AICPA PEER REVIEW PROGRAM
We are pleased to resume the publication of our AICPA Peer Review Program Newsletter, created to keep members informed of important technical developments, program requirements, and upcoming professional opportunities.
The extension concurrence of GAO is obtained by sending the letter of approval of the due date extension granted by the administering entity (AE) (in this case, the Colegio de CPA de PR) to GAO, at its email address: yellowbook@gao.gov. Once the firm receives from GAO its extension concurrence, the firm is to give the copy to its firm’s peer review team captain. It is the firm’s responsibility to comply with GAO standards.
EXTENSIONS GRANTED BY AE
• An AE will ordinarily approve a review due date extension of three months or less.
The Government Auditing Standards (GAO) 2018 Revision1, technical update of April 2021, requires in its paragraph 5.64 the following:
“In cases of unusual difficulty or hardship, extensions of the deadlines for submitting peer review reports exceeding 3 months beyond the due date may be granted by the entity that administers the peer review program with the concurrence of GAO.”
• Extensions requested for over 3 months after due date should have a particularly valid reason in order to be accepted. After evaluation, these extensions will be granted by the AE with the approval of the Peer Review Committee
• Extensions requested for over 6 months after due date should have an extraordinary reason and should be requested 60 days before the due date. After evaluation, these extensions will also
be granted by the AE with the approval of the Peer Review Committee.
• As a general note, it is important to consider that the extension requests must be requested before the due date, and once the scheduling is completed.
AICPA 2026
PEER REVIEW CONFERENCE
REGISTER for the 2026 Annual Peer Review Conference. It will be held from August 10-12, 2026 in Providence, Rhode Island at the Omni Providence Hotel. Join our Puerto Rico delegation by registering in the following link and enjoy the live presentations: http://26aicpa-peer.epwebsite.com
REPRESENTATION LETTER & CHECKLISTS
Team Captains & Member Firms: please remember the following:
• For peer reviews with years ending before December 15, 2025 you will be using the May 2025 representation letter & checklists.
• For peer reviews with years ending on or after December 31, 2025 you will be using the April 2026 representation letter & checklists.
Always remember to look for the applicable version of the checklists and letters based on the peer review year end!
GAO DOCUMENTATION CONSIDERATIONS WHEN INDEPENDENCE IS IMPAIRED
• It is very important to emphasize, for you as AICPA Peer Review Program members, the importance of documentation on working papers: “work not documented is work not done”.
PEER
On this edition, we will start with the required documentation when your external auditor’s independence is impaired with respect to an audited entity2:
• GAO 2018 and 2024 revisions, paragraph 3.107 has the following documentation requirements:
1. Threat
2. Safeguards
3. Management’s ability to oversee (SKE)
4. Understanding with audited entity
5. Evaluation of the significance of the threat
• GAO 2018 and GAO 2024 revisions, paragraph 3.48 provide examples of safeguards and relevant considerations for their proper handling and documentation:
1. Consulting an independent third party.
2. Involving another audit organization
3. Engaging an auditor not a member of the engagement team
• These requirements apply to all CPA firms, including sole practitioners (SP).
1GAO 2024 Revision applies for financial audits attestation engagements and reviews of F/S for periods beginning on or after 12-15-2025, and for performance audits beginning on or after 1215-2025. In this version, refer to paragraph 5.159.
2Please refer to GAO 2018 revision Technical Update April 2021 and GAO 2024 revision paragraphs from 3.48 through 3.108 for detailed information in these important matters.
Thank you for your continued commitment to quality and compliance; we look forward to sharing additional guidance and program updates in our next newsletter, scheduled for October 2026. See you soon!!
REVIEW TEAM INFORMATION
• Even though for Sole practitioners this can be more difficult to comply with, there are alternatives among which, for example, the SP can get in contact with other independent auditor(s) with the necessary competence to comply with these standards. María T. Laboy,
CPA on
(787) 667-7955 mlaboy@colegiocpa.com Alma J. Vélez Erba, CPA Technical Reviewer (787) 754-1950 (Ext. 238) ajvelez@colegiocpa.com
Vera Administrator (787) 754-1950 (Ext. 238) nvera@colegiocpa.com