Jun 29, 2015

State Board Proposed Regulatory Changes Impact CPE and Experience Verification

By Michael D. Colgan, PICPA CEO & Executive Director

Regulations image The Pennsylvania State Board of Accountancy (SBOA) published on June 13, 2015 proposed regulatory changes for CPAs to implement the two most recent amendments to the PA CPA Law (Act 73 of 2008 and Act 15 of 2013) and to clarify civil penalties for CPE violations. Included in the proposals are revisions to CPE requirements for all licensees as well as clarification for how a CPA candidate’s experience should be verified. More details are provided below, along with a link to the proposed regulations.  The comment period expires July 12, 2015, and PICPA will be providing a comment letter.

You will recall that in Act 15 of 2015, a general experience requirement replaced the previous requirement that every license obtain 25% of their required experience in attest services. In the proposed regulations, CPAs licensed by the SBOA after August 18, 2013 to supervise attest services and/or sign or authorize another to sign an accountant’s report for attest services, the licensee must have at least 400 hours of attest experience within the previous five years and at least 24 hours of CPE in the area of accounting, auditing, or attest during the immediately preceding 24 months of issuing the report. The licensee would also need to be a member of or employed by a firm that has met the peer review requirements.

The proposed regulations clarify the types of general experience permitted as a result of the passage of Act 15 of 2015 to meet the experience requirement for CPA licensure. In addition, the proposed regulations clarify who can verify an applicant’s experience. The verifier must hold a current CPA license during the entire period of the verification, either employs or is employed by the same employer as the candidate, or has a similar relationship approved by the SBOA prior to the period of verification. This final provision provides an opportunity for candidates who works for an entity that does not employ another licensee to seek approval from the SBOA to allow the relationship to serve to verify their experience.

With respect to CPE requirements, SBOA proposes to eliminate the 8 hour tax requirement for all licensees, and will require 24 hours of accounting and auditing credits only for those licensees participating in attest activities – licensees not participating in attest activities will have no A&A minimum.  The four hour biennial ethics requirement remains in place. This change will allow licensees to complete CPE in areas most related to their current professional development needs. The proposed regulations also outline a schedule of civil penalties for licensees who fail to comply with the biennial CPE requirements.

If you would like to review the proposed regulations in detail, please use the following links:

Understand that these proposed regulatory changes have been published in The PA Bulletin for comment and will not be effective until final promulgation after the comment period expires and comments may be addressed. The proposed CPE changes will not impact the current biennial license period expiring December 31, 2015. Licensees will still need to meet the current requirements when renewing your license (16 hours of A&A, 8 hours tax, 4 hours ethics, minimum of 20 hours per year). The PICPA has been actively engaged with SBOA during this regulatory process and will formally respond to the proposed regulations. If you have any thoughts or input please reach out to me in the next week.


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  • Michael Colgan | May 01, 2017
    Jim:  The State Board requirement can be looked at two ways - for a licensee who is going to issue their first attest engagement report, the licensee would be required to have obtained 24 hours of A&A CPE within the immediately preceding 24 months, or, the annual biennial requirement (24 months) will be for 24 hours of A&A for any licensee providing attest services to a client.  So, in a situation where there is an ongoing attest practice, a licensee would be required to have obtained 24 hours in the previous biennial period, and presumably probably attained even more A&A hours then that. What the Board was trying to address here was for newer licensees, that were nor required to meet an attest requirement to get licensed, to demonstrate that they had some recent A&A training before issuing a report.
  • James Newhard | Apr 27, 2017

    I am curious as to whether the SBOA is going to enforce the these requirements, and t=whether they will in accordance with the "letter of the law." Specifically, there is a provisions above that states that a CPA involved in the issuance of an attest report must have satisfied at least 24 hours of CPE of A&A within the 24 months just prior to the the issuance. Does this mean the previous biennial reporting 24 month period, and the exact calendar of 24 months prior to the report's issuance. My concern might be, depending on timing and how linear the CPA's CPE is, might not have had 24 A&A hours in the 24 months prior to the issuance of the report. Accordingly, I would be looking for some clarity, as trivial as it might seem.

    Jim Newhard


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