AICPA PEEC Proposes Independence Rule for "Staff Augmentation" Arrangements

On December 7, 2018, the AICPA Professional Ethics Executive Committee (PEEC) issued a new proposed interpretation under the Independence Rule that would address a nonattest service called "staff augmentation arrangements".

What is staff augmentation? 

As proposed, staff augmentation is a nonattest service in which the audit firm lends staff to the client to perform certain activities. The proposed interpretation acknowledges that staff augmentation may create self-review or management participation threats to independence but also suggests there are certain "safeguards" that may mitigate the threats and allow the service. Those safeguards are: 

  • The engagement lasts for a short period of time.
  • Client management designates someone with suitable skill, knowledge and experience who is responsible for setting the scope of the activities the firm's staff will perform, will supervise the staff's activities, and evaluate the adequacy and results of the services.
  • The firm's staff do not perform any management responsibilities (e.g. make decisions or judgments for management, approve transactions, etc.) and do not perform services prohibited under the Independence rule.

What primary considerations were addressed in this interpretation? 

The appearance of the firm's independence is a primary consideration. Factors the PEEC provided for a member to consider are: 

  • is the engagement is discrete or recurring in nature? 
  • if recurring, how frequent are the engagements? 
  • what is the duration of the engagement? 
  • did staff provide services exclusively for the client, or does he/she also serve other clients? 
  • how frequently does staff perform its activities at the client (e.g. daily, monthly)? 

Certain situations would impair independence, according to the proposal: 

  • Staff listed in employee directory or other client publications
  • Staff referred to by title or otherwise as being "in charge"
  • Staff identified as employee in email or other internal communications
  • Staff participates in client's employee benefit plans

The interpretation would require members to evaluate the significance of any threats. If a member concludes that threats are significant, the proposal suggests (but does not require) the following possible safeguards to eliminate or reduce threats to an acceptable level, which would allow performance of the services: 

  • do not use the same staff who provide augmented (nonattest) services on the attest engagement (may mitigate the self-review threat)
  • discuss the threats / safeguards analysis with the client's governance committee (to ensure agreement with the firm's approach to maintain independence) 
  • rotate staff performing the nonattest services (may mitigate the self-review threat)
  • monitor scope of the staff's activities (may mitigate the management participation threat)

PEEC members had several discussions on this proposed interpretation and thoughtfully considered various concerns. To obtain stakeholder feedback on the concerns, the proposal includes several questions for respondents' consideration, including: 

  • clarity of the safeguard that augmentation be of a short duration
  • addressing staff augmentation arrangements in the Code as a nonattest service (as opposed to employment)
  • whether the proposal appropriately addresses the appearance of independence

Comments on this proposal are due March 7, 2019