March 22, 2024
Stephanie Saunders, CPA
Chair, NASBA
150 Fourth Ave., North
Suite 700
Nashville, TN 37219
RE: Professional Licensure Task Force Proposal on Structured Professional Program
Dear Ms. Saunders:
On behalf of the nearly 13,000 members of the Virginia Society of CPAs (VSCPA), the VSCPA Executive Committee reviewed and discussed the NASBA Professional Licensure Task Force’s concept of creating a Structured Professional Program (SPP) as an additional pathway to CPA licensure. We generally support the concept and encourage the task force to continue its work developing this model with input from relevant stakeholders. We believe this approach will also minimize disruption to license mobility for CPAs.
We are acutely aware of the challenges posed by the current 150-hour pathway to CPA licensure, particularly in terms of the time and cost of education for prospective CPAs. Many aspiring professionals appear to be deterred by these obstacles and candidates from diverse backgrounds seem to be particularly affected. Creating a pathway which incorporates more experiential learning opportunities would be welcome and hopefully more accessible to a broader candidate pool.
While we support the SPP in concept, we offer the following additional thoughts for your consideration:
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Streamlined Requirements: Avoid unnecessary complexity to ensure clarity for candidates and faster implementation.
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Standardization of Competencies: Define and establish clear metrics for assessing competencies, along with assigning responsibility for this task.
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Ongoing Evaluation: The SPP should incorporate mechanisms for periodic review and updates of competencies to align with the evolving needs of the CPA profession and market demands.
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Accessibility Across the Profession: Ensure the SPP is accessible and adaptable to candidates from sectors beyond public accounting, including business, government, academia, etc.
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Financial Considerations: Determine who is responsible for the costs associated with the creation and maintenance of the SPP, minimizing the cost to candidates.
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Timely Updates to Regulatory Frameworks: Corresponding updates to the Uniform Accountancy Act (UAA) and UAA model rules should be made as soon as practicable to recognize the SPP as an equivalent pathway to the traditional 150-hour requirement. Thought should also be given to whether model language could be more evergreen to allow future updates to occur more easily.
We firmly believe collaborative efforts within the CPA profession are essential to address the talent shortages in the CPA pipeline effectively. Adoption of widely accepted alternative pathways to licensure will significantly benefit the profession as a whole.
We appreciate the opportunity to comment and remain committed to working alongside 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