Alternative Pathways to CPA Licensure
Proposals Contain Changes to Licensure Requirements and Updates CPA Mobility
October 4, 2024
There has been significant discussion in recent years regarding the accounting pipeline, the time and cost of education, and whether the licensure requirements to become a CPA should be reevaluated. The discussion around licensure requirements was often referred to as the 150/120 debate. The AICPA and NASBA recently convened a joint task force to recommend an alternative pathway based on feedback they have received.
In the past several months, the debate has evolved into a broader discussion about alternative pathways and mobility. While the issue has been discussed for some time, the timing and sense of urgency has become paramount as many state boards of accountancy, state legislatures, and state societies have begun to address legislative initiatives in advance of the Uniform Accountancy Act (UAA) exposure drafts.
Two exposure drafts with an invitation to provide feedback and commentary have recently been released related to initial licensure requirements and mobility for CPAs.
- The first exposure draft, titled CPA Competency-Based Experience Pathway provides details on the framework of the new pathway referenced with comments due by December 6, 2024.
- The second exposure draft would update language to the UAA that would add a new pathway to licensure and update substantial equivalency language which allows CPAs to practice in other states. Comments are due on the proposed UAA language by December 30, 2024.
The exposure draft process is an opportunity to provide feedback to those responsible for writing the laws and rules that govern the profession. Your responses may determine if these changes are implemented as is or are amended. Once the UAA is amended each state/jurisdiction considers the changes and decides if they will adopt the recommendations.
TXCPA is preparing responses to both exposure drafts and considering the following points:
- Maintaining and continuing mobility between and among jurisdictions for current and future licensees is imperative. There should be no disruption in the ability of CPAs to practice across state lines. TXCPA supports the inclusion of effective and sufficient guardrails to ensure that out-of-state CPAs working in Texas have the qualifications to practice and are mindful of the protection of the public.
- It should be relatively easy to explain, and for a student to understand, the requirements to become licensed as a CPA.
- An alternative pathway based on a bachelor’s degree must include the required accounting and business concentrations already in place.
- There needs to be consideration for both the burden and potential liability related to CPA evaluators and the companies and firms who are responsible for certifying work experience and competency attainment. TXCPA supports further discussion of a competency framework that is scalable, easy to use, understandable, and efficient.
The TXCPA Board of Directors will approve our responses to the exposure drafts at their meeting on November 7-8 2024.
An Opportunity to Provide Feedback
Your comments and input will be valuable as we position the Society with legislation in 2025 addressing alternative pathways and mobility. TXCPA has already begun the process of developing its 2025 legislative agenda and your comments can help us to further develop that agenda.
If you would like to share your thoughts related to these proposals with TXCPA, we welcome your email submissions to chair@tx.cpa.
Timing in Texas is critical as the Texas legislative timeline does not mirror the UAA exposure draft comment period, nor the final adoption of the UAA (which could be in late Spring or early Summer 2025). The Texas Legislature will begin on January 14, 2025 and end in late May and will not be back in session until January 2027.
Comments on the proposals can also be provided directly:
Webcast Discussion
Take the opportunity to learn more on these subjects on either Nov. 6 or Nov. 20 on our Professional Issues Update webcast. This webcast is free for TXCPA members.
Professional Issues Update webcast
10 a.m. to Noon (Central time) | CPE Hours: 2
Register for: Nov. 6, 2024
Register for: Nov. 20, 2024 (replay)