Firms / ATOs
Frequently Asked Questions
Frequently Asked Questions
The following questions and answers address specific matters relating to the completion of the Planning Questionnaire (or Declaration for Exemption, if appropriate), as well as other commonly raised Practice Inspection matters.
FAQ#1 - Is my office subject to Practice Inspection?
All members and offices engaged in the practice of public accounting or in providing accounting services to the public are subject to practice inspection. All engagements addressed by the standards in the CPA Canada Handbook - Assurance are within the scope of the Practice Inspection program. At a minimum, assurance (audit and review) and compilation engagements are subject to practice inspection. FAQ #3 and FAQ #4 below address services which, while performed by many offices, do not fall under the scope of Practice Inspection. Offices involved in only the preparation of tax returns, or the schedules accompanying them, e.g. government-prescribed schedules of income and expenses, would NOT be subject to Practice Inspection; however, if notice to reader communications are prepared in tandem with such returns, the office would be subject to Practice Inspection.
A member may be exempt from Practice Inspection; please refer to Regulation 10-1, section 3 for details of the circumstances in which an exemption may be permissible. If there is still uncertainty with respect to whether the office is subject to inspection after receipt of a selection letter, please send your specific questions by e-mail to email@example.com, using the subject line "Questions re: exemption from inspection". All questions must be submitted in writing and all responses will be provided in writing.
FAQ #2 – Why was my office selected for Practice Inspection this year?
Our authority to maintain a Practice Inspection program is mandated under The Chartered Accountants Act, 2010, Bylaw 10 and Regulation 10-1. The frequency of an office’s selection for Practice Inspection is set out in Regulation 10-1, paragraphs 4 to 9. Generally, an office would be inspected not more than three years from the date of its previous inspection year (including inspections carried out by all legacy bodies); this timeline will vary based on the circumstances set out in the Regulation. An office will be advised of the year of its next inspection in its most recent practice inspection decision letter.
An office that has undergone reinspection, and which now meets the requirements of Practice Inspection as a result of that reinspection, will undergo its next inspection:
FAQ #3 - I perform bookkeeping/accounting/management services. Are these services subject to Practice Inspection?
No, they are not. Only engagements covered by professional standards as set out in the CPA Canada Handbook – Assurance, i.e., Canadian Standards on Quality Control (CSQC 1), Canadian Auditing Standards, and Other Canadian Standards (including review and compilation engagements) are subject to inspection.
If you are uncertain as to whether any of your engagements are subject to inspection, please email firstname.lastname@example.org, using the subject line “Questions re: exemption from inspection”, and include your inspection number and details of your situation. All questions must be submitted in writing and all responses will be provided in writing.
FAQ #4 - My practice includes the preparation of working papers (on a per diem basis) for other offices, with respect to assurance and/or compilation engagements performed by them. These are not my clients; I am not the engagement partner responsible for the issuance of any reports/communications for these engagements. Are such per diem services subject to inspection in my practice?
No, they are not. The performance of per diem services for other offices is not subject to inspection for your office. However, if there is any work performed for clients of your own office, then those files are potentially subject to inspection.
If you require further clarification, please email email@example.com, using the subject line “Questions re: exemption from inspection”, and include your inspection number and details of your situation. All questions must be submitted in writing and all responses will be provided in writing.
FAQ #5 – My Professional Corporation was selected for inspection. Am I subject to Practice Inspection?
If you are engaged in the practice of public accounting or in providing accounting services to the public under the name of the professional corporation, then you would be subject to Practice Inspection.
If you are a shareholder of a professional corporation whose sole purpose is to hold your interest in another public accounting practice, AND you perform no public accounting services under the name of the professional corporation itself, your professional corporation may qualify for an exemption. Any public accounting services you perform under the name of the other public accounting practice, the interest in which is held in your professional corporation, would be subject to inspection in such other practice. Please email firstname.lastname@example.org, using the subject line “Questions re: exemption from inspection”, and include your inspection number and details of your situation. All questions must be submitted in writing and all responses will be provided in writing.
FAQ #6 - How do I change who can access the planning questionnaire?
The only person with access to the planning questionnaire is the office’s designated Practice Inspection (PI) Contact. This is the individual to whom all correspondence in connection with the inspection will be addressed. This person must be a member of CPA Ontario.
In order to change the PI Contact, one of the office’s designated contacts must log in to the Update Profile - Firm andmake the appropriate change to the records. If any other changes are required to the firm’s information, such as a change in address, it should be done through here. The following people are considered to be the office’s designated contacts:
FAQ#7 - Our firm has multiple offices selected for inspection. Do we need to fill out a separate Planning Questionnaire for each office? If so, why and how do we do this?
Yes. As each office is assigned a unique PI number, we require separate information for each office selected.
We understand that some multi-office firms group their various locations into “business units”, which may create difficulty in splitting out the information between the offices selected for inspection. Practice Inspection considers each office’s roster of staff and partners as set out in the Member Listing generated from our membership database; those engagement partners who are included on a particular office’s roster are inspected as part of that office. An engagement partner who issues reports from multiple offices in the firm would only be included on one office’s roster.
If a particular office has not been included in the current year’s selection, but is part of a business unit which has other offices selected for inspection in the current year, please contact the coordinator named in your selection letter.
FAQ #8 – If my firm’s PI Contact and/or address changes AFTER submission of the planning questionnaire, what should I do?
Please follow the procedure as set out in FAQ #6 above. Please also contact the coordinator named in your selection letter, so that the information for your inspection can be updated on a timely basis.
FAQ #9 – What should I do if I can’t meet the deadline(s) to submit the requested forms or files to Practice Inspection? What happens if I do not respond to correspondence sent by Practice Inspection?
If a firm is unable to meet the deadlines set out in the correspondence, the coordinator assigned to handle the inspection must be contacted as soon as possible (the name, telephone number and e-mail address of the coordinator will be provided in the selection letter) to discuss the possibility of extending the deadline. In accordance with Rule of Professional Conduct 104.2 and Regulation 10-1, Section 48, failure to respond to any Practice Inspection request to submit information, client files or other documentation will result in immediate referral to the Registrar for suspension.
FAQ #10 - What dates do I need to include in our inspection blackout period?
Apart from Federal and Ontario statutory holidays, all other dates, including religious holidays, should be included in the blackout period if your inspection cannot be scheduled during those dates. For example, if your firm experiences peak workloads during May and June, consider whether any weeks in those months should be included in your blackout period. The inspection blackout period cannot exceed a total of eight (8) weeks. If no blackout dates are indicated, we will schedule the inspection on that basis. Once scheduled, the inspection dates are considered firm.
FAQ #11 - How flexible is my inspection date?
Due to the high volume of inspections, we have very limited flexibility in changing inspection dates. Once an inspection date is assigned, it is considered firm and may only be changed in exceptional circumstances, with the approval of the director of practice inspection. An exceptional circumstance does NOT include excessive workload or vacation schedules. If such circumstances are anticipated, these dates should be included in the firm’s blackout period (see FAQ #10).
FAQ #12 - Who is considered an engagement partner?
The role of the “engagement partner”, as it relates to audit and review engagements, is defined in the Canadian Standards on Quality Control (CSQC-1), in the CPA Canada Handbook – Assurance. Additional guidance for audits is available in CAS 220, Quality Control for an Audit of Financial Statements.
FAQ #13 - What is the difference between an office visit and a desk inspection?
A visit inspection is performed onsite at the office’s premises. This is normally for practices with two or more partners where assurance engagements are performed.
A desk inspection is performed offsite. CPA Ontario requests submission of a sample of files and other information upfront. This is normally for sole practitioners with a limited number of assurance engagements, or where the office performs only compilation engagements. Files are selected from the client listing submitted with the planning questionnaire, and are subsequently sent to the inspector for review.
FAQ #14 - Who needs to be available during the inspection?
Office visit: The PI Contact (or another appropriate representative for the office) should be available for a meeting at the conclusion of the inspection to discuss the draft practice inspection report. Prior to the inspection, the PI Contact should discuss with the inspector the process for the selection of files and other information that the inspector will require at the start of the visit. It is not necessary that the PI Contact be present throughout the inspection.
For multi-partner offices, it is not necessary for all partners to be available for the inspection.
Desk inspection: The inspector will attempt to arrange a time (within three weeks of the assigned inspection date) with the PI Contact to discuss the draft practice inspection report by phone.
FAQ #15 - Should I request a preference for a full-time or a part-time inspector (visit inspections only)?
A part-time practice inspector is a member in good standing, currently or recently in public practice, who has been contracted and trained by us to perform inspections. A full-time practice inspector is a member in good standing, formerly in public practice, employed by us on a full-time basis to perform inspections. Regardless of whether an inspector is full- or part-time, a practice is assessed based on the standards in the CPA Canada Handbook using the same inspection tools and methodology.
In the Planning Questionnaire for offices which will undergo a visit inspection, you may indicate a preference (or no preference) for a full- or part-time inspector; desk inspections are assigned, with very few exceptions, to part-time inspectors. While we will attempt to accommodate your preference with respect to the type of inspector assigned, the practice inspection office reserves the right to determine inspector assignment.
FAQ #16 - For a desk inspection, can I submit my files electronically?
As an alternative to submitting paper files for a desk inspection, CaseWare and PDF files may be submitted to the practice inspection office either by uploading a copy of your files to a secure portal (available only for “compilation only” inspections) or on a USB key (for all desk inspections). If certain elements of file documentation are maintained separately from the electronic file, e.g. an engagement letter kept in a permanent file, they should be scanned and included in your electronic submission. Our written communication advising the office of its inspection date will set out the documentation required and the options available for submitting it.
FAQ #17 – I have concerns about the inspector who has been assigned to perform my inspection. What should I do?
You must contact your coordinator, in writing, within seven (7) days after you have received the letter indicating your inspection date and name of inspector assigned. In that email, you must outline your concern with respect to the assignment of that inspector (e.g., independence, potential conflict of interest, proximity of inspector’s practice to your own, etc.).
FAQ #18 – How are the specific engagement files selected for inspection?
The inspector determines the number and type of current engagements which will be subject to inspection, after giving due consideration to the quality controls of the office, the number of engagement partners, and the risk profile of the client engagements.
The number and identification of specific engagements subject to inspection shall be selected solely by the inspector and not by the office (Regulation 10-1, paragraph 19).
FAQ #19 - What do we need to do to satisfy the requirements of Practice Inspection?
Practice Inspection assesses whether offices are compliant with professional standards as set out in the CPA Canada Handbook and CPA Ontario’s bylaws, regulations and the CPA Code of Professional Conduct. When deficiencies raised on an inspection, individually or cumulatively, indicate a serious departure from standards, the Practice Inspection Committee may determine that a firm has not met the requirements of Practice Inspection. For the more common deficiencies encountered on past practice inspections, please refer to our Focus on Practice Inspection Reportable Deficiencies communication.
FAQ #20 - What is the difference between an annual monitoring and a cyclical inspection?
If assurance engagements are performed (i.e., audits or reviews, or any other assurance engagements as set out in the CPA Canada Handbook – Assurance), CSQC 1 requires the establishment of policies to document and maintain a system of quality control and to establish procedures necessary to implement and monitor compliance with those policies, regardless of the size of the office or the number of assurance engagements performed.
As part of monitoring compliance, CSQC 1 requires both an annual monitoring and cyclical inspection be performed for assurance engagements:
Annual monitoring of the quality control system – includes an ongoing consideration and evaluation of the design and implementation of the quality control system in order to determine that it is relevant, adequate and operating effectively. (CSQC 1, paragraphs 48 and A64-A68)
Cyclical inspection of completed assurance engagements – includes a periodic (cyclical) inspection of at least one completed assurance engagement for each engagement partner (refer to FAQ #12). For example, the policy may specify a cycle that spans three years.
The cyclical inspection must be completed by an individual independent of the specific engagement. In particular, the engagement partner or any individual involved in either the performance of the engagement or its engagement quality control review (if applicable), cannot monitor the completed assurance engagement. Further, neither CPA Ontario’s practice inspections nor second partner pre-issuance review is a substitute for the periodic inspection of completed assurance engagements. (CSQC 1, paragraphs 48 and A64-A68)
FAQ #21 - Do we need to keep the documentation of the results of the annual monitoring and/or the cyclical inspection?
Yes – evidence that monitoring has been completed must be documented and retained. That documentation should include:
(CSQC 1 paragraphs 50, 53-54, 57-58 and A73-A75)
The Sample Quality Assurance Manual, available from CPA Canada's knotia.ca online store, provides templates for documenting both the annual monitoring and cyclical inspections.
FAQ #22 - What if I disagree with the contents of the draft inspection report?
As part of your response to the draft report, please include documentation (such as copies of working papers) that supports your position. It will be reviewed by Practice Inspection staff during the detail review process, where changes may be made if deemed appropriate.
FAQ #23 - When and how is the final outcome of the inspection communicated? Will the inspector tell us?
The role of the inspectors is to be “information-gatherers” on behalf of the Practice Inspection Committee; accordingly, they cannot tell you the final outcome of the inspection, as that determination is subsequently made by the Practice Inspection Committee. However, the inspector will discuss the reportable deficiencies identified during the course of the inspection with you, in keeping with the educational component of the process. You will then have a period of three weeks to submit a written response to the draft reportable deficiencies raised.
The Practice Inspection Committee’s decision concerning an inspection will be communicated to the practice in writing by the director of practice inspection once the committee has reviewed the inspection file. We make every effort to complete the process and communicate the decision within a reasonable timeframe, normally not exceeding three to four months.
FAQ #24 - How much will a practice inspection cost?
The cost of an inspection is dependent upon number of variables, such as the size of the office, and the number and types of files being inspected. There are three components to the practice inspection fee: the inspector’s time charge for the inspection, the detailed review of the inspection file and an administrative fee. The practice inspection rate is reviewed and approved by Council annually; the approved rate for the 2016-2017 year is $205 per hour.
FAQ #25 - What is the purpose of the Practice Inspection Review - Public Accounting Experience form?
The Public Accounting Experience form is collected on behalf of the Public Accounting Licensing Board (see CPA Ontario Regulation 9-1, sections 24-42) as part of the monitoring of members’ compliance with public accounting licensure requirements in Ontario. CPA Ontario is authorized to issue public accounting licences to our eligible members on behalf of the Public Accountants Council for the Province of Ontario. Depending on the number of members holding a public accounting licence at the time of an office’s practice inspection, some or all of them will be required to complete this form.
Care should be taken to ensure that all information requested in the form is provided, including your practice inspection number, CPA Ontario member number, Public Accounting licence number, and the expiry date of the Public Accounting licence. Please note that the hours required in the bottom section of the form are only for the twelve month period ending on the date indicated in the form. Assurance hours include work performed on audit and review engagements in your own practice (or your employer’s practice), as well as work performed on a per diem basis for any accounting practice other than your own or your employer’s. Compilation engagement hours include those obtained on engagements to which the prescribed Notice to Reader communication is appended (i.e., as set out in CPA Canada Handbook – Assurance 9200) and, as with assurance hours, include work performed for your own firm, or for others on a per diem basis.
FAQ #26 - Does an office need to be inspected under the CPA Ontario program to be considered for student training approval, and does the outcome of the inspection impact such approval?
Information is available from our Employer Relations department with respect to obtaining a student training approval either in External Audit or Outside of External Audit. Please note that Practice Inspection is no longer involved in the granting or ongoing oversight of student training approvals in External Audit; those roles are now fulfilled by Employer Relations.