The List of Delays Is Long 

To say the pandemic has had an impact on the effective dates of various rules and regulations would be an understatement. Here are few of the delays and changes (though this list is not completely exhaustive), not including tax due date extensions, from a few American Institute of CPAs (AICPA) boards and government agencies. 

FROM THE EXPERT 

Due to the delay in effective dates of major standards, companies and nonprofits will have some breathing room this year. It will be important to use this time wisely. Once entities have recovered from COVID-19, it will be important to start work on some of the larger standards that take time to implement. These delays will allow for a less frustrating implementation process if used effectively. 

Audit firms need to consider the impact on their quality control as a result of these delays. As most permit early adoption, firms will need to communicate adoption plans and ensure that quality control systems are in place. Having two sets of available standards can create difficulties for firms if an adoption plan is not clearly communicated and understood by the firm. 

—Melisa Galasso, CPA, founder & CEO of Galasso Learning Solutions 

AICPA Auditing Standards Board (ASB)

Statement on Auditing Standards (SAS) No. 141, issued May 1, amends the effective dates of SAS Nos. 134–140. They are now generally effective for audits of calendar year-end 2021 financial statements. But, if firms want to proceed sooner, they may: SAS. No. 141 lifts the prohibition against early implementation. The ASB recommends SASs No. 134–140 be implemented concurrently. 

AICPA Peer Review Board

CPA firms have been granted six-month extensions for peer reviews, corrective actions, and implementation plans with original due dates between Jan. 1 and Sept. 30, 2020. Despite the automatic extension, firms are still encouraged to have their reviews performed as soon as they are able. Find more information at vscpa.com/peer-review or email the VSCPA Peer Review Team at [email protected]. 

AICPA Professional Ethics Executive Committee (PEEC) 

PEEC extended the effective dates of the three interpretations to the AICPA Code of Professional Conduct by one year: 

• Information Systems Services (ET §1.295.145): Effective on Jan. 1, 2022, with early implementation permitted. 
• State and Local Government Client Affiliates (ET §1.224.020): Effective for years beginning after Dec. 15, 2021. 
• Leases (ET §1.260.040): Effective for fiscal years beginning after Dec. 15, 2020, with early implementation permitted. 

PEEC also issued an exposure draft addressing record requests and updates to the interpretation regarding acts discreditable. Comments are due on the draft by Sept. 30, 2020. 

Financial Accounting Standards Board (FASB) 

FASB has extended by one year the effective date of its standards update, Revenue from Contracts with Customers (Topic 606), for non-public entities. Entities are given the choice to adopt on the original timeline or deferring. The effective date for Leases (Topic 842) was amended for private companies and nonprofits, to fiscal years beginning after Dec. 15, 2021, and interim periods within fiscal years beginning after Dec. 15, 2022; early implementation is also permitted.  

Governmental Accounting Standards Board (GASB) 

Statement No. 95 from GASB postpones the effective dates of several statements and implementation guides, including Statement No. 87, Leases, and the leases implementation guide, which have been postponed by 18 months. Visit gasb.org for a list of all delays. 

Office of Management and Budget (OMB)  

To relieve short-term administration, financial management and audit requirements, the OMB released two memorandums in March for those impacted by the pandemic and receiving COVID-19 funding as well as those who were impacted operationally. The guidance addresses flexibility with System for Award Management (SAM) registration and recertification and expenditure of funds by awarding agencies as well as provides delays for single audit deadlines. Those receiving COVID-19 funding have an extra 12 months to submit their single audits, while those impacted operationally will have an extra six months.  

U.S. Government Accountability Office (GAO) 

The GAO provided exceptions for circumstances related to the pandemic for CPE requirements for auditors as outlined in generally accepted government auditing standards (GAGAS, i.e. Yellow Book). This includes a six-month grace period to complete CPE. More details are available in the “COVID-19: GAGAS CPE Alert” at gao.gov.