The VSCPA has written a letter to the Virginia Board of Accountancy (VBOA) detailing its reasons for supporting the establishment of a formal “inactive” licensure status for individual CPA licenses in Virginia.
The VSCPA noted that the VBOA has made a priority of ensuring that all Virginia accounting statutes and regulations align with the Uniform Accountancy Act (UAA) and related Model Rules. The UAA stipulates that state boards of accountancy include an option to allow an exception to continuing professional education (CPE) requirements for licensure and renewal and that licensees who use this exception must use the term “inactive” adjacent to their CPA title, except on their CPA certificate.
The VBOA currently allows an exemption from CPE requirements for licensees who are not providing services to the public or an employer, but does not require use of the term “inactive” or maintain a listing of CPAs utilizing this exemption.
The VSCPA wrote:
“We believe the ambiguity of the current regulation creates confusion for licensees and the public as to when CPAs qualify for the CPE exemption. Consequently, many CPAs actively providing services to employers believe they are eligible for the CPE exemption simply because they do not use the CPA title on any documents or devices, and are not “holding out” as a CPA. The direct outcome of this is CPE deficiencies identified through the VBOA’s CPE audit process, which ultimately results in additional enforcement actions.”
The VSCPA recommended that the VBOA:
- Require licensed CPAs who are eligible for AND take advantage of the CPE exemption to place the word “inactive” adjacent to their CPA title except on their CPA certificate
- Clearly define which CPAs are eligible for “inactive” status
- Indicate all CPA licenses in “inactive” status on the VBOA website
- Continue to require CPAs in “inactive” status to comply with re-entry requirements to become “active”