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Letter to NASBA on proposed amendments to CPA Exam testing window

April 17, 2023

Nicola Neilon, CPA
Chair, NASBA Uniform Accountancy Act Committee
Sent via email to [email protected]

RE: Proposed amendments to the UAA Model Rules on Uniform CPA Examination testing window

Dear Ms. Neilon:

On behalf of the nearly 13,000 members of the Virginia Society of CPAs (VSCPA), the VSCPA has reviewed proposed amendments to the Uniform Accountancy Act’s (UAA) Model Rules pertaining to the Uniform CPA Exam Testing Window. We appreciate NASBA’s attention to this matter, as we consistently hear from CPA firms and other employers that the CPA pipeline is among their top challenges in hiring. 

We believe it is critically important for the CPA profession to come together to address the pipeline challenges through both short and long-term efforts to ensure a robust pipeline of CPA candidates. We also believe more discussion is needed before proceeding with a specific expansion of the CPA Examination testing window. This proposal includes an expansion from 18 to 24 months, and we are aware many other state CPA societies have submitted comment letters recommending expanding the window to 36 months. While we support an extension of the testing window, we feel there is insufficient data available to support a specific proposal at this time. Furthermore, while we recognize the urgency of the situation, the short timeline and a comment deadline in the midst of tax season has made it challenging to adequately gather input from our members and firms most impacted by this proposal. 

We respectfully request NASBA extend the comment deadline by at least 120 days and do additional research as well as gather broader stakeholder input prior to finalizing this proposal. The continued success of our practice mobility and substantial equivalency model is predicated on maintaining similar requirements for obtaining a CPA license. While we recognize differences in the testing window likely would not impact substantial equivalency and practice mobility, such differences could contribute to candidate confusion. Additionally, variance between jurisdictions on the testing window may also cause revenue and workload shifts among state boards as candidates seek out jurisdictions with longer testing windows. We believe maintaining a consistent testing window across all jurisdictions is critical.

We sincerely thank you for the opportunity to comment, and we appreciate your consideration of our input as you finalize this proposal. Please feel free to contact me or VSCPA Vice President, Advocacy Emily Walker, CAE, at (804) 612-9428 or [email protected] if we can be of further assistance.


Stephanie R. Peters, CAE
President & CEO
Virginia Society of CPAs