EBPAQC Membership Requirements

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Membership Requirements Q & A

• Designate an audit partner to have firm-wide responsibility for the quality of the firm's ERISA employee benefit plan audit practice. (Effective at admission date.)
• Have all audit partners of the firm residing in the United States and eligible for AICPA membership be members of the AICPA.  (Effective at admission date.)
• Establish a program to ensure that all ERISA employee benefit plan audit engagement personnel possess current knowledge, appropriate to their level of involvement in the engagement, of applicable professional standards, rules and regulations for ERISA employee benefit plan audits. Such knowledge may be obtained from on-the-job training or training courses or both. For an individual signing audit opinions and an individual managing ERISA employee benefit plan audit engagements, the individual must complete a minimum of 8 hours of employee benefit plan-specific continuing professional education (CPE) within the three year period (or within the firm's or individual's most recent CPE period ending within the three year period) prior to signing an ERISA employee benefit plan audit opinion or managing an ERISA employee benefit plan audit engagement. Thereafter, the individual must have a minimum of 8 hours of employee benefit plan-specific CPE every three years (or within the firm's or individual's CPE period covering a three year period) where an individual continues in this capacity for ERISA employee benefit plan audits. (Program must be in place at admission; CPE requirement must be met in the firms or individual's first CPE cycle ending after admission date.)
• Require the audit partner designated with firm-wide responsibility for the quality of the firm's ERISA employee benefit plan audit practice to participate in an annual Center-sponsored Designated Partner planning webinar on recent developments in employee benefit plan auditing each year.  Participation may be on the live webinar, rebroadcasts, or archived webinar. (Effective upon admission. Designated Partners should view the annual Center webinar as soon as possible after the firm’s enrollment in the Center. However, if the firm joins after October 15, it is not necessary for the Designated Partner to view the previous annual Center webinar. The Designated partner would be required to meet this requirement for the first time in the subsequent year.)
• Establish policies and procedures specific to the firms ERISA employee benefit plan audit practice to comply with the applicable professional standards and Center membership requirements. These policies and procedures must be documented and appropriately communicated. (Effective at admission date.)
• In addition to meeting the quality control standards requirement for monitoring, establish annual internal inspection procedures that include a review of the firms ERISA employee benefit plan audit practice by individuals possessing current experience and knowledge of the accounting and auditing practices specific to ERISA employee benefit plan audits. The engagements inspected should be representative of the firms ERISA employee benefit plan practice considering the number and different types of plan audits (e.g.- defined benefit, defined contribution, health and welfare, multiemployer, ESOPs, limited and full scope) and the various locations at which those audits are performed. The internal inspection should include reviewing the firm's compliance with the Center membership requirements. The internal inspection reports specific to the ERISA engagements should be made available to the firm's peer reviewer. (Effective for firm monitoring performed beginning after admission date.)
• Make publicly available information about its most recently accepted peer review as determined by the Executive Committee which can be sent via email ebpaqc@aicpa.org or fax to 919-419-4772. (Effective at admission date.)
• Have its ERISA employee benefit plan audits selected as part of the firm's peer review reviewed by individuals employed by a Center member firm. (Effective for peer reviews commencing on or after admission date.)
• Periodically file with the Center information about the firm and its ERISA employee benefit plan audit practice, and agree to make such information available for public inspection, as determined by the Executive Committee. 
• Pay dues as established by the Executive Committee.

Comply with additional requirements as may be established by the Executive Committee and approved by the AICPA Board of Directors.  

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¹ An audit partner refers to an individual who is legally a partner, owner or shareholder in a CPA firm or a sole practitioner and who performs audit services, concurring reviews (if applicable) or consultations on technical or industry-specific issues with respect to audit clients of the firm. Such individual should be party to any partnership, ownership or shareholder agreement of a CPA firm.

² Member firms must use best efforts to ensure compliance with this membership requirement. Best efforts include (a) annually advising each audit partner that AICPA membership is mandatory; and (b) taking appropriate corrective action in the event that the firm detects non-compliance. In addition, while only audit partners residing in the United States and eligible for AICPA membership must be members of the AICPA, member firms must encourage all other firm professionals who are eligible for membership in the AICPA to enroll as an individual AICPA member.

³ Individuals managing the audit engagement are professional employees who have either continuing responsibility for the overall planning and supervision of the engagement or the authority to determine that an engagement is complete subject to final partner approval if required.

⁴ The Executive Committee has determined that Center member firms are required to make publicly available the following information, if applicable, relative to the firms peer review:

• Peer review report
• Letter of response, if applicable
• Letter signed by the reviewed firm indicating that the peer review documents have been accepted with the understanding that the firm agrees to take certain actions , if applicable
• Letter notifying the firm that certain required actions have been completed, if applicable, and 
• Letter notifying the firm that the peer review has been accepted

⁵ The Executive Committee has determined that Center member firms are required to file with the Center the following information:          

• Firm name and address
• Indicate whether the firm is a member of PCPS
• Name and contact information of the designated audit partner with firm-wide responsibility for the quality of the firms ERISA employee benefit plan audit practice
• Name and contact information of the firms designated Center contact administrator (if different from designated person above)
• Total number of CPAs in owner's group, CPAs in firm, professional staff, and firm personnel
• Approximate number of ERISA employee benefit plan audits (i.e.- 1-5, 6-25, 26-50, 51-100,101-500, over 500)