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Rule Update: Board of Accountancy Approves 120-Credit Hours to Sit Rule — What's Next

Dec 9, 2021
Students taking the CPA Exam
11/2/22 Update: The 120-Credit Hours to Sit for the CPA Exam and Exam changes rule is now effective. To learn more visit incpas.org/120.

The INCPAS advocacy team is excited to announce the Board of Accountancy reviewed and approved the proposed 120-Credit Hours to Sit for the CPA Exam and Exam changes draft rule.

A request now goes to the Office of Management & Budget and then the Governor's office for their additional review of the rule. We will keep you posted as the rule goes through "promulgation" — the process of putting a regulation into effect — which can range from 12-18 months.

Once the rule is finalized, it will be a crucial win for removing barriers of time and expense for students who wish to pursue the CPA license. Review the four reasons behind the change to 120-Credit Hours.

"Most states — and all the ones adjacent to Indiana — have already adopted this rule, so there's a competitive barrier there," said INCPAS Government Relations Advisory Council member Tom Bayer, CPA, CExP. "In addition, colleges and universities are starting to plan curriculums so that in their fifth year, students can start focusing on the CPA Exam. This would enable more students to come out of college with the CPA Exam partially or fully completed, which would be huge for our profession."


Bill Background & Details

In 2021, allowing candidates to sit for the CPA Exam at 120-credit hours, while still requiring 150-credit hours for licensure, was a priority of the Indiana CPA Society’s legislative agenda. As one of only 9 jurisdictions that still required CPA Exam candidates to have 150-credit hours to sit for the CPA Exam, it was important we act to address this barrier to the profession.

HB1373 was authored by Rep. Heath VanNatter (R- Kokomo) and went on to be sponsored in the Senate by Sen. Andy Zay (R-Huntington). The bill also requires the rule to remove Exam windows and section names and to allow continuous testing and retesting, bringing Indiana into alignment with Exam and CPA Evolution changes. The Society successfully lobbied for this bill, and Governor Holcomb signed HEA1373 on April 15, 2021.

While it’s an important advocacy win and a time to celebrate a successful legislative session, there is still more work to do. Although the 120-to-sit bill and Exam changes bill is now law and the draft rule is approved by the Board of Accountancy, students cannot begin sitting for the Exam at 120 hours, yet.

There is an additional hiccup in this process. Since 2013, there has been a gubernatorial moratorium on rulemaking in Indiana to “cut down on red tape.” So how does a rule get made if there is a moratorium on rulemaking? This is one of the reasons the Society worked on legislation that would require the rule to be made. With this approval by the board, a request for an exception to the moratorium from the Governor is filed with the Office of Management & Budget.

Over the summer, the Society’s Government Relations Advisory Council members worked with the Indiana Board of Accountancy to draft the rule and start the process. The draft rule has to be in as near final form as possible to be approved as an exception to the rulemaking moratorium. Following the Governor’s approval, the Board of Accountancy will issue a Notice of Intent to Adopt a Rule.

Once a Notice of Intent is filed, there will be approvals of fiscal and financial impact and a time for public hearing and public comment. Finally, the Office of the Attorney General and the Governor’s Office will review and approve the rule.

As you can see, it’s a process and one that will take some time. As the Society works with the Board of Accountancy, we will keep members updated on the progress, and when students are finally allowed to sit for the CPA Exam at 120-credit hours, we will let students, educators and Indiana CPAs know.


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