Is CPA Mobility In Jeopardy?
On Dec. 14, 2023, the Journal of Accountancy published an article titled "AICPA Issues Guidance on Potential Mobility Changes."1 The article caught my eye immediately. I flashed back to years past when CPA expert witnesses always had to be aware of whether or not they could “practice” as a CPA in a state where they were not licensed without obtaining a temporary license. I have been a CPA since 1969, 54 years, and a testifying witness since 1980. Even as late as the 1980s, some states still did not have full mobility.
Marta Zaniewski, vice president, AICPA State Regulatory and Legislative Affairs, and her colleague, James Cox, graciously allowed me to discuss this perhaps burgeoning issue with them. Some states are considering legislation that might change the requirements to become a CPA in that state. Apparently most of the currently considered changes would modify or lessen the current requirements (see below).
According to the article, “CPAs in good standing with their state boards of accountancy presently benefit from practice mobility—a licensing system that allows CPAs to practice across state lines without having to acquire an additional license.” Mobility is currently guided by the concept of “substantial equivalency.” The concept is outlined in the article as follows:
Currently, to meet substantial equivalency standards, CPAs typically must have completed 150 credit hours of undergraduate or graduate-level studies, successfully passed the Uniform CPA Exam, and have accrued at least one year of relevant experience. CPAs who meet the standards for education, exams, and experience can practice both in person and virtually outside of the state in which they are licensed.2
The mobility issue could become serious if a person is licensed as a CPA in a state under rules that are less than the current “substantial equivalency” requirements, noted above. Most other states have more stringent requirements for a person licensed as a CPA who currently wants to practice in those states. So, in the near term, this issue might be a problem for newer CPAs. However, if more states diverge from the current rules, it could become a more widespread issue for valuation and litigation experts. It might revert to the old rules where, as experts, we had always to be aware of whether we needed a license to practice as a CPA in a state other than our state of residence and licensure. I remember having to obtain a temporary license in a couple of instances in order to testify.
Let us hope that “substantial equivalency” does not become a thing of the past. I would urge you all to stay aware of any proposed legislation regarding CPA licensure in your state and make it known to the legislators what the issue is if “substantial equivalency” goes away. I am not suggesting you oppose a legislative change to the CPA rules but that you emphasize the need to keep mobility not only for your state’s CPAs, but also for CPAs from other states doing business in your state. For valuation purposes, it is more than just if you are testifying in a matter. My understanding is that “virtual” practice would also be covered if you are engaged to prepare a valuation in another state even though you never leave your home state to perform the work. If you are putting yourself out as a CPA, then you technically would need to be licensed in that other state in order to perform the work as a CPA. If you performed the engagement and failed to get a license and the valuation became involved in some controversy or litigation, it could be detrimental to your defense if you failed to get a license in that other state.
To help CPAs with mobility issues that might arise, the AICPA has developed a website (aicpa-cima.com/news/landing/protecting-cpa-mobility) that explains further this issue and will be updated to keep you informed on issues that might arise regarding mobility.
If you have any questions or comments on this article, please contact me at info@bvresources.com.
1 Mari Sagedal, "AICPA Issues Guidance on Potential Mobility Changes," Journal of Accounting, Association of International Certified Professional Accountants, Dec. 14, 2023.
2 It is my understanding that current mobility allows licensed CPAs from a state to meet the “substantial equivalency” test as long as they met the requirements of their state on the date at which they were granted a license in that state.