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CPA License Mobility Implemented in 11 States; Michigan Moves Forward

Mobility remains the accounting profession’s top state legislative priority in 2008, as efforts proceed to remove unnecessary barriers that prevent CPAs from providing timely service to clients in different states.

Thanks to thoughtful, collaborative hard work by the MACPA and other state societies, the National Association of State Boards of Accountancy (NASBA), the Accountants Coalition (TAC) and the AICPA, CPA mobility efforts achieved important traction in 2007.

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Seven states, beginning with Tennessee and followed by Texas, Illinois, Indiana, Rhode Island, Maine and Louisiana, adopted a revision to Section 23 of the Uniform Accountancy Act (UAA) that allows a CPA licensed in another state to serve a client in its state without the need to provide prior notification. Additionally, licensees and firms using this practice privilege would fall under the automatic jurisdiction of the state board. These states joined Ohio (1961), Virginia (1999), Missouri (2002) and Wisconsin (2006) in recognizing that a CPA who is licensed in one state can serve a client in theirs while fully protecting the public interest – without the need of time-consuming and repetitive registration requirements that often do nothing to protect the public interest.

This year – 2008 – (exactly a decade after “substantial equivalency” was introduced into the UAA in 1998) is a critical year for efforts in state capitols from Boston to Lansing to Honolulu to provide CPA licensees the mobility they need in today’s electronic age.

Mobility legislation is pending in Pennsylvania, Massachusetts, Delaware, Hawaii and Oklahoma, and efforts to introduce bills are underway across the country in at least 15 states. Enacting mobility legislation in these states would mean the profession is nearly half way toward true mobility between all 55 U.S. jurisdictions.

In Michigan, a Mobility Committee comprised of representatives from the MACPA, the State Board of Accountancy, the Michigan Department of Labor & Economic Growth and NASBA was developed in 2007 and met several times to begin the pursuit of mobility legislation. Following a State Board vote to support the concept, actual legislation is being drafted to implement Section 23 of the UAA into Michigan law and is expected to be introduced in the first quarter of 2008.

“We’re really talking about that temporary practice privilege, meaning the opportunity to come into a state that is not your normal home state or place where you have an office, and take care of client needs,” said Scott Voynich, CPA, who chairs the AICPA’s Special Committee on Mobility.

Putting substantial equivalency into the UAA ten years ago meant that any state requiring the “three E’s” (the Uniform CPA Examination, at least one year of experience and completing the 150-hour education requirement) makes the state a substantially equivalent state and gives its licensees the ability to gain a practice privilege in another substantially equivalent state without a need for another license.

One critical area where substantial equivalency broke down is the notification requirement. According to Voynich, “The original language of substantial equivalency was to provide mobility for CPAs to move from state to state with what became known as ‘simple notification.’ Each state has added on different forms, fees and processes which have turned it into something that has just been totally unworkable.”

The irony of the added notification requirements is that rather than protecting the public, they actually are contrary to public interest.

“Public protection really has two sides to it,” says Ken Bishop, with the NASBA Mobility Task Force. “Number one is a state board’s requirement to regulate the industry and to investigate when something bad happens. The other part of public protection is ensuring that the citizens – the consumers of the profession – have the ability to use the CPA that they want.”


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