April 22, 2025
AICPA/NASBA Joint UAA Committee
AICPA Leadership and Board of Directors
NASBA Leadership and Board of Directors
RE: March 4, 2025, Exposure Draft to the Uniform Accountancy Act, Eighth Edition - January 2018
The Virginia Society of CPAs (VSCPA) has reviewed and appreciates the opportunity to respond to the Exposure Draft (ED) — Exposure Draft to the Uniform Accountancy Act, Eighth Edition - January 2018 — issued by the AICPA and NASBA on March 4, 2025. 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.
The Uniform Accountancy Act (UAA) serves an important role as model legislation to help promote consistency among all U.S. accounting jurisdictions. Still, its effectiveness relies on adoption by each jurisdiction and the need for it to reflect a consensus within the profession. The development process for this language must prioritize transparency and inclusivity, especially in a political climate that is increasingly anti-regulatory.
Changes to the UAA should reflect a commitment to understanding the current landscape while ensuring robust public protection. As the regulatory landscape has evolved over the past two decades, especially with the advent of interstate compacts and trust systems, it is vital to continuously re-evaluate the requirements for CPA licensure as well as practice mobility. Moving forward, we strongly recommend the establishment of a documented process for practice analysis to occur regularly to ensure licensure requirements remain relevant and applicable. By aligning with modern standards and addressing these concerns, we can ensure the UAA remains relevant and effective for the future of the profession. Showing a commitment to ongoing analysis and evolution of CPA licensure could be an important tool in thwarting attempts at deregulation.
Section 5 — Qualifications for a Certificate as a Certified Public Accountant
We are pleased to see the significant changes in this ED as compared to the ED issued on Sept. 30, 2024. Overall, the new ED appears to be responsive to the comments submitted and aligned with the direction many states have already begun implementing through legislative and regulatory initiatives. In particular, we note the shift from the proposed competency-based experience pathway to the addition of a baccalaureate degree along with two years of experience as defined by the board of accountancy of the state issuing the license. We support this approach, which is consistent with legislation passed in Virginia and signed into law on March 24, 2025.
Section 23 — Substantial Equivalency & Practice Privilege
By shifting the focus for determination of practice privileges from a state-by-state substantial equivalency analysis to license status of individual CPAs, this ED has a much-improved approach to practice mobility. Additionally, we agree with the removal of the National Qualification Appraisal Service (NQAS) as an entity with the authority to act on behalf of state boards of accountancy. NQAS is a valuable resource to state boards but should not be granted authority to make decisions on their behalf.
While we agree with including passage of the CPA Exam as a condition of practice privileges, we have concerns that the draft also includes completion of one of the three education and experience pathways to licensure as a requirement for individual CPAs to qualify for practice privileges. Not only could inclusion of this language in a state’s statutes unnecessarily limit the acceptance of innovative licensure pathways in the future, adding multiple conditions in various states will create unnecessary confusion and complexity to practice mobility across the country. We believe only requiring passage of the CPA Exam is sufficient to ensure licensees are well qualified to practice in all states — three states today only require licensure in good standing from another state, and one state requires only licensure in good standing and passage of the CPA Exam. We believe this process has worked effectively in these states and would be a preferred process in all states, which is why Virginia also adopted the latter model effective July 1, 2025.
At a minimum, the language should be amended to include the addition of language permitting state boards to approve additional licensure pathways or remove the specific pathways altogether from the model language and instead offer them as optional language in the comments for states that choose to include that level of specificity.
Conclusion
We applaud the efforts of the Joint UAA Committee to address the comments and concerns raised in response to the previous ED. We firmly believe collaborative efforts within the CPA profession are essential to address the talent shortages in the CPA pipeline effectively. The adoption of widely accepted alternative pathways to licensure and an easy-to-administer, evergreen approach to practice mobility will significantly benefit 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.
Sincerely,
Stephanie R. Peters, CAE
President & CEO
Virginia Society of CPAs