When the pandemic first hit a year ago, a key challenge for QAD was how to adapt its approach so that statutory and other monitoring reviews could continue safely, securely and effectively. In response, it very quickly turned traditional onsite visits into remote reviews. A year on, the team has completed a staggering 87% of its usual onsite visits virtually.
Pre-COVID-19, QAD carried out over 60% of reviews onsite, so the move to 100% remote monitoring was a daunting prospect for both the reviewers and firms. But the results speak for themselves and most of this is down to ICAEW and firms working together.
Emma Fountain, a QAD reviewer, attributes much of the success to flexibility on both sides. “We’re trying to work alongside our firms,” she emphasises. “We understand they’ve got a business to run, and that’s their livelihood, so although monitoring is a requirement, there is no need to make it awkward or difficult. It’s about working alongside them and guiding them through it.”
Despite the prospect of COVID-19 restrictions easing by the middle of 2021, the reality is that reviews are likely to remain remote for at least the next few months. So, if your review is due, what can you expect, how will it differ from onsite visits, and how can you best prepare?
QAD has produced specific guidance for firms about to undergo a virtual review. There are also some frequently asked questions and a list of information reviewers require. “First, we want the firm to look at these documents and think about what is possible and how they can supply us with the required information,” explains Fountain.
The next step is a pre-review call between the reviewer and the firm to discuss any initial queries, plan for the review and agree the review date. The reviewer will explain anything the firm is unsure about and address any difficulties they have, for example with document formats and sharing.
For remote reviews, firms generally submit documentation in two ways. If the firm has electronic capability, the main way is for ICAEW to set up a Sharefile secure portal. “We try to set this up as early as possible, so they can start uploading before the review date,” says Fountain. This data is kept solely for the review and then deleted. If firms are more paper-based, the reviewer will discuss how to pull everything together to produce a physical file, which can then be couriered.
Miriam Hickson, Director at JCS Accountants, found the document submission process simple. “The list of documents required by the reviewer was very clear,” she says, “and we had sufficient time to gather the files together once the Practice Assurance review was booked.”
JCS Accountants has been through two remote reviews: one for audit and the other for Practice Assurance. “We’ve been reinventing how we work as we go for the last year, so our audit files don’t look like they did last year,” says Hickson. “They’re more digital, and are reviewed and held in different ways. Having an opportunity to have the files picked and the two weeks to put the package together, gave us time to gather all those threads.”
The nature of remote and onsite reviews means the timescales may be slightly different. Onsite reviews are more focused on the day or days of the visit, so there can be more pressure to get everything finished within that time.
For the reviewer and firm, the remote review can feel more spread out, as the information comes through in a more dispersed way. “We discuss timescales and the process with firms at the beginning,” says Fountain. “Quite a few of the stages are dependent on specific information being provided, or us receiving answers by a specific point. So we’re trying to manage scheduling and making it clear to the firm that just because we’re not onsite that doesn’t mean we’re not going to want their attention.”
After the pre-review call, the reviewer will arrange a further call on the agreed review date to cover any queries about the documents submitted and other topics. This conversation will involve relevant people, such as the Practice Assurance principal, the firm’s money-laundering reporting officer or other team members covering the review’s remit. There may also be other calls with specific contacts as necessary to resolve queries.
The contacts required to be available depend on the type of review, and the firm’s structure and areas of work. “As with onsite visits, usually the reviewer will confirm at the planning stage what areas they will be covering and that usually flushes out who needs to be available,” explains Janet Hartas, Senior Manager, QAD, at ICAEW.
Don't be afraid
Hickson at JCS Accountants sees significant practical advantages for firms in the remote process. “When I remember back to the last onsite visit, if you’ve got a reviewer on the premises you devote yourselves to them while they’re there. And you can’t get any work done because you’re on tenterhooks all the time in case they need something to keep their work going.” With the remote review, the documents were all bundled up and sent beforehand. “The reviewer then went through them, only asking to speak to us at 4pm when she’d been though everything,” she says.
“The key is for firms to be prepared,” stresses Fountain. “Make sure you’ve got the information that we’ve asked for together in advance. That applies equally whether it’s onsite or remote. It gives everybody a running start.”
Next, make sure all key contacts are accessible and available. “It does get difficult for us if the right people are not around,” says Hartas. “So being on top of that and alert to it is very helpful. If we’re asking the right people the right questions, it speeds everything up.”
More broadly, Hartas urges firms to be open-minded and flexible. Some firms might be more wary than others, or more daunted by what they’re being asked to do. “But actually, we’re used to doing this now,” she says. “We can guide them through it and make it easy for them. They just need to be flexible and be prepared to have a go.”
“Don’t be afraid of us,” advises Fountain. “We are there for you to talk to and ask questions, whether that’s about something in the information you’re sending or about security; we can answer those questions.”
Hickson adds “don’t panic” to this advice. “As long as you are consistently hitting acceptable quality, your work should speak for itself,” she says. “And in my experience the reviewer can assess and identify that.”
Striking a balance
Looking into the future, what’s next for quality monitoring, and will remote reviews become a longer-term feature of the regulatory landscape? “Like everybody in the UK, we’ve learnt a great deal during the last year about what we can do differently,” says Hartas. “And one of the things we’re looking at is what good points we can harness from our experiences to roll into our visit approach going forward.”
While she wouldn’t like to predict the future balance of onsite and remote monitoring, she adds: “I think it’s clear we’ve all learnt, and our firms have learnt, that there are huge benefits from doing some things remotely and why wouldn’t we carry on with that in some way. What the visit of the future will look like, we don’t know yet, but I think it will be different.”