Last year, the Colegio de Contadores Públicos Autorizados de Panamá (CCPAP), alongside several other professional accountancy organizations, participated in a regional workshop to talk about overcoming obstacles to enhance quality assurance (QA) in Latin America. While we all recognize that QA review systems are an important element of a sustainable global financial infrastructure (as well as a requirement for all IFAC member organizations), the implementation is not an easy, straightforward endeavor. There are numerous challenges on the road to adoption. Addressing these issues requires technical and financial resources, collaboration, and stakeholder buy-in. At the CCPAP, we realized that we had a pivotal role to play in driving the change in our jurisdiction to introduce quality assurance reviews. Over the course of four years we strategically worked to tackle these challenges.
Why QA Reviews?
In 2010, the CCPAP submitted its first SMO Action Plan to IFAC (International Federation of Accountants) as part of its membership requirement, demonstrating its commitment to serve the public interest. While reviewing the seven Statements of Membership Obligations (SMOs), the CCPAP determined that fulfilling SMO 1—the establishment of a jurisdictional QA review system—would be the most complicated and important to cover. QA reviews and their findings would not only improve the quality of professional services delivered by Panamanian CPAs but would also be useful tools for banks, other regulators, and investors that are the main users of audited financial information. This is especially true for financial statements prepared and audited for small and medium-sized enterprises.
With QA reviews, end-users would have more confidence in the quality of the audits and the financial information presented within the financial statements. We also knew this could be a game changer in reducing risks related to fraud and money laundering that continue to occur worldwide.
Targeted Approach
CCPAP took a three-pronged approach, identifying resources, collaboration, and stakeholder buy-in that would be necessary to implement a QA review system.
Resources
Since none of the national accountancy regulators were operating a QA review system at the time, the CCPAP looked regionally for guidance. We engaged with the Colegio de Contadores Públicos Autorizados de Puerto Rico (CCPAPPR) as the institute had already been operating a QA review program for more than 20 years. I visited the CCPAPPR in 2010 to learn firsthand how their QA review was developed and how it operates—everything from the QA review methodology, evaluating how to develop a customized system, and how to update and amend Panama legislation and frameworks to enforce such a system.
With this new knowledge, we set out to overcome our first barrier—financial resources. We approached several international multilateral agencies explaining the importance of this project and the impact that it would have in the country. We were unable to secure funds in this way but this did not deter our determination.
Collaboration
Over the next two years, we worked with the CCPAPPR to establish a working agreement and framework to develop our own QA review system. We also engaged in extensive outreach to our fellow PAOs to explain the significance and benefits of a QA review system in order to have them join us in this initiative. After much deliberation, the Asociación de Mujeres Contadoras Púbicas Autorizadas de Panamá (AMUCOPA) agreed and we were able to form the Panama Quality Alliance (it is known by its Spanish acronym, ALCAPA).
The ALCAPA became the principal authority with respect to decision-making and designing the four phases that would ultimately lead to the QA review program in Panama. In 2013, ALCAPA and CCPAPPR signed a formal contract and the program officially kicked-off.
Stakeholder Buy-In
We knew we had to first take stock and get a general understanding of a) if small, medium, and individual practitioners were implementing quality control standards and practices and b) if they were applying the standards properly. This consultation provided the CCPAP with a picture of the operating environment of the firms and consequently, how we should design and conceptualize the QA reviews.
As we were conducting this consultation, it became clear that we would need to convince both firms and reviewers of the benefits of QA reviews. We emphasized that a Regulatory Committee would be formed to independently assess findings and that first rounds of QA reviews would be voluntary and educational (non-punitive) to ensure firms’ willing participation. We also assured them that CCPAP would be ready and prepared to offer continuing education in order to support members with QA reviews and keep them updated on new developments. Furthermore, we also assured members of confidentiality in relation to their clients. Our review results are not disclosed to third parties not associated with the QA review process.
After our Phase 1 consultation was completed in 2014, we began developing operational manuals that clearly aligned with ISQC 1. I am proud to say that in December 2016, we officially launched the program with significant coverage highlighting the value of QA reviews for the Panamanian economy.
Lessons Learned
The CCPAP learned valuable lessons regarding the factors that contributed to this successful implementation process, including:
- Consistency and commitment—the Executive Directors from CCPAP and from CCPAPPR were the same throughout the span of this project ensuring that both institutes would see the project through;
- Bringing firms and practitioners along the journey—change can be daunting unless we provide support and educate our members on the benefits on this process;
- Reaching out—collaborating with other local associations to form a united coalition created strength and energy behind the project;
- Properly training reviewers—without competent reviewers that can identify good quality control practices, the QA review process is not operable.
Next Steps
A strong, stable QA review system is supported by a legal framework that mandates reviews. In an ideal world, this helps ensure that all firms and practitioners are subject to reviews, which in turn would elevate the overall quality of audit work. Unfortunately, the current accountancy legislation in Panama is over 60 years old and outdated. Our QA review program is not currently mandatory. The CCPAP continues to advocate for changes to the law to include an official endorsement of the QA reviews and require mandatory participation in the program.
In addition, the CCPAP continues to engage with and encourage a third PAO—the Association of Authorized Public Accountants (ACONTAP)—to join the ALCAPA to further strengthen the program. With a third association included, the ALCAPA may create a legally incorporated union/entity called the Consejo Ejecutivo de Asociaciones de Contadores in Panama which would add further credibility and authority to our program.
The path to establishing and operationalizing a QA review program has not been without its bumps and challenges. We hope that the experience of CCPAP demonstrates that these obstacles can be overcome and that PAOs continue to be a force for positive change in this area.
If you are interested in learning more about the project or seek more practical guidance on establishing a QA review system, please contact the author or visit the CCPAP’s website or ALCAPA’s website. Readers can also subscribe online to receive updates from the Quality & Development Team, and stay tuned from outcomes of the XIV Inter-American Regional Accounting Conference in Panama taking place on May 17 and 18th.
Has your PAO led an initiative to develop and implement a QA review system in your jurisdiction? Let IFAC know—we would love to showcase your work in action!
