, CPA

Chair, Virginia Society of CPAs

 

Cc:       AICPA Peer Review Division

            VSCPA Peer Review Committee

LAST UPDATED 7/20/2010

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