Facilitated State Board Access FAQ

What is FSBA? | Top
FSBA is a process that the American Institute of CPAs (AICPA) has created to help keep up with the evolving changes in the business and regulatory environments and to address the demand for greater peer review transparency.

How does my firm benefit from the FSBA process? | Top
The FSBA 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. Visit boa.virginia.gov for additional information on Virginia’s peer review information submission requirements.

Which firms in Virginia will be affected by the FSBA process? | Top
Firms with their main office in Virginia are required under the Virginia accounting statutes to participate in the FSBA process. This includes firms that already allow their peer review results to be posted to the existing public file as a condition of membership in the Governmental Audit Quality Center (GAQC), Employee Benefit Plan Audit Quality Center (EBPAQC) or Private Companies Practice Section (PCPS). 

Will a firm’s peer review information be made public as a result of this process? | Top
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 U.S. Government Accountability Office (GAO) or Virginia Board of Accountancy (VBOA) requirement. In addition, many firms make their peer review results available upon client request as it demonstrates a firm’s commitment to quality. 

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

How does this affect my firm’s peer review information submission requirements? | Top
Virginia firms required to undergo peer review are required to participate in the FSBA process. For Washington, D.C., firms, this process WILL NOT replace the current peer review information submission requirements of the District of Columbia Board of Accountancy, which licenses firms practicing in Washington, D.C. 

Why FSBA? | Top
After careful evaluation of the various options, stakeholders determined that the best way to address the 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.

When was Facilitated State Board Access implemented? | Top
Virginia began the FSBA process for firms whose reviews were accepted June 9, 2008, and thereafter. Virginia firms with reviews commencing on or after July 1, 2014, are subject to mandatory participation.

How does this process work? | Top
For Virginia firms, the process will entail making peer review results available to the VBOA using a secure, BOA access-only website that will only be available to authorized state board representatives. The VSCPA will post applicable peer review information related to a firm’s most recently accepted review to this website. 

For Washington, D.C., firms, 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 will only be available to authorized state board representatives. Firms will have the option of "opting out" during the scheduling phase of their peer review provided they are not members of the AICPA Employee Benefit Plan Audit Quality Center, Governmental Audit Quality Center or Private Companies Practice Section.

The firm’s managing partner and peer review contact will receive a confirmation via email (or regular mail if email is not available) notifying them of the posting and offering them the opportunity to make the firm’s results available to additional select BOAs.  

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. However, access will be limited only to those BOAs that are already participating in FSBA.  

When can I expand access to other BOA outside of those currently participating? | Top
Firms will be provided with the opportunity to select additional BOA to receive expanded access once the results are posted. However, access will not be granted until the selected state or states are participating in the FSBA process. Firms will be notified by the VSCPA when the BOA that they have selected for expanded access begin participating in FSBA. This will remind firms of their selection and provide them with the opportunity to change their decision regarding expanded access.

What peer review information will be posted by the VSCPA to the secure BOA?  | Top
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. 

• Peer review report
• Letter of response
• 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
• Letter notifying the reviewed firm or individual that certain required actions have been completed

Isn’t this an example of how rules imposed on large firms can cascade down to small firms? | Top
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. Currently, 47 out of 54 state boards of accountancy either mandate peer review as a condition of licensure or have announced plans to do so, and about half of those states already require some form of submission of peer review information as a condition for renewal of their license.

What happens if my firm already allows its peer review results to be posted to the existing public file as a condition of membership in the Governmental Audit Quality Center (GAQC), Employee Benefit Plan Audit Quality Center (EBPAQC) or Private Companies Practice Section (PCPS)? | Top
Because the information is already in the public file as a condition of membership, your firm will automatically have its peer review results posted to the secure BOA website. Your firm will not be able to opt out from providing access to the Virginia Board of Accountancy but will receive a letter from the VSCPA 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. If you request the VSCPA to do so, it will grant access to the authorized state board representatives in the state(s) you specify.

Who do I contact if I have questions? | Top
You can contact the VSCPA Peer Review Team at [email protected] or (800) 733-8272, option 4, or you can contact AICPA Technical Director Gary Freundlich, CPA, at [email protected].