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Beyond Borders: The Complexities of CPA Mobility

April 22, 2024

by Andrew Brajcich, CPA, JD, LLM

CPA mobility is increasingly in the spotlight. Mobility gives CPAs the ability to practice in jurisdictions outside of the jurisdiction(s) in which they are licensed. For example, as a Washington CPA I can provide services in California without being required to apply to the California Board of Accountancy. As a profession, we are fortunate to have mobility across all 55 jurisdictions except one, Hawaii. This is possible through a concept known as substantial equivalency. That is, each jurisdiction has agreed to accept all other jurisdictions’ CPA licensure requirements as substantially equivalent to their own. (1) Thus, a licensed CPA from any jurisdiction has met the standards of nearly all other jurisdictions. Or at least something close to their standards. There are variations in rules across jurisdictions, such as when a candidate can begin taking the CPA exam, years of experience required, specific educational courses required, and hours of ethics needed.  

Generally, to become licensed as a CPA, a candidate must complete 150 semester credits, pass the uniform CPA exam, and work for a year. This is often referred to as the “universal pathway.” According to some, this is the cornerstone of substantial equivalency and without it, mobility collapses. Without mobility, many CPAs will be restricted from practicing across state lines at potentially economic and professional risk. There are, however, currently some circumstances that still qualify as substantially equivalent without requiring a candidate to obtain the 150 credit hours.  

In New York, candidates with 15 years of experience can bypass the 150-credit hour rule and take the exam. In Ohio, candidates do not need to complete 150 credit hours if they score 670 or higher on the Graduate Management Admission Test (GMAT). Also in Ohio, 60 credits with a two-year degree will suffice if the candidates have four years of experience and score at least 670 on the GMAT. In South Carolina, candidates serving in the military can count executive education toward their 150 hours. And in Nebraska, candidates can use experience “in lieu of” college degrees. (2) The question that begs to be answered here is, why haven’t these exceptions torpedoed substantial equivalency already? Alternatively, why would an alternative pathway similar to that proposed in Minnesota (3) be any different than these long-established exceptions?

In response to the CPA pipeline crisis, the AICPA formed the National Pipeline Advisory Group (NPAG), of which our very own President & CEO Kimberly Scott is a select member, and NASBA formed the Professional Licensure Task Force. Both groups’ work continues, with plans expected from NPAG in May and NASBA’s task force in October.  

NPAG is examining the licensure model as well as larger pipeline issues, while NASBA's task force is only addressing the licensure model. NASBA’s response is meant to be just-in-time/rapid or reactive response to what is happening legislatively around the US at this moment, while NPAG is looking at broader, long-term solutions. There is potential for the two groups to align around the licensure model process. While many have expressed that the work is reactive and late to the table to fix issues, I am hopeful when I hear Kimberly state that all potential solutions are on the table and robust, meaningful discussions are happening.  

I hope that the solutions or outcomes proposed from the group or task force look beyond the issue of keeping everyone happy and work toward creating outcomes that will modernize the licensing process and make it more appealing to the next generation. This is a noble and worthy profession, and we need to attract and keep talented people.

  1. This determination is made at the jurisdiction level. In Washington, our State Board of Accountancy makes decisions around this.
  2.  Nebraska Revised Statute 1-136.04.

2023-2024 Chair of the Board of Directors, Andrew Brajcich, CPA, JD, LLM, is the Jud Regis Endowed Chair of Accounting, Graduate Accounting Director, and Professor of Accounting at Gonzaga University. You can contact Andrew by email.

This article appears in the spring 2024 issue of the Washington CPA magazine. Read more here.

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illustration: © iStock/hurca