CalCPA submitted comments on the proposed CPA Competency-Based Experience Pathway (CBE Pathway) and related revisions to the Uniform Accountancy Act (UAA) developed by the AICPA and NASBA.

While we commend the AICPA and NASBA for their efforts to address pipeline challenges and pursue alternative paths to CPA licensure, we believe the proposed changes do not meet current and future needs of the profession and the public it serves.

Key Issues with Proposed CBE Pathway

CalCPA emphasized the proposed CBE Pathway introduces unnecessary complexity and lacks sufficient validation to support its use in a licensure framework. We also expressed disappointment that the proposed UAA changes fail to sufficiently modernize the CPA interstate mobility framework to better accommodate changing licensing requirements.

Our letter identifies several concerns with the proposed CBE Pathway:

1. Lack of Validation: We noted that the pathway is not supported by a dedicated practice analysis, which is essential to ensure the competencies reflect the actual needs of newly licensed CPAs and align with public protection mandate of state boards of accountancy.

2. Excessive Complexity: The pathway risks creating additional barriers by introducing vague competency requirements, ambiguous performance indicators and subjective assessments.

3. Limited Accessibility: Smaller firms and candidates in less diverse roles may struggle to meet the pathway’s requirements, potentially deepening existing disparities in the profession.

4. Subjectivity Concerns: The absence of clear standards for competency evaluation raises fairness and consistency issues, which could lead to varying interpretations by employers and state boards.

Recommendations

We recommended interim steps to simplify the current framework to make licensure more accessible and appealing to prospective CPAs. This approach aligns with California’s efforts, where CalCPA is collaborating with the California Board of Accountancy on a legislative proposal to modernize provisions, strengthen the mobility framework and introduce a licensure model that supports multiple pathways into the profession.

By focusing on flexibility between licensing pathways and mobility rules, this proposal ensures seamless interstate practice and offers candidates greater flexibility in meeting requirements.

Aware of national discussions, the proposal incorporates built-in adaptability to include competency-based concepts as they evolve, leveraging a lengthy legislative process to refine and integrate exposure draft concepts once finalized.

These immediate changes can help build momentum while additional analysis is done to better inform the development and implementation of long-term licensing changes that incorporate competencies to support a “future-proof” licensing model.

Concerns with UAA Revisions

CalCPA also relayed concerns that the proposed UAA changes missed an opportunity to enhance the flexibility and adaptability of the CPA interstate mobility framework. Instead, the proposal’s rigid adherence to “substantial equivalency” requirements could undermine mobility for candidates pursuing alternative pathways and impose unnecessary burdens on state boards.

CalCPA urged NASBA and AICPA to decouple mobility rules from licensure standards and adopt a more inclusive and forward-looking approach. The letter highlighted California’s efforts to implement an open mobility framework as a model for balancing consumer protection with flexibility.

Moving Forward

CalCPA is committed to working with national and state stakeholders to advance meaningful licensure reforms, which includes our ongoing partnership with the CBA to develop a legislative proposal that modernizes CPA mobility and licensure, while maintaining alignment with national efforts.

Making Progress in California

CalCPA continues to work with the CBA on its proposals to support CPA licensure changes to support California consumers and aspiring CPAs. The latest episode of the CBA’s “Accounting for California Podcast” features CBA Executive Officer Dominic Franzella and CalCPA President and CEO Denise LeDuc Froemming, CPA discussing the licensing and mobility changes approved by the CBA, and the partnership the two organizations had as the proposals took shape.

We expect legislation to be introduced in 2025 to move forward with these changes. Continue to monitor CalCPA and CBA communications for the latest updates on this important initiative.