Nov. 11, 2024
AICPA/NASBA Joint UAA Committee
AICPA Leadership and Board of Directors
NASBA Leadership and Board of Directors
RE: CPA Competency-Based Experience Pathway
The Virginia Society of CPAs (VSCPA) has reviewed the Exposure Draft (ED) — CPA Competency-Based Experience Pathway — issued by the AICPA and NASBA. The VSCPA is the leading professional association in Virginia dedicated to enhancing the success of all CPAs and their profession by communicating information and vision, promoting professionalism, and advocating members’ interests. The VSCPA membership consists of nearly 12,000 individual members who actively work in public accounting, private industry, government, and education.
While we commend your efforts to explore a competency-based pathway to CPA licensure, we believe that the current proposal, as drafted, poses serious challenges that could undermine both its effectiveness and fairness. The existing 150-hour educational requirement presents significant barriers for many aspiring CPAs, particularly those from diverse backgrounds. Moving forward with the proposed model also creates its own potentially significant barriers due to its inherent subjectivity, thereby not putting the profession in a better position.
The reliance on subjective assessments without a standardized, objective evaluation process raises critical concerns. The potential for inconsistencies in competency evaluations could lead to legal challenges and could compromise the integrity of the CPA profession. Moreover, failing to account for unconscious bias in the assessment process not only endangers the fairness of evaluations but could deter qualified candidates from pursuing licensure altogether.
Placing the responsibility of competency assessment to individual CPA evaluators and organizations adds unnecessary pressure on practitioners already grappling with complex regulatory environments. This also increases the risk of liability for CPA evaluators and organizations signing off on candidates who may later fall short of the necessary competency. Additionally, this requirement adds more complexity if the candidate works for an employer that does not have a CPA to directly supervise the candidate — it is unclear how a CPA in another organization would or could attest to the skills. It also is unclear how a candidate’s experience would be verified through volunteer work. Lastly, inserting the candidate/evaluator dynamic into employment relationships could create undesirable situations that, at a minimum, deserve further consideration before adoption.
The proposed pathway is challenging to communicate to state lawmakers and stakeholders, particularly given current anti-regulatory sentiments in state legislatures. It adds complexity to the licensure process at a time when there is a push for removing unnecessary barriers to licensure, and in some cases eliminating licensure altogether. Any new pathway to licensure must be consistent, fair, and transparent for all candidates to be acceptable to state legislatures.
Our profession is at a critical juncture, and collaborative efforts are urgently needed to effectively address the talent shortages in the CPA pipeline. The adoption of alternative pathways to licensure that are widely accepted and embraced will significantly enhance the profession as a whole.
We appreciate the opportunity to comment and remain committed to working alongside AICPA, NASBA and other stakeholders in shaping the future of CPA licensure. Please feel free to contact me or VSCPA Vice President, Advocacy & Pipeline Emily Walker, CAE, at (804) 612-9428 or [email protected] if we can be of further assistance.
Thank you for considering our perspectives as we strive to strengthen the integrity and accessibility of the CPA profession. Together, we can pave the way for a more equitable future for all aspiring CPAs.
Sincerely,
Stephanie R. Peters, CAE
President & CEO
Virginia Society of CPAs