In circumstances expected to be rare and unusual, a firm may find that it cannot have its peer review by the date assigned. The firm must submit a request for an extension through PRIMA prior to the due date of the review. Ordinarily, the request should be submitted during the planning stages of the review, but not later than 60 days prior to the due date. The request should cite the reasons the firm cannot undergo the review and offer an alternative due date. Each extension request will be considered on a case-by-case basis. Requests cannot be made for any more than 90 days past the original due date. If a firm wishes to change its peer review year-end, that request can be made separately or in addition to any request for an extension of the peer review due date. Extension requests submitted after the review due date has passed will not be granted under any circumstances. (AICPA Administrative Manual, Chapter 7, Interpretation 18-1)
Special Note: If the firm requesting an extension performs engagements under Government Auditing Standards (GAS), the firm should be aware that the U.S. Government Accountability Office (GAO) does not accept extensions granted by the administering entity beyond three months. Requests for extension beyond three months for firms that perform audits under GAS can only be granted by the GAO. Per GAS, "the external peer review should be conducted within three years from the date they start field work on the first engagement under GAS. Subsequent external peer reviews should be conducted every three years. Extensions beyond three months can only be granted by GAO and should only be requested for extraordinary circumstances." Such requests should be addressed to: Michael C. Hrapsky, Senior Project Manager, Government Auditing Standards, U.S. Government Accountability Office, (202) 512-9535.
Acceptable reasons for requesting an extension
- The firm is a new firm as a result of a merger or dissolution.
- The firm needs a few months to complete a major engagement (one to two months granted).
- The timing of the review conflicts with the firm's busy season (one to two months granted).
- The firm is unable to have the review because of an absence, loss or turnover of personnel significant to the conduct of the review (applicable only to smaller firms).
- The firm's records or offices have been severely damaged or destroyed because of a natural catastrophe.
- The firm needs more time because it has selected a reviewer that has a scheduling conflict and is unavailable to perform the review by the firm's due date, but is available to perform the review later in the calendar year (one to two months granted).
- One of the firm's partners has a family or medical emergency (applicable only to smaller firms).
Unacceptable reasons for requesting an extension
- The firm indicated that it needed more time to prepare for the review or to implement new quality control policies and procedures.
- The firm is developing a quality control document.
- The firm is relocating or renovating its offices.
- The nature of the firm's accounting and auditing practice changes (for example, a firm with an audit practice when it enrolled was assigned a due date, and later gave up its audit practice and the firm has not performed an audit for at least a year).
For questions about extension requests, please contact the VSCPA Peer Review Team at [email protected] or (800) 733-8272, option 4.