VSCPA signs on to AICPA letter encouraging accounting receive CIP STEM designation code

Date: August 1, 2023

To: SEVP Response Center via email

Subject: Attention: STEM CIP Code Nomination

On behalf of the American Institute of CPAs (AICPA), and the many organizations enumerated at the end of this letter, we are writing to request that several Classification of Instructional Program (CIP) codes be added to the Department of Homeland Security’s (DHS’s) STEM Designated Degree Program List.

The accounting profession has evolved substantially into a profession actively driving technological innovations to help businesses compete in an expanding global marketplace. These professionals have acquired new skills to remain competitive, including the development of software, cloud computing and other emerging technology innovation skills.

Critically, and as emerging technology intersects in new ways with business, accountants are routinely contributing to this innovation. Robotic process automation (RPA) is just one example of how accountants are writing scripts and developing bots to improve the operations and financial management of organizations. Many emerging technologies (for example, blockchain and cybersecurity technologies) converge directly with accounting and finance. Professionals in the accounting field are required to understand these technologies and have been instrumental in developing software and other technology to manage them. Further, conducting data and financial analytics is an essential skillset for accountants, requiring digital acumen and the ability to develop technologies to enhance these skills.

While many accounting programs have modified their curricula to reflect the changing environment of accounting and its technological base, these changes have not yet been reflected in the recognition of accounting as a DHS STEM subject. Programs use different CIP codes, and this submission is requesting DHS consider six of these codes to be included on the DHS STEM Designated Degree Program List (rationale for each is presented in the Appendices to this letter). They are:

• 52.0301 – Accounting (See Appendix A) 
• 30.1601 – Accounting and Computer Science (See Appendix B) 
• 52.0304 – Accounting and Finance (See Appendix C) 
• 52.0303 – Auditing (See Appendix D) 
• 43.0405 – Financial Forensics and Fraud Investigation (See Appendix E) 
• 52.1601 – Taxation (See Appendix F)

It is our strongest belief that accounting, as a field of study and as it is practiced by accounting professionals, should be designated as a STEM field, specifically under the “T” for Technology.

Because CIP codes directly reference fields of study rather than occupations, the justifications provided for each CIP code further clarifies the courses that are taught, particularly at the college/university level, for degrees in these areas. Further, we highlight additional modernization efforts by accounting firms to 

ensure both newer entrants to the profession and seasoned professionals – whether they are integrating new innovations into their practices, are advising clients on business enhancement practices, or as part of other areas of practice – possess the skills to meet the needs of the competitive global marketplace.

Accounting Profession Modernization and an Increasing Use of Complex Technology Solutions

To serve the public interest, Certified Public Accountants (CPAs) provide the capital markets with confidence and assurance in financial reporting. The work performed by professionals in public accounting impacts employees, retirees, communities, investors, the capital markets and the global economy. In addition to those serving in public accounting, accounting professionals in business, government, and not-for-profit organizations work to meet the public’s, clients’ and employers’ needs in a technology-driven marketplace.

Across the globe, companies rely on increasingly complex technology systems. To best serve the public interest, accounting professionals are constantly adapting their skills to allow them to properly use and develop cutting-edge technology. These skills allow accountants to manage and analyze data that drives decision-making. Accounting professionals’ attention to detail, critical thinking and digital acumen are the foundation for their ability to develop the technology required to assist in problem solving in today’s modernized market. Accountants now have skill sets which also include their ability to design and implement analytical dashboards with data visualization software such as Tableau and Spotfire. Additionally, they develop unique data visualizations and real time dashboards to help their employers or client companies understand results and identify important information for decision making. Some accounting professionals also assist their employers and clients with financial planning by developing algorithms to determine appropriate investment strategies for their clients’ unique life situations.

Public accounting firms have developed proprietary technologies to improve their handling and analysis of information. Such technologies include programs which allow firms to better and more quickly perform risk assessments (including with AI technology), manage day-to-day audit work, and utilize metrics unique to companies across many market sectors to efficiently review and evaluate transactions. This allows for analysis specific to the types of industries in which these companies operate, for example in healthcare, insurance, real estate, oil and gas, mortgage origination, vehicle production, chemicals production, and many others. Their work provides important data and analysis, utilizing many different technologies, (for example, through the use of SQL, DAX (Power BI), Powerquery, VizQL) which may mean the difference between choosing to move forward with innovation or waiting for a better economic environment.

Accounting professionals work alongside Information Technology (IT) professionals to create programs that allow for financial analytics, financial data processing, knowledge management, data visualization, effective decision communication, machine learning for finance, statistical inference, and dynamic modeling on financial data. Accounting professionals often utilize technology skills that are integral to the audit function and other areas of American business, including IT auditing (which demands a high- level of technological knowledge and skills to evaluate the IT infrastructure), artificial intelligence, blockchain, data analytics, and forensic and predictive accounting and cybersecurity, among others. The accounting profession continues to further this knowledge through the development of the Dynamic

Audit Solution (DAS)1 and accounting firms’ proprietary digital technology, which equips audit professionals to be proficient in data science, integration, and analytics. These audit professionals must become experts in the data with which they spend time analyzing. They must further be able to identify and analyze new risks and anomalies, as well as help businesses reengineer systems so that they are able to speak to one another.

As an example, according to Vetter (2018),2 many accounting firms use blockchain implementations, applications, and assurance services. This allows users to access ledgers in real time, as well as create smart contracts and record transactions. Blockchain technology is growing in use by global corporations such as Walmart, Amazon, Anheuser-Busch, and McDonalds3 and is changing the way transactions are processed and for how they are accounted. As such, accountants are now performing increasingly complex analyses of financial results.

Regardless of their practice area, whether in business, a CPA firm, academia, the associations, or engaged in the regulatory environment, our economy is demanding more of accountants. It is the accounting profession’s duty to push for the requisite technology education while students are in university programs to ensure accounting professionals meet and surpass the demands of our global economy, now and in the future. We strongly believe that recognition of the profession as a STEM (specifically, technology) profession, will help to accomplish that goal.

Evolution of Education to Support Global Markets

Accounting students may not plan to become CPAs; rather they may decide to pursue other positions in finance, computer science or become entrepreneurs. Most accounting programs, however, include coursework and curriculum content to address the specific needs of the CPA profession.

Accounting programs have been updating their curricula in response to the changing landscape for the profession, as evidenced by the CPA Evolution Model Curriculum (CPAEMC)4 project of the AICPA and National Association of State Boards of Accountancy (NASBA), published in June 2021. This project developed a sample curriculum for programs to consider as they updated their course offerings. An entire section of the sample curriculum is related to Information Systems and Controls. Additionally, CPAEMC includes specific competencies in technology for adaptation in university accounting programs. To illustrate, Appendix G includes selected competencies addressed in the Business Analysis and Reporting section of this curriculum resource. These competencies have been developed by academics currently teaching these topics in courses in the accounting programs at their universities.

The accounting profession has reviewed the competencies and skills needed by accounting students to succeed amid today’s rapidly expanding digital world and global demand for advanced analytics. The skills and competencies identified such as enhanced knowledge and ability to manipulate robotic process automation (RPA), natural language processing (NLP) machine learning (ML), artificial intelligence (AI), among others, align directly with STEM instruction. Accounting programs must have the support and flexibility needed to instruct students to understand, use, and develop technology as the profession evolves. STEM recognition for the CIP codes listed below is a crucial tool in the academic toolbox to ensure such evolution remains in balance with the marketplace.

Changes to CPA Exam and Academic Programs Underscores the Need for CPAs’ Technology Acumen

The Uniform CPA Exam (Exam) is a critical step toward licensing accounting professionals. AICPA and NASBA’s joint CPA Evolution initiative ensures future Exam candidates possess the rapidly changing skills and competencies the practice of accounting requires today. Under the CPA Evolution licensure model, all candidates will be required to pass three Core exam sections covering: Auditing and Attestation (AUD); Financial Accounting and Reporting (FAR); and Taxation and Regulation (REG). Each candidate will also choose one Discipline (i.e., Business Analysis and Reporting (BAR), Information Systems and Controls (ISC), or Tax Compliance and Planning (TCP)) to demonstrate knowledge and skills in that discipline.

Beginning in January 2024, the updated Exam content will have a pervasive focus on data and technology throughout all sections of the exam. These updates will assess a candidate’s ability to understand how data is structured and how information flows through IT systems and business processes. The Exam also covers aspects of IT infrastructure, from platforms and services, to security, confidentiality, and privacy, as well as to the foundational skills needed to build and develop technology. As the profession changes, so too has the education and credentialing for those entering the profession.

Of importance, the world’s leading business school and accounting accreditor – the Association to Advance Collegiate Schools of Business (AACSB) – predicted the increased use of information technology and has mandated that technology knowledge is a minimum requirement for entry into the accounting profession. The AACSB now requires all programs seeking accounting program accreditation in addition to business school accreditation to meet this requirement:

Standard A5: Consistent with mission, expected outcomes, and supporting strategies, accounting degree programs include learning experiences that develop skills and knowledge related to the integration of information technology in accounting and business. This includes the ability of both faculty and students to adapt to emerging technologies as well as the mastery of current technology. [INFORMATION TECHNOLOGY SKILLS, AGILITY AND KNOWLEDGE FOR ACCOUNTING GRADUATES AND FACULTY—RELATED BUSINESS STANDARD 4]5

University programs and the joint initiative through AICPA and NASBA highlight the responsibility entrusted to us to ensure accounting students and Exam candidates fully understand how technology intersects directly with the accounting profession and business community. To promote an environment for advancement of the public interest, the accounting profession is committed to looking at how each field has impacted technology, and further how that technology can be enhanced. We believe it would be a disservice to our nation’s future should we fail to provide accounting students with every opportunity to explore and grow the use of emerging technology.

Conclusion

For each of the CIP codes nominated in this submission (see Appendices A – F), we have included those common courses requiring the integration of technology traditionally taught as part of most universities’ curricula for accounting and accounting-related programs (See Table 1 in Appendix A). In that Table, we also provide a sample of the types of technology that students are expected to master in those courses. When different coursework is required for a particular program, we discuss the modification to Table 1 as we address those nominations. Note, too, that many universities offer both undergraduate and graduate degrees in accounting and accounting-related fields; the courses provided in Table 1 of Appendix A may be taught at either level, depending on the individual programs.

We appreciate the opportunity to provide this nomination submission on behalf of the accounting profession. The profession is crucial to protecting the public interest, creating positive change and of enhancing competitiveness for American and global businesses.

Sincerely,

Barry C. Melancon, CPA, CGMA Susan S. Coffey, CPA, CGMA
President & CEO Chief Executive Officer – Public Accounting

*****

About the American Institute of CPAs

The American Institute of CPAs® (AICPA®) is the world’s largest member association representing the CPA profession, with more than 421,000 members in the United States and worldwide, and a history of serving the public interest since 1887. AICPA members represent many areas of practice, including business and industry, public practice, government, education and consulting. The AICPA sets ethical standards for its members and U.S. auditing standards for private companies, not-for-profit organizations, and federal, state and local governments. It develops and grades the Uniform CPA Examination, offers specialized credentials, builds the pipeline of future talent and drives continuing education to advance the vitality, relevance and quality of the profession.

Additional organizations supporting this nomination submission:

Alabama Society of CPAs
Alaska Society of CPAs
American Accounting Association
Arizona Society of CPAs
Arkansas Society of CPAs ASCEND
Association to Advance Collegiate Schools of Business
Association of Latino Professionals for America
California Society of CPAs
Center for Audit Quality
Colorado Society of CPAs
Connecticut Society of CPAs
Delaware Society of CPAs
Greater Washington Society of CPAs Diverse Organization of Firms
Florida Institute of CPAs
The Georgia Society of CPAs
Guam Society of CPAs
Hawaii Society of CPAs
Idaho Society of CPAs
Illinois CPA Society
Indiana CPA Society
Iowa Society of CPAs
Kansas Society of CPAs
Kentucky Society of CPAs
LatinoTaxPro
Society of Louisiana CPAs
Maine Society of CPAs
Maryland Association of CPAs
Massachusetts Society of CPAs
Michigan Association of CPAs
Minnesota Society of CPAs
Mississippi Society of CPAs
Missouri Society of CPAs
Montana Society of CPAs
National Association of Black Accountants NAF
National Association of State Boards of Accountancy
National Council of Philippine American Canadian Accountants
Nebraska Society of CPAs
Nevada Society of CPAs
New Hampshire Society of CPAs
New Jersey Society of CPAs
New Mexico Society of CPAs
New York State Society of CPAs
North Carolina Association of CPAs
North Dakota CPA Society
The Ohio Society of CPAs
Oklahoma Society of CPAs
Oregon Society of CPAs
Pennsylvania Institute of CPAs
Puerto Rico Society of CPAs
Rhode Island Society of CPAs
South Carolina Association of CPAs
South Dakota CPA Society
Tennessee Society of CPAs
Texas Society of CPAs
Utah Association of CPAs
Vermont Society of CPAs
Virgin Islands Society of CPAs
Virginia Society of CPAs
Washington Society of CPAs
West Virginia Society of CPAs
Wisconsin Institute of CPAs
Wyoming Society of CPAs