Comment letter submitted on November 25, 2024, to:

• AICPA/NASBA Joint UAA Committee
• AICPA Leadership and Board of Directors
• NASBA Leadership and Board of Directors

The Indiana CPA Society (INCPAS) appreciates the opportunity to provide comments on the proposed amendments to the Uniform Accountancy Act (UAA) as issued in the September 30, 2024, Exposure Draft. INCPAS recognizes the importance of modernizing the CPA licensure process to address the talent pipeline challenges while maintaining the high standards of the profession and public trust.

After nearly two years of internal discussion and debate, our board of directors and government relations advisory council (GRAC) agree: additional pathways to licensure should be pursued and validated. These varied pathways, so long as they include analogous combinations of education from an accredited college/university, professional experience, and uniform examination, help remove unnecessary barriers.

At the same time, we believe that we must avoid, when at all possible, adding unnecessary barriers that don’t add value for the candidate, profession or public. It is these positions that shaped our comments. While the concept of a competency-based education (CBE) pathway has potential, the proposed CBE Pathway raises significant concerns:

• Complexity and Accessibility: The pathway introduces additional complexity, which may confuse candidates and deter participation. Research shows navigating the pathway to licensure is already a huge barrier for candidates considering pursuing a CPA. Current complexity would be further exacerbated by the proposed CBE pathway. In addition to the vague, checkbox attestation that fails to meet common CBE standards; the fact that the requirement only applies to one of three candidate scenarios, will be difficult to explain. This inconsistency creates confusion and a needless barrier for candidates as they navigate licensure options. Such complexity undermines efforts to broaden the pathways to licensure and is particularly problematic as the profession competes with other career opportunities for talent. A streamlined and clear pathway is critical for enhancing access and reducing candidate attrition.
• Subjectivity and Consistency: Evaluating subjective competencies such as ethical behavior and teamwork introduces variability, which can undermine the reliability and fairness of licensure decisions. CBE is typically designed to rely on clear, outcome-focused standards with well-defined performance indicators. However, the proposed pathway lacks the structured and measurable approach that is usually associated with CBE frameworks.
• Administrative Burden: Administrative Burden and Evaluator Challenges: The proposed pathway adds significant new responsibilities for boards of accountancy and CPA evaluators, making implementation difficult without major investments in resources and training. Boards would need to create and manage new systems to evaluate competencies, train evaluators consistently, and ensure they have enough staff and tools to oversee the process. This would require a lot of time, money, and effort to get right.
  
  CPA evaluators face challenges under this system. Assessing subjective qualities like ethical behavior and teamwork is difficult because these areas are hard to measure consistently and fairly. Evaluators have shared concerns about being held responsible if a candidate they approve later acts unethically, which could harm the evaluator’s reputation. These concerns could discourage evaluators from participating and make the system less reliable.

A more robust dialogue on this subject lies in our response to the pathway’s exposure draft attached to this submission.

INCPAS recommends following an analogous approach across the proposed pathways. We believe a simplified approach—a bachelor’s degree, two years of professional experience, and passing the CPA Exam—would meet the needs of the profession while also protecting the public interest. This approach would ensure clarity, accessibility, and—most importantly—consistency across jurisdictions.

We are particularly concerned that the UAA proposal falls short in addressing the critical issues outlined in Section 23. The current UAA links substantial equivalency with both mobility and reciprocity, and the proposed amendments suggest maintaining that connection. While we would support the many calling for automatic mobility, we believe this is only a partial solution to the issues at hand. Universal mobility addresses the ability of CPAs to serve clients across state lines without obtaining additional licenses, but it does not resolve the challenges tied to reciprocity.

Reciprocity—the ability to relocate and obtain a license in another state—would still depend on the proposed definition of substantial equivalency, which raises concerns about fairness, consistency, and administrative burden. The language in this exposure draft would, we fear, create barriers for licensees from a jurisdiction that has adopted alternative licensure pathways, such as our proposed pathway of a baccalaureate degree, two years of professional experience, and passage of the CPA Exam. These candidates would face additional evaluations to prove they meet substantial equivalency, even if they were originally licensed under similar pathways. This inconsistency undermines equity and creates unnecessary complexity.

Further, we oppose including the National Qualification Appraisal Service (NQAS) in model rules or legislation. NQAS is a service provider, not a regulator, and delegating regulatory authority to NQAS dilutes the power and accountability of state boards of accountancy. The inclusion of NQAS risks creating a fragmented system where regulatory decisions are outsourced, rather than being made by the entities directly responsible for public protection.

To address these concerns, we recommend decoupling mobility from substantial equivalency and adopting universal mobility language that allows CPAs in good standing to practice across jurisdictions without additional licensure requirements. For reciprocity, we urge reconsideration of the proposed definition of substantial equivalency to ensure fairness, simplicity, and alignment with the evolving needs of the profession. By taking these steps, the UAA can modernize the licensure framework while addressing the challenges of both mobility and reciprocity in a balanced and equitable manner.

INCPAS is committed to collaborating with NASBA, AICPA, and state boards of accountancy to facilitate necessary changes, ensuring that the UAA continues to serve as a relevant and effective framework for the regulation of the profession.

We thank the Joint UAA Committee for the opportunity to provide feedback and look forward to continued collaboration to strengthen the CPA profession.

Sincerely,

Courtney Kincaid, CAE
INCPAS President & CEO

Kyle Simmerman, CPA
INCPAS Board Chair