March 22, 2023

TO: NASBA UAA Committee

FROM: Alabama Society of CPAs Board of Directors

The Alabama Society of CPAs Board of Directors (the “ASCPA Board”) appreciates the opportunity to comment on NASBA’s proposed amendments to Rule 5-7 that would increase the length of conditional credit from 18 months to 24 months.

Based on many conversations with members, educators, and colleagues, we respectfully request that NASBA consider three suggestions:

• Conditional Credit Length – The provision that once a candidate has successfully passed one section of the CPA Examination, the candidate will be allowed a rolling period of no less than 36 months to successfully pass the remaining sections of the examination.
• Conditional Credit Commencement – We would also like to recommend that the credit period begin with the date the first passing section score(s) are released by NASBA to the candidate or board.
• Rule 5-7(e) - The ASCPA Board agrees that the period to pass all sections of the CPA examination may be extended by the Board of Accountancy if the candidate shows that a credit was lost by individual hardship meeting the criteria proposed, health, military service, etc.

Basis

The ASCPA Board appreciates that we are in unprecedented times regarding the pipeline. As a testament to the importance of this conversation, our entire board devoted time during the busiest season to take advantage of this opportunity to provide input and insight. Instead of approaching this as a pipeline “problem”, we strove to approach it as a pipeline “opportunity”. We encouraged our board to be open-minded.

As we asked our Board to be open-minded, our conversations included concepts as unconventional as “why have any time-limit?” and “why not 48 or 60 months?” While we appreciate any extension of the timeframe, there was an appetite from our board to extend well-beyond the 24-month window.

From the candidates’ perspectives, we often hear that candidates would benefit from a longer window because of:

• Life events – Candidates face many life events upon graduation. For the student who has not completed the exam by the time they graduate, a move, a career start, getting married, and other life events may directly affect the candidate's ability to complete the CPA exam – especially with all these items occurring in such a short window.
• Work-load demands – For many who are working full time, the period of January – April, studying for the exam is difficult if not impossible. If they are working in public accounting, the months of September and October have also become an “extension busy season”. This means studying or sitting for the exam is very difficult for between four and six months of a candidate’s year. The irony that the pipeline issue creating this conversation exacerbates this timeline crunch is not lost on even the most casual of observers.

From a candidate’s perspective, given the life events and workload demands, the current rule of eighteen months or even the proposed twenty-four months is simply not enough time because they lose somewhere between one-third and one-half of their year with work demands alone. Students have commented that they would appreciate a 36-month opportunity; the added time could make a difference in the ability to complete, or make significant progress towards completing, the CPA examination. We also believe that by allowing a 36-month credit period will retain some candidates who drop out entirely because they do not have enough time to finish all four exam parts, or lose a credit, under the current rule.

Alabama accounting faculty shared a preference of 36 months. To quote a University of North Alabama professor, “I do not think there has ever been any empirical studies done to determine why 18 months is the correct period. The decline in the number of CPAs is already having detrimental effects on the business community. The profession should remove barriers to entry, such as the 18-month rule, that are not grounded in solid logic. CPA Evolution is focused more on skills and application than previous exams. An individual does not “lose” their skills in an 18-month window. They may forget facts they memorized, but memorization is not the focus of CPA Evolution.”

We do not believe the decision to move to a 36-month credit period would harm the public interest. As noted above, we concede that we are unaware of any empirical studies or data indicating that extending the 18-month credit period time limit will have a direct causative effect of increasing the number of CPAs. We seem to all agree that keeping it shorter creates a direct threat of losing candidates because they do not have enough time to complete the four CPA Exam sections. If the public interest is unaffected, then we believe the risk of losing CPA candidates far outweighs the opportunity to allow more time to complete, such as our recommended period of no less than 36 months.

Conclusion

In summary, if someone is actively trying to complete the exam, why would we want to stop them? What is the purpose? What does our profession gain? If a candidate is actively putting forth the requisite effort and incurring the costs (both time and expense), then what does the profession gain by stopping their progress and making a candidate re-start. We do not see any reason to deter someone who is actively trying to achieve their goal.

The ASCPA Board appreciates the opportunity to provide input into your decision-making process regarding this important proposal. We appreciate your efforts to provide the best path forward for the profession.

Sincerely,

Jeannine P. Birmingham, CPA

President & CEO, Alabama Society of CPAs