The Virginia Board of Accountancy (VBOA) recently added two new license statuses: “Active — Renewal Fee Delinquent” and “Active — CPE Exempt.” The latter status went into effect July 1, 2014, and affects CPAs who wish to maintain their license but are not providing services to an employer or the public and do not expect to provide such services for a period of time. The VSCPA spoke with VBOA Executive Director Wade Jewell to get more information on the details of the new status. This interview was conducted via email.
VSCPA: Can a licensee take advantage of Active — CPE Exempt status if he or she does not use the CPA title?
WJ: There continues to be confusion around this issue. Per Board Regulation 18VAC5-22-40, “...holding a Virginia license constitutes using the CPA title.” Therefore, not using the CPA title does not automatically exempt a licensee from CPE requirements. A licensee can only be considered Active – CPE Exempt if he/she is not currently providing services to the public (providing services that are subject to the guidance of the standard-setting authorities listed in the standards of conduct and practice in subdivisions 5 and 6 of § 54.1-4413.3) or to an employer (providing to an entity services that require the substantial use of accounting, financial, tax or other skills that are relevant, as determined by the Board).
VSCPA: How long does a licensee need to be out of work or not performing accounting services to qualify for CPE Exempt status?
WJ: A licensee can apply for the Active — CPE Exempt status immediately upon a change in working status that qualifies for this exemption.
VSCPA: What does a licensee need to do to reactivate his or her non-CPE Exempt status? How many hours of “backfill” CPE will he or she need to take?
WJ: A licensee must request reinstatement of the Active status from the Board prior to beginning to provide relevant services. A licensee must obtain at least 120 hours of CPE prior to providing the services, including the Virginia-Specific Ethics course. CPE obtained during the three calendar years prior to the current calendar year and from the start of the current calendar year to when the licensee begins providing the services shall be considered in determining whether the licensee has complied with the CPE requirements.
VSCPA: Does a licensee need to inform the VBOA if he or she realizes he or she has fallen short on his or her required CPE?
WJ: Yes. All licensees are expected to self-report a CPE deficiency.
VSCPA: How will the public know the difference between a CPA and a CPA exempt from CPE requirements?
WJ: The public can check the status of a CPA on the VBOA website. On the VBOA home page, anyone can go to the “Licensee Search” function and perform an inquiry. For any CPA that has been approved as CPE Exempt, their status will reflect Active — CPE Exempt.
VSCPA: Are there any plans to implement an Emeritus status for retirees?
WJ: No, retirees who are not providing services to the public or to an employer must apply for the Active — CPE Exempt status in order to avoid taking CPE.
VSCPA: Is there any difference in the annual renewal fee for CPAs using the CPE Exempt status?
WJ: No, the fee is the same for both the Active and Active — CPE Exempt statuses.