Janice Gray

NASBA Chair Janice L. Gray and President & CEO Ken L. Bishop have written to the AICPA Professional Ethics Executive Committee expressing NASBA’s concerns about PEEC’s proposed Staff Augmentation Arrangements Interpretation, which would address a nonattest service in which a CPA firm’s staff provides services to an attest client under the client’s supervision. Their letter states: “Overall, NASBA recommends the PEEC not adopt the proposed interpretation as we believe the premise that firms may lend their staff to perform services under the client’s supervision is inconsistent with the existing and longstanding provision in the Code [of Professional Conduct] that bars simultaneous employment with an attest client.”

The February 25, 2019 letter explains: “First and foremost, we are concerned that the manner in which staff would be employed in this proposal would make them indistinguishable from an attest client’s other employees because client management would be responsible for directing the staff’s daily activities. We believe this will be the case even if the CPA applies the required and suggested, optional safeguards described in the Exposure Draft.”

The proposed interpretation would be “challenging to interpret, apply and enforce” given its subjectivity, the letter states. For example, an engagement is of “short duration” could mean it lasts a week or a year. The safeguards to be applied rely to some extent on the CPA’s judgement as to whether they consider the arrangement to be of “short duration.”

NASBA’s comment letters can be found on the Publications page of

The AICPA Professional Ethics Executive Committee is composed of 20 members, four recommended by NASBA. They are: Samuel L. Burke-Chair, Coalter Baker, Carlos Barrera, Stanley Berman, Chris Cahill, Tom Campbell, Robert E. Denham, Anna Dourdourekas, Gregory Gunn, Kelly H. Hunter, Sharon Jensen, Martin Levin, Brian S. Lynch, Bill Mann, William McKeown, Steven Reed, Stephanie Saunders, Lisa Snyder, James Smolinski and Shelly Van Dyne.

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