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The American Institute of CPAs (AICPA) and the National Association of State Boards of Accountancy (NASBA) recently proposed an alternative pathway to the standard 150-hour requirement: the CPA Competency-Based Experience Pathway. Comments on the proposal are due by Dec. 6.

The AICPA and NASBA are also recommending changes to the Uniform Accountancy Act (UAA). The UAA model legislation gives state legislatures and boards of accountancy a national model that can be adopted in full or in part to meet the needs of their own jurisdiction. The changes in the UAA provide for implementing the competency model. They would also make changes to the current substantial equivalency provisions in the UAA, which would be monitored and implemented by NASBA. Comments on the proposal are due by Dec. 30.

NJCPA Position

The NJCPA Board of Trustees supports licensure with an additional year of experience instead of 30 credits but does not support the proposal’s requirement that the first year of experience be done within the competency-based framework outlined in their proposal. We are concerned about the onerous compliance requirements on employers to document specific competencies. We are also concerned about the potential to disproportionately impact small firms. 

The Board did not support the draft UAA’s proposal to adopt a modified version of the current substantial equivalency system to provide for interstate mobility. Instead, the Board supports the concept of “automatic mobility,” which provides mobility privileges to any person with a CPA license in any other state, so long as they have passed the CPA exam, received a bachelor’s degree, and have two years of experience.

On Nov. 14, the NJCPA Board of Trustees submitted a comment letter to the AICPA and NASBA indicating the Society’s intention to introduce legislation in 2025 to add a pathway for licensure that does not require 150 hours of education. Our proposal will include language intended to ensure continued practice mobility for out-of-state CPAs practicing in New Jersey as well as the addition of a licensure pathway requiring passage of the CPA Exam, a baccalaureate degree with an accounting concentration and two years of experience in accounting.

Other Organizations and Individuals

CPA firms, CPA societies, accounting professionals and others are issuing statements and submitting comment letters:

• Minnesota Society of CPAs comment letters: CPA Competency-Based Experience Pathway and amendments to the UAA (Nov. 15, 2024)
• Virginia Society of CPAs comment letter (Nov. 11, 2024)
• California Board of Accountancy comment letter (Nov. 5, 2024)
• There’s an accountant shortage. KPMG says the ‘150-hour rule’ needs to go (Oct. 28, 2024)
• EY, PwC voice cautious support for 120-credit hour CPA licensure (Oct. 18, 2024)
• Deloitte joins backers of 120-credit hours CPA licensure option (Oct. 14, 2024)
• KPMG US chief calls for urgent reform to halt slide in accounting ranks (Oct. 9, 2024)