Firm data is a major focus right now in light of the DOL audit quality study results and the related challenges with peer review. As a result, we’ve begun collecting two additional pieces of data in the ALD feeds from Boards: EINs (employer identification numbers) and peer review requirement data. Having firm EINs provides a unique ID to link firms and sole proprietors across state lines. The EINs will also make it possible to reconcile the disciplinary referrals and audit records we receive from federal agencies with Board data for creating automated alerts and reports to boards such as firms that have received actions from federal agencies and firms that have filed audits, but aren’t registered.
You may already collect EIN for firms but not yet for sole proprietors. The AICPA is now requiring firms and sole proprietors to provide an EIN as part of peer review enrollment, so it should be seamless to request this data point from registered firms and sole proprietors if they are enrolled in the peer review program.
The addition of the peer review requirement data in the ALD feeds will help Boards with identifying if firms that are required to get a peer review are actually getting a peer review and within the proper time frame. Another advantage will be the ability to identify firms that are enrolled in the peer review program and should be registered with the Board, but are not. The current labor-intensive efforts required for tracking this information is creating a major gap in enforcement efforts since peer review is a requirement of firm licensure for firms conducting services that trigger a peer review requirement.
While this information can be deduced by searching the AICPA’s Facilitated State Board Access (FSBA) database that houses data on peer review, it currently requires a time consuming manual process for Board staff whose resources are limited.
To recap, here are the two data points that must be added to your ALD feed to make your Board eligible for NASBA’s future peer review compliance reports:
Checklist for Participation
None of the steps involved are difficult, but there are several. It’s best to just get started! You may be able to immediately check off one or all of these right away! We have begun this process with Montana and Mississippi and look forward to assisting you with your own addition.
NASBA staff would be pleased to discuss your Board’s specific situation and help design a custom game plan for your Board that is based on the steps outlined here. Please contact ALD Manager, Elizabeth Stanton, at 615-564-2143 or via email at firstname.lastname@example.org to get started.
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