Announced February 13, the AICPA and NASBA are giving up the quixotic fight to maintain 150 hours of education as the sole standard across CPA jurisdictions and are now “advancing model legislative language that enables an additional path to CPA licensure.”
As has already been made law in Ohio recently, the alternate pathway option doesn’t eliminate 150 hours entirely, rather gives aspiring CPAs another option.
The optional path maintains the license’s integrity and protects the public while providing flexibility in response to stakeholder demand.
The organizations asked the joint Uniform Accountancy Act (UAA) committee to draft proposed model law language in two key areas:
- A bachelor’s degree plus two (2) years of experience pathway to licensure that incorporates a broad role for experience, to be determined at the state level.
- Individual-Based Practice Privilege that incorporates a CPA’s ability to practice across state lines.
Comment letters submitted on two recent AICPA and NASBA exposure drafts, as well as early 2025 state legislative activity indicate a growing preference for an individual practice privilege and a bachelor’s degree plus two (2) years of experience path. Feedback also supported a more in-depth study of competencies as they relate to the experience requirement.
The newest proposal follows a late-2024 exposure draft that proposed a few changes to the UAA that would:
- Facilitate adoption of an additional, Competency-Based Experience Pathway
- Protect seamless interstate practice for CPAs
- Specify the education requirement to sit for the CPA Exam
- Clarify the process by which a CPA can practice under mobility
This most recent amenability to change comes almost two years to the day after then-CEO of NASBA Ken Bishop dug his heels in in a Journal of Accountancy interview and warned rogue states considering alternate pathway proposals that they’d cause real trouble making state-specific changes “that could damage both the public and the profession.” Although stubborn about changing rules at all, Bishop did say at the time that they’re open to discussing a change, just that they wanted it to be across the UAA and not only in certain rebellious Midwestern states (*ahem*, Minnesota).
Here’s what he said in the JofA interview:
“Should any state or jurisdiction lower the licensure requirement to 120 hours, their CPAs would no longer be automatically substantially equivalent and would no longer enjoy the mobility and reciprocal practice privileges they currently are afforded,” NASBA President and CEO Ken Bishop said in an interview with the JofA. “Lowering the bar to 120 hours is only one of the alternatives we have heard that has been discussed and considered. Others, including lowering the cut score for passing the CPA Exam, have the potential and risk of creating the perception of dumbing down the profession. No one is talking about, for example, lowering the bar to become an attorney, and they’re also suffering from lack of entry.”
Well Ken is gone now (deuces!) and here’s what his replacement had to say about the new proposal:
“We look forward to the expertise and perspectives the 55 U.S. licensing jurisdictions will share during this next comment period,” said Daniel J. Dustin, CPA, President and CEO of NASBA. “We believe that any new proposal, and the feedback received from all stakeholders, will not only result in a thriving profession but also one that, because it keeps its eye on protecting the public, will allow that public to continue to trust in a CPA’s work.”
The new proposal is open for public comment for 60 days.
Anyone in practice or academia — current or former — is welcome to submit a letter to the editor with your thoughts should you want to share them with us and potentially the audience.
AICPA and NASBA Advance Public Protection-Focused and Market-Responsive Model Licensure Legislation [AICPA]
Wait: It’s vital to the profession to maintain those 150 hours!
It’s mind-boggling how 150 ever got passed in the first place. Had they added a 30-credit requirement to the 120 hours to require courses like “Enron: A Case Study,” or “Accounting Theory, Not Rule Memorization,” or “Accounting Systems,” or “Excel for Accounting,” or even “History of Accounting,” I could see it. But no one could ever successfully defend 30 extra credits when those 30 credits could be in ANYTHING. Pure silliness. There was a serious case of group-think going on when that was passed. Just goofy.
Considering that it took forty years for the profession to recognize specialties as delineated in the exam, backing out of the 150 hour rule has come about pretty quickly. The accounting pipeline has been drying up over the last ten years.
Now firms need to bill for the assurance an audit provides the way insurance companies charge… and that is NOT by the hour.
It still drives me nuts when I see a return to 120 and 2 years referred to as “lowering the bar”. The bar was lowered dramatically when the 150 / 1 year requirement was codified.
The extra course hours do nothing for the profession, unless they are a mock audit engagement/bookkeeping to tax return simulation. I need people who understand how to do the work and how to critically think. You can teach someone to work backwards and audit work that they know how to perform.