Post-Implementation Review

What is the Post-Implementation Review (PIR) process?

The PIR process is an evaluation of whether a standard is achieving its objective by providing financial statement users with relevant information in ways that justify the cost of providing it. It is an important quality control mechanism built into FASB’s standard-setting process which begins after the issuance of select standards. During the PIR process, the Board solicits and considers diverse stakeholder input and other research to evaluate the standards that are issued and whether there are areas of improvements the Board should address.

PIR Projects

A standard that is the result of a comprehensive or major standard-setting project is normally subject to a PIR.
 
Currently, the FASB is reviewing the following: More information on guidance that is in the process of being reviewed by the PIR team can be found here.

PIRs previously completed by the FAF can be found here.
 

PIR Process

The PIR process comprises three stages:
 
Stage 1. Post-issuance date implementation monitoring
Stage 2. Post-effective date evaluation of costs and benefits
Stage 3. Summary of research and reporting.

The commencement of a PIR and opportunities to participate in PIR activities will be announced publicly to stakeholders. The following is a summary of each stage.

Stage 1: Post-Issuance Date Implementation Monitoring

This stage begins after issuance of the standard and continues until at least three years after the latest effective date of the standard. During the post-issuance date implementation monitoring period (and before the effective date), at a macro level the Board will:
  1. Actively monitor practice as stakeholders prepare for initial implementation of the standard.
  2. Develop and disseminate implementation guidance and educational material.
  3. Communicate and perform outreach with stakeholder organizations, including outreach with the academic community (leveraging advisory councils, committees, and resource groups where applicable) to generate interest in research activities associated with the standard that are the subject of the PIR process.
After the effective date of the final standard, the Board will perform an archival review of financial reports and survey financial statement preparers (with the assistance of the academic community when needed).

Stage 2: Post-Effective Date Evaluation of Costs and Benefits

This stage begins after the effective date of the final standard and continues for approximately three to five years. Stage 2 activities consist of:
  1. Understanding the costs that an entity incurred in applying the standard as well as the costs that investors and other users incurred in analyzing and interpreting the information that the standard provides
  2. Understanding the benefits of the standard to investors and other users as well as to entities
  3. Monitoring the ongoing application of the standard. 
In this stage, the Board may consider sponsoring academic research to assess certain aspects of the standard to provide information to the Board on the effectiveness of the standard.

Stage 3: Summary of Research and Reporting

Following the completion of Stages 1 and 2, the Board summarizes their research in a final report. The final report is a culmination of previous reports and describes the activities conducted and actions taken to address any identified issues. In addition, a memorandum summarizing the PIR findings is prepared and discussed by the Board at a public meeting.
 

PIR Objectives

The PIR process has three main objectives:
  1. To determine whether a standard is accomplishing its stated purpose
  2. To evaluate the selected standard’s implementation and continuing compliance costs and related benefits
  3. To provide feedback to improve the standard-setting process.
To determine whether a standard is accomplishing its stated purpose, the PIR team assesses whether:
  1. The standard resolved the issues underlying its need
  2. Decision-useful information is being reported to, and used by, investors, creditors, and other users of financial statements
  3. The standard is operational; that is, stakeholders can apply the standard as intended, the standard is understandable, and preparers are able to report the information reliably
  4. Any significant unexpected changes to financial reporting or operating practices resulted from applying the standard
  5. Any significant unanticipated consequences resulted from applying the standard.
To evaluate the selected standard’s implementation and continuing compliance costs and related benefits, the PIR team assesses whether:
  1. Implementation and continuing compliance costs are consistent with the costs that the Board considered and stakeholders expected
  2. Benefits are consistent with what the Board intended and stakeholders expected.
To provide feedback to improve the standard-setting process, the PIR team assesses whether the results of the review suggest that improvements are needed.
 

Examples of PIR Process Activities

Stage 1: Post-Issuance Date Implementation Monitoring

Public accountability is a hallmark of the PIR process. The commencement of the post-issuance date implementation monitoring stage of PIR for a standard and opportunities to participate in PIR activities are announced publicly to stakeholders. To ensure the independence of the PIR process, evaluative activities of Stage 1, such as archival and survey research, are directly conducted by staff members who were not involved in the development of the standard being reviewed. That can include permanent staff, practice fellows, academic fellows, and Board members not seated during the development of the standard. The following are examples of the activities in this stage:
  1. Collect implementation questions from stakeholders following issuance of the final standard; consider requesting questions from stakeholders; and develop answers to the questions for possible inclusion in implementation guidance or for standard-setting consideration.
  2. Discuss the implementation of the standard with the advisory council(s) and committees, transition resource groups (if applicable), industry liaison groups (if applicable), implementation resource groups, and stakeholder organizations.
  3. Monitor technical inquiries to identify major emerging issues arising from the standard’s implementation.
  4. Incorporate major implementation issues into presentations at conferences and meetings.
  5. Conduct archival research on the financial reports using a random sample and other volunteer entities (for example, entities that participated in field tests or field studies).
Stage 2: Post-Effective Date Evaluation of Costs and Benefits

The following steps are examples of the activities in this stage:
  1. Conduct surveys to assess the cost of transition to the new standard, differentiating between those costs that will be nonrecurring compared with costs that will be recurring.
  2. Solicit feedback from advisory councils and committees/regulators/liaison groups about their experience with the costs to apply the standard and to analyze the resulting information.
  3. Conduct one-on-one outreach meetings with preparers and auditors to gather information on the costs to apply the standard and how it compares with their plan.
  4. Conduct workshops and/or roundtables to discuss costs with a cross-section of stakeholders.
  5. Assess and monitor financial statement user perceptions to understand whether the standard achieved its expected benefits and the information utility to financial statement users.
  6. Monitor accounting and analyst publications.
  7. Review financial statement disclosures for consistency and transparency; leverage eXtensible Business Reporting Language (XBRL) where possible.
  8. Conduct discussions with the Investor Advisory Committee (IAC) and other advisory councils, committees, regulators, liaison groups, etc., to gather data on the perceived benefits of the standard.
  9. Conduct archival research on financial reports.
  10. Consider sponsoring academic research on the achievement of the standard’s objectives. 
Stage 3: Summary of Research and Reporting

In this stage, the FASB publicly discusses the results of its research and prepares a final report for the FAF’s Board of Trustees. The following steps are examples of the activities in this stage:
  1. Prepare a report for discussion with the FAF’s Board of Trustees. Post the report to the public website.
  2. Prepare a memorandum summarizing the research findings and discuss with the FASB in a public meeting.

Potential Standard-Setting Action

A PIR could result in the need for the FASB to take standard-setting action to address (1) areas of the standard that are not understandable, (2) unintended consequences that were not foreseen during development of the standard, and/or (3) unexpected costs (either one time or ongoing) based on the actual results observed as compared with the expectations documented in the Board’s basis for conclusions. Like all aspects of the Board’s standard-setting activities, actions resulting from a PIR are subject to the Board’s normal due process.

One of the primary benefits of having the PIR process embedded within the overall standard-setting process is that it is a more efficient and effective way to continually improve the standard-setting process and the resulting standards. For example, if it becomes evident during a PIR that portions of a given standard are not understandable or that unexpected costs arise during implementation, the Boards can address those issues on a timely basis and any needed improvements to standards can be immediately achieved through due-process activities.

More information on FASB standards and any potential standard-setting action can be found here.
 

Oversight of the PIR Process

The PIR process is subject to FAF Board of Trustees oversight throughout all three stages.

The FASB reports on the progress of PIR projects during their public meetings and report regularly to the Standard-Setting Process Oversight Committee (SSPOC) of the FAF Board of Trustees. The final PIR report is reviewed by the SSPOC and published on the FAF website.
 
A document further detailing the PIR process can be accessed here.