It’s not a secrete that the CPA profession in the U.S. has a pipeline crisis. Many attribute (at least in part) the problem to the 150-credit hour requirement to be licensed as a hurdle to prevent college students from choosing accounting as a career. 150-credit requirement is not perfect – I believe the original idea is to create that “professional” image by mimicking what the medical and legal professions do to prepare their next generation lawyers or doctors. Many can argue that goal was not achieved after a decade of implementing this model. In this exposure draft, AICPA and NASBA proposed an alternative pathway for students to be licensed as a CPA. You can find a copy of the exposure draft here.
It is concerning that this draft exposure devalues the importance of formal education. The proposed additional pathway suggests that 30 additional credit hours of formal education could be substituted with one extra year of work experience verified by a CPA using the “competency framework”. This equivalence is questionable, as a formal education provides a structured learning environment, rigorous coursework, and critical thinking development that cannot be fully replicated through on-the-job experience. The recent updates to the CPA Exam (CPA Evolution) have increased the emphasis on substantive knowledge and skills required of CPAs. Reducing the amount of formal education while simultaneously raising the bar for professional competence creates a paradoxical situation. It is unreasonable to expect candidates to be adequately prepared for the more rigorous CPA Exam without the foundational knowledge and skills developed through a robust educational program.
Additionally, many students currently utilize their final year of undergraduate study, during which they pursue the extra 30 credit hours, to dedicate themselves to CPA Exam preparation. Research indicates that post-graduation delays in taking the exam often result in lower pass rates, as life commitments and work responsibilities can hinder effective study time. If students are forced to postpone exam attempts due to immediate post-graduation employment, without the dedicated study time afforded by a fifth year of education, the overall CPA Exam pass rate is likely to decline. This could ultimately lead to a less qualified pool of CPAs entering the profession.
Another critical factor to consider is the potential impact on public trust. If a bachelor’s degree were to be reduced to 90 credit hours (as some colleges in the U.S. are exploring), it would further diminish the educational requirements for CPAs. This raises concerns about whether the public would continue to view CPAs as highly qualified professionals capable of providing complex financial, tax, and consulting services.
Another issue that’s even more concerning is the use of the competency framework in the additional licensure pathway. The proposed competency-based approach, which relies on supervisor assessment and a simplified evaluation process, raises concerns about the adequacy of assessing candidates’ readiness for licensure. Accredited higher education institutions go through rigorous processes to develop the assessment of academic programs. Replacing the assessment programs often adopted by reputable academic programs and traditional academic rigor of coursework and grading with a simple yes/no questionnaire undermines the quality assurance necessary for protecting the public interest. “Check the box” form is not the same as formal education and can be gamed easily.
It is also not logical to expect a 25 or 26-year-old CPAs to accurately assess the competencies of a 22 or 23-year-old candidate. Implicit and explicit biases could significantly influence these evaluations, potentially leading to unfair assessments. Also, there’s no accountability in such evaluations. Will the evaluators be liable in the future since CPA is a regulated profession?
It is crucial that any alternative pathway to CPA licensure maintains the high standards of education and professional competence that have historically been required. Diluting these standards could compromise the integrity of the CPA designation and potentially harm the public.
Pentastic 