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 competencybased 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 .

Jason Fox is CalCPA ’ s vice president of advocacy and public affairs . You can reach him at jason . fox @ calcpa . org .

20 CALIFORNIA CPA JANUARY / FEBRUARY 2025 www . calcpa . org