The New York State Society of CPAs is recommending approval of a change in New York State regulations that would establish a mandatory quality review program for public accountants.

The NYSSCPA has been recommending a mandatory quality review program for CPAs for about five years. The proposed regulations and a recent change in the Empire State’s laws reflect many of the society’s suggestions.

NYSSCPA president Margaret Wood sent a few suggested changes to the proposed regulations in a letter Tuesday to Daniel Dustin of the New York State Board for Public Accountancy, including removing “any ambiguity regarding when a firm is deemed to begin providing attest services.” 

She noted that a firm might be deemed to begin providing attest services upon the signing of the engagement letter, or when a firm begins actually scheduling and planning its services, or at some other point, such as the commencement of field work.

The exact date is important because firms are supposed to have a quality review conducted within 18 months of the date when attest services are first provided. Any wiggle room there, and nobody would know exactly when to start the quality reviews. Wood also pointed out that the AICPA has its own peer review requirements, and there could be some ambiguity over when a review is “conducted” or “completed.” Ah, technicalities, technicalities.