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review of a work product is required prior to The likelihood of rogue activity decreases when
issuance, or identify monitoring mechanisms to a firm encourages open dialogue if engagement
help detect incomplete returns that the firm has teams encounter issues they need help resolving or
been engaged to prepare. if a firm member notes conduct that is inconsis-
Once such policies and procedures are es- tent with established policies. Consider activities
tablished, firmwide training about them is the that encourage collaboration. For example, when
next step and can help ensure that all partners laws or standards change, form a diverse working
and employees are focused on the importance group to examine guidance and develop a firm-
of practice risk mitigation. In addition, routine wide approach to implementation. Think about
communications around risk policies, in the form establishing a quality control champion within
of easily digestible “lessons learned” scenarios, are the firm who can provide guidance and insights as
a great way to educate firm members about things situations arise.
done right — and how easy it is for things to
go wrong. Incentivize good behavior
Consider a policy that encourages senior Positive reinforcement works for everyone, includ-
partners nearing retirement to work collaboratively ing CPAs. Compensation models should provide
with less-experienced partners during the client an incentive for good behavior, such as adherence
transition process to allow them to share the “risk to the firm’s quality procedures, in addition to
lessons” they’ve learned over time. meeting financial and other metrics. Spot bonus
programs can provide real-time rewards for those
Trust but verify — everyone is subject to who demonstrate quality-minded behaviors,
oversight such as collaborating with experts on a high-risk
President Ronald Reagan said it best — trust but engagement or asking for help with a diffi-
verify. Firms trust their partners and staff to un- cult situation.
derstand and follow the firm’s policies and proce-
dures. Nevertheless, a timely, well-run compliance FINAL THOUGHTS
or internal inspection program that periodically Practice risk management is everyone’s responsi-
reviews a selection of completed engagements for bility. Firm leadership sets the tone at the top and
compliance with the firm’s policies can help ensure leads by example. Consulting with one another
that quality control procedures are understood and and staff, following risk management protocols,
effectively implemented by engagement teams. and encouraging staff to value risk management
Firms should tailor compliance programs to their are all examples of how leadership can help
size and practice areas. The population from which prevent rogue behavior.
they select engagements for review should include
all service lines, as well as every partner or final Deborah K. Rood, CPA, is a risk control consulting
reviewer, and should occur on a regular basis, such director at CNA. For more information about this
as annually. Other considerations when selecting article, contact specialtyriskcontrol@cna.com. ■
engagements for a compliance review may include
those involving new services and those led by Continental Casualty Company, one of the CNA insurance companies, is
the underwriter of the AICPA Professional Liability Insurance Program.
recently promoted or onboarded partners.
Aon Insurance Services, the National Program Administrator for the
Results from compliance program inspections AICPA Professional Liability Program, is available at 800-221-3023 or
may identify a better way to accomplish a task, areas visit cpai.com.
This article provides information, rather than advice or opinion. It
where firm members are struggling to implement a
is accurate to the best of the author’s knowledge as of the article date. This ar-
specific policy, or areas where additional training is ticle should not be viewed as a substitute for recommendations of a retained
needed. Incorporate lessons learned from internal professional. Such consultation is recommended in applying this material in
any particular factual situations.
inspections into firm training.
Examples are for illustrative purposes only and not intended to
establish any standards of care, serve as legal advice, or acknowledge
Consulting isn’t just a CPA firm service any given factual situation is covered under any CNA insurance
Generally speaking, firms with consultative and policy. The relevant insurance policy provides actual terms, coverages,
amounts, conditions, and exclusions for an insured. All products and
collaborative cultures not only deliver better ser- services may not be available in all states and may be subject to change
vice but also are better equipped to mitigate risk. without notice.
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