What is Peer Review and Why Is It Important

Organizations and individuals around the country rely on audit reports issued by CPA firms. When a CPA firm signs an audit report, they are certifying that they have done what is required by generally accepted auditing standards in order to issue that report.

But who checks up on the CPA firm to make sure they did what they were supposed to do? That is where the AICPA Peer Review Program enters the picture.

CPA firms enrolled in the AICPA Peer Review Program are required to have a peer review of their accounting and auditing practice once every three years.

Peer review provides a mechanism for a firm to engage a peer firm to review its system of quality control related to its application of professional accounting, auditing and attestation standards. This process strengthens a firm's quality control and encourages firms to improve processes and to correct any flaws in their system.

Firms have peer reviews because of the public interest in the quality of services provided by public accounting firms. Additionally, most state boards of accountancy require its licensees to undergo peer review to practice in their state.

Peer Reviews involve many organizations, including:

At the conclusion of a peer review, a report is issued. Firms can receive a rating of pass, pass with deficiency(ies), or fail. Novak Francella has received pass ratings in all peer reviews since our inception.

The AICPA Peer Review Program plays a crucial role in maintaining the integrity and quality of CPA services. For clients, it provides peace of mind and assurance that their chosen CPA firm meets rigorous professional standards.

PBGC Premium Filing Due Date Change for 2025 Plan Years

PBGC Premium Filing Due Date Change for 2025 Plan Years - premiums are due one month earlier than usual

On January 6, 2025, the Pension Benefit Guaranty Corporation (PBGC) issued Technical Update 25-1, providing important guidance to sponsors of PBGC-covered1 single-employer and multiemployer defined benefit (DB) plans regarding the change in the timing of PBGC premiums for the 2025 premium payment year.

New premium due date: For the 2025 plan year only, PBGC premiums are due on the 15th day of the ninth month of the premium payment year, which is one month earlier than the usual timeline. For calendar-year plans, the due date will be September 15, 2025, instead of the usual October 15, 2025.
Temporary adjustment: This accelerated timeline is specific to the 2025 plan year. The premium due date will revert to its normal schedule in 2026.

Section 502 of the Bipartisan Budget Act of 2015 (BBA 2015) mandated this acceleration.

Premium filing due dates for the 2025 plan year

Below are the revised premium filing due dates for the 2025 plan year:

Date Plan Year Begins Due Date
1/1/2025 9/15/2025
1/2/2025 - 2/1/2025 10/15/2025
2/2/2025 - 3/1/2025 11/17/2025*
3/2/2025 - 4/1/2025 12/15/2025
4/2/2025 - 5/1/2025 1/15/2026
5/2/2025 - 6/1/2025 2/17/2026*
6/2/2025 - 7/1/2025 3/16/2026*
7/2/2025 - 8/1/2025 4/15/2026
8/2/2025 - 9/1/2025 5/15/2026
9/2/2025 - 10/1/2025 6/15/2026
10/2/2025 - 11/1/2025 7/15/2026
11/2/2025 - 12/1/2025 8/17/2026
12/2/2025 - 12/31/2025 9/15/2026
*The 15th day of ninth month beginning on or after the first day of the plan year falls on a weekend or federal holiday.

The premium due date may be different than shown above for new plans, plans that are newly covered by the PBGC, terminated plans whose assets were fully distributed during the year, plans with a changed plan year, or plans affected by disasters.

Possible repeal of the accelerated due date

The President’s Budget has called for the repeal of the accelerated premium due date for the last eight years, noting the additional costs and burdens it places on plan sponsors. As a result, it is possible that this provision could be repealed during the 2025 federal fiscal year (October 1, 2024 – September 30, 2025). We will continue to monitor developments and inform you of any changes.

IRS Announces New Pilot “Pre-Audit” Compliance Program for Retirement Plans

On June 3, 2022, the IRS announced a new pilot pre-examination compliance program for retirement plans beginning in June 2022.  Under the new program, the IRS will send letters to plans advising them that they have been selected for an examination and will have a 90-day window to self-review the plan’s documentation and operation to determine if they meet current tax law requirements. If the plan does not respond within 90-days, the IRS will audit the plan. If self-review reveals non-compliance, the plans will be able to self-correct the mistakes using the correction principles in the IRS voluntary compliance program (EPCRS).  

EPCRS’s self-correction program will be available. If a mistake cannot be self-corrected, an IRS closing agreement under EPCRS will be available based on the voluntary compliance program (VCP) fees rather than the normal closing agreement fees.

If the plan does respond within 90 days, the IRS will review the submitted documentation, determine whether it agrees and enter into a closing agreement. If the IRS does not fully agree that appropriate corrections have been made, the IRS will conduct either a limited or full scope examination.

The IRS views the program as a way to reduce the taxpayer burden and the amount of time that the IRS spends on examinations. To date, the IRS has just issued an announcement of the pilot program but not provided full details.

For questions or more information in how this program may affect your plan, please contact us here. 

 Full IRS Announcement:  https://www.irs.gov/retirement-plans/employee-plans-news

IRS Employee Plans Compliance Resolution System (EPCRS):  https://www.irs.gov/retirement-plans/employee-plans-news

IRS Voluntary Correction Program Fees:  https://www.irs.gov/retirement-plans/voluntary-correction-program-fees

American Rescue Plan Act - Information for Labor Unions and Benefit Funds

On March 11, 2021 the American Rescue Plan Act became law. It makes important changes to relief available for Labor Unions and Benefit Funds.

Please see our bulletin for additional information.

ARPA Bulletin

DOL Form T-1

Update: The OLMS will not seek to enforce the filing of the Form T-1 for one year from the original due date.

Office of Labor-Management Standards (OLMS) published a final rule on May 30, 2019 establishing a Form T–1 Trust Annual Report which requires annual reporting by Form LM-2 filing labor organizations on financial information pertinent to “trusts in which a labor organization is interested”.


On March 29, 2021, the Office of Labor-Management Standards (OLMS) released News 01-2021 – Notice of a non-enforcement policy in connection with an intended rulemaking to rescind the Form T-1 Trust Annual Report.

Follow this link for our client bulletin:

Non-enforcement Policy

Bulletin

Please contact us for additional information

DOL proposes changes to Form LM-2

The Office of Labor-Management Standards (OLMS) Department of Labor (DOL) is expected to publish a Notice of Proposed Rulemaking (NPRM) to modify the existing Form LM-2 and to establish a LM-2 Long Form (LM-2 LF).

Please follow this link for our client bulletin:

Bulletin

Copies of the draft LM-2 and LM-2 Long Form can be accessed by following these links:

Draft - LM-2

Draft - LM-2 Long Form

Please contact us for additional information

CARES and Families First Payroll Protection Acts - information for Benefit Funds and Labor Unions

The Coronavirus Aid, Relief, and Economic Security (CARES)
Act and the Families First Coronavirus Response Act both provide potential
relief for nonprofit associations.
We are still awaiting important details on the many
provisions of the Acts, but we wanted to provide a summary of some of the programs
which will be of interest to our clients.  We will update our materials as
additional information becomes available.

We have provided sections below specific to your client type. Please check back to this page periodically for updates and further information.

Relief available to clients from these Acts

Labor Unions
       Eligible for:
       Employee Retention Tax Credit
       EIDL Loan or Advance

      Employee Retention Tax Credit (for Unions)
      How these programs interact with each other
      SBA Payroll Protection Program and Economic Injury Disaster Loans
      Tax filing extensions

Welfare and Pension Plans
       Eligible for:
       Employee Retention Tax Credit
       EIDL Loan or Advance

       Note: If the benefit funds utilize a TPA there is a chance
       that a Payroll Protection Loan would be available to the TPA.

       Employee Retention Tax Credit (Welfare and Pension Plans)
       How these programs interact with each other
       SBA Payroll Protection Program and Economic Injury Disaster Loans
       Tax filing extensions

501(c)(3) entities (such as training funds)
       Eligible for:
       Payroll Protection Program Loan
       EIDL Loan or Advance

       Information on Payroll Protection Program
       SBA Payroll Protection Program and Economic Injury Disaster Loans
       Tax filing extensions

Annuity and Defined Contribution Plans
       Withdrawal changes for annuity and DC plans
       Tax filing extensions

We're Open for Business

Our
firm has been deemed “Life Sustaining” which allows us to remain open. Please see our bulletin regarding our ongoing operations:


We're Open for Business


CARES and Family First Acts provide potential relief for Unions

The Coronavirus Aid, Relief, and Economic Security (CARES) Act and the Families First Coronavirus Response Act both provide potential relief for nonprofit associations.

We are still awaiting important details on the many provisions of the Acts, but we wanted to provide a summary of some of the programs which will be of interest to our Union clients. We will update this bulletin as additional information becomes available.

Update for Union Clients

IRS Extends Filing Deadline

The Treasury Department and the Internal Revenue Service has provided
special tax filing and payment relief to individuals and businesses in response
to the COVID-19 Outbreak, by extending the 2019 tax filing deadline from April
15, 2020 to July 15, 2020. Please see our bulletin below for more information: 

Bulletin