practice monitoring desktop review

practice monitoring desktop review

INTRODUCTION This leaflet explains your forthcoming Practice Monitoring Desktop Review. If you have any queries or concerns, please do not hesitate to discuss them with the Practice Monitoring Reviewer assigned to your review, or if you prefer you can contact the Visit Coordinator on 0131 347 0284. WHAT IS PRACTICE MONITORING? Upholding standards is one of the main objectives of ICAS and Practice Monitoring is devoted to achieving this mission. The ICAS Practice Monitoring regime has been designed to support the work of our Practising Certificate holders by reassuring the public and other regulators that our firms are complying with regulatory requirements. The Practice Monitoring function monitors all areas of accountancy practice, except for audit and insolvency which are dealt with by different teams in the Regulatory Monitoring department. The predecessor to Practice Monitoring was Quality Review, which was first introduced in January 2000 following a vote by the Members of ICAS. In 2014, the programme was redesigned and redeveloped to try to reduce the regulatory burden for Members and to streamline the review process to minimise disruption for firms. The goals of Practice Monitoring are: maintenance and enhancement of standards within accountancy practice; and helping and educating Members to achieve this. For further information please refer to the Practice Monitoring section of the ICAS website (icas.org.uk/regulation-and-ethics/practice-monitoring). In addition, we have set up a new dedicated practice area of the website called Practice Hub (icas. org.uk/ca/practice-hub/) which will sign post you to all the information you need as PC holders. This will now be your one stop shop for practice information. WHY HAVE YOU BEEN SELECTED FOR A DESKTOP REVIEW? Whilst Members feedback on Quality Review visits has been very positive, we have introduced a new monitoring approach called Practice Monitoring, which is aimed at keeping the valued aspects of Quality Review but reducing the disruption to firms. Under the Quality Review regime every firm received the same style of onsite visit on a cyclical basis. However under the Practice Monitoring regime, there are three separate delivery methods, dependent on the size and nature of your firm: telephone reviews; desktop reviews; and face to face visits. 1

Based on the information held, a desktop review would appear to most suit your circumstances. However, if you would prefer a face to face visit rather than a desk top review, you can discuss this with the Practice Monitoring Reviewer assigned to your review, or you can contact the Visit Coordinator on 0131 347 0284. Please note that all requests must be made within 10 business days of the notification letter. WHO WILL CONDUCT THE REVIEW? The Practice Monitoring team consists of qualified Chartered Accountants who are employed by ICAS and have extensive experience gained in all areas of general practice, including taxation, accounting for owner managed businesses, charity accounting, audit, and corporate finance. Additionally, as a number of Practising Certificate holders are often peripatetic directors, we have reviewers who have experience of work outwith traditional practice too. Brief biographies of the team members can be found on the Practice Monitoring section of the ICAS website (icas.org.uk/regulation-and-ethics/practice-monitoring). WHAT INFORMATION HAS BEEN SENT TO YOU? With this booklet, you should have received: a desktop notification letter; and information request list. The desktop notification letter will tell you when and how we plan to carry out the review and the name of the reviewer. The information request list sets out what should be sent to ICAS prior to the review. It is very important that this information is provided to ICAS by the deadline stated in the notification letter. The reviewer will be happy to answer any queries you have in compiling this information. Please contact the Visit Coordinator on 0131 347 0284, or the reviewer to discuss the most appropriate method of sending the requested information to ICAS. You will usually be given at least six weeks notice of the review. WHAT DO I DO IF THE DATE, TYPE OF REVIEW, OR REVIEWER IS UNSUITABLE? Please notify the Visit Coordinator (contact details above) within ten business days of the date of the notification letter if you have any objections to the date of the review, the type of review, or the named Reviewer. Provided the grounds for objection are reasonable the review will be rearranged. 2

THE DESKTOP REVIEW: WHEN AND WHAT TO EXPECT? The desktop review will be conducted by the reviewer offsite. As noted above, the information request list will be provided with the notification letter and you will be asked to submit copy information to ICAS at least two weeks before the date of the scheduled review. The reviewer will consider whether the firm has appropriate policies and procedures in place, and will look at your various information submissions to ascertain if they provide evidence of these policies. The tests will vary depending on the systems but will generally include the following: structure of files, standard documentation, permanent information etc; review of CPD Records; adherence with the ICAS Code of Ethics, Standards, Rules, Regulations and best practice guidance; practice management as it relates to clients money, money laundering, professional conduct, procedures for accepting new clients, disengagement procedures, bank accounts information etc; and fee notes, commission statements, PII renewal documentation. Some of the above areas are best covered by looking at a current assignment of your firm. This is why you will be asked to submit a recently completed engagement to ICAS in advance of the review. Prior to drafting the review report the reviewer will discuss the outcome of the review and any queries arising by telephone with you. This call will also give you the opportunity to ask any questions you might have, and the reviewer will be happy to discuss any aspect of your practice and provide any advice you may need. THE REPORT: WHAT TO EXPECT? The reviewer will prepare a draft report which will contain an overall assessment of your firm along with the review findings that require corrective action. The reviewer will e-mail you a copy of the draft report, which should reflect the discussions you had by telephone. If you have any queries on receipt of the report, your reviewer will be happy to discuss these with you. The report will identify any breaches of law or any regulations, standards or binding guidance which may require to be reported to the appropriate authority. Any significant breaches of Clients Money Regulations, Anti-Money Laundering Regulations or Designated Professional Body rules may require immediate reporting to the appropriate authority, depending on their nature Once you have received the draft report, you will be asked to respond to the points which have been raised. Your responses should acknowledge the matter, and note what action will be taken to remedy the issue on a timely basis. When these have 3

been completed the report will go through an internal quality control process to ensure firms are being treated consistently. If the final report differs materially from the draft report discussed with you, the differences will be identified and further discussed. The final report should be received within six weeks of the review date. In the unlikely event that agreement cannot be reached on the final report, you will be invited to state the reasons for disagreement in writing and this will be submitted to the Public Practice Committee with the report for consideration. At the end of the process, you will have a report that gives an overall assessment of the firm, a commentary on those areas performed well and a record of findings arising from the review. AFTER THE REVIEW As a result of the review, you may be asked to take appropriate follow up action to the findings raised during the review. The report will state clearly: which, if any findings require submission of evidence of follow up action; and the timescale for submission to the reviewer. Checking of follow up action will be conducted by the reviewer and they will endeavour to do this in as constructive a way as possible for your firm. We do ask that you provide your submissions within the deadline set out in the desk top review report. Once the reviewer has assessed your submissions, they will refer the assessment and submissions to the Public Practice Committee ( the PPC ), which will decide whether the review has been satisfactorily concluded. You will be informed, via letter, of the outcome of the Committee s consideration and whether the matter is cleared or whether further action is needed. If further action is needed, the Public Practice Committee will ask you to send in further submissions. This will continue until either the matters are considered closed or the Public Practice Committee considers additional regulatory action to be appropriate (for example, a face to face visit, or referral to the Investigations Committee). If at any time you disagree with the reviewer s assessment of the need for follow up action or the adequacy of action taken, then this will be considered in the first instance by the Assistant Director, Audit and Practice Monitoring. Failure to reach agreement would result in the matter being considered by the Public Practice Committee. The Public Practice Committee will consider the matter and determine an appropriate course of action which may include: Impose conditions/restrictions on an existing PC; and Withdraw or suspend a PC. In such a circumstance, the PPC will inform you that it is minded to take the 4

particular course of action and will provide full supporting reasons. You would then have 10 working days to decide whether to challenge the intended decision. If no challenge is made by the end of the 10-day period, the PPC s proposed decision will automatically come into force. If a challenge is submitted, the PPC will set up a quorum of its Members to conduct a hearing. The hearing is your opportunity to make representations as to why the proposed decision is unnecessary or inappropriate. After the hearing, the PPC will confirm its decision to you: it may implement its proposed decision, or else vary or withdraw it. If you are unhappy with the outcome, a right of appeal is available to the ICAS Appeal Panel, which is independent of PPC. Full details of the process are set out in the Public Practice Regulations. FEEDBACK With your final report you will receive a desk top review feedback form and this is your chance to comment on the desktop process. Completion is voluntary but your views are valued and could influence how the process operates in the future. If you have any serious concerns about the review process that cannot wait until the completion of the review, please call the Assistant Director, Audit and Practice Monitoring on 0131 347 0284. CONFIDENTIALITY No member of the Practice Monitoring team may make use of or disclose, the contents of any Practice Monitoring report, file, any working paper file, document, other material reviewed, any confidential information concerning the affairs of any firm or of their clients obtained during the course of a desk top review, except where appropriate to the Public Practice Committee. A copy of the final report will be retained on the firm s file in ICAS. ANY QUESTIONS? If you have any queries, please ask. Practice Monitoring staff can be contacted on 0131 347 0284 and they will try to help you as much as they can. Your reviewer s telephone number is included in the review notification letter. FURTHER MEMBER SUPPORT? As highlighted earlier, ICAS provides a one stop shop for practitioners looking for information. The Practice Hub can be found here icas.org.uk/ca/practice-hub/, and this provides a wealth of information and links to regulatory, technical and other matters affecting your practice. 5

CA House 21 Haymarket Yards Edinburgh EH12 5BH auditandpracticemonitoring@icas.org.uk +44 (0)131 347 0284 icas.org.uk