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Nov 23, 2018

Zero or 24? Understanding the New A&A CPE Requirements

By Michael D. Colgan, CEO and executive director


The PICPA has received inquiries from several firms regarding the interpretation of Pennsylvania’s new CPE requirements, which were effective Jan. 1, 2018. Specifically, firms are asking for clarification on which licensees are now required to obtain 24 CPE hours of accounting and auditing (A&A).

Figuring out A&A education requirementsGenerally, the new regulations eliminate the minimum eight-hour tax requirement for all licensees, but require 24 hours (increased from 16) of A&A credits for those CPAs 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 for all licensees. The changes allow licensees to select and complete CPE in the areas most related to their own professional development needs. The question firms have raised, however, is how to define “participating in attest activities” to determine whether or not licensees need to meet the expanded A&A requirement.

Examples raised have included a licensee who is a tax professional, but audits the tax provision included in the financial statements of a company; or a tax professional who completes an uncertain tax position checklist for a pass-through entity, corporation, or nonprofit, and may perform an analysis to determine if any uncertain tax position exists.

The PICPA requested clarification from the Pennsylvania State Board of Accountancy (SBOA) as to how to interpret the new regulations with respect to A&A. Here is the response, but in brief the SBOA is relying on the definition of attest activity in the CPA Law, but does not define the term “participating.”

From our discussions with the SBOA prior to these changes being adopted, I am confident that its intent on eliminating the minimum CPE requirements for A&A and tax for most licensees was to allow CPAs to determine which CPE would best help them maintain and build competencies in the areas in which they practiced. The SBOA included the 24 hours of A&A CPE for those participating in attest activities due to changes in the experience requirements to become a CPA, which no longer required a portion of the experience gained to come from the attest area. The intent, I believe, is not to require licensees who do not work in the attest area to increase their required A&A CPE from 16 to 24 hours.

The SBOA has verbally communicated that “participating” will likely be a firm-by-firm interpretation. Some firms may conclude that any service charged to an audit code defines participation, and will require their licensees to get 24 hours of A&A; others may deem the review of a tax provision as incidental and not fully participating in attest activity, so they will not require their licensees to get 24 hours of A&A.

The PICPA will work to add more clarity to the next revision of the CPA regulations, but that will not arrive prior to the end of the licensing period that concludes in December 2019.

Licensees will self-report on their license renewal applications in December 2019 on whether they participated in attest activities, which would trigger the 24-hour A&A requirement.

If you have additional questions, please do not hesitate to contact me.




6 comments

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  • Jill Kvalsvik | Dec 02, 2018
    As a CPA who currently specializes in individual income tax return compliance, i.e., 100% of my charge hours comprise of 1040 review, I always have close to 40 hours of Tax CPE annually.  The requirement to take up a full day each year for an A&A class about issues with no impact what so ever on the US expat & foreign national returns that keep the 1,000 professionals in my business unit busy is a waste of time & money. Most of my colleagues live in other states with no A&A requirements. Their professional competence is not comprised.  Nor will mine be now that I no longer have to take another “Accounting for Income Taxes” or IFRS Update” class!
  • Steve Geisenberger | Nov 28, 2018

     

    Mike,

    The blog needs some interim clarification.   By using the words "audit code" in your explanation you imply that those who do reviews and comps might be off the hook.  Unfortunately no such luck!  Please let us know if another definition for attest is operative.

    “Attest activity.” The provision of any of the following financial statement services together with the issuance of a report expressing or disclaiming an opinion or other assurance on the information: (1) an audit or other engagement performed in accordance with Statements on Auditing Standards (SAS); (2) a review or compilation of a financial statement performed in accordance with Statements on Standards for Accounting and Review Services (SSARS); (3) an engagement performed in accordance with Statements on Standards for Attestation Engagements (SSAE); (4) an audit or other engagement performed in accordance with government auditing standards issued by the Comptroller General of the United States; or (5) any other engagement performed in accordance with attestation standards established by an organization granted authority by statute or regulation to establish attestation standards, such as the American Institute of Certified Public Accountants (AICPA) or the PCOAB

  • Riaz Mullick | Nov 28, 2018
    I would not have changed anything and would have kept the minimum 16 A&A and the 8 tax.  How can an accountant be an accountant if the accountant does not update his A&A and Tax knowledge?
  • Joseph Schaeffer | Nov 28, 2018

    Pardon my ignorance but if I perform compilations only do I need 24 hours of A&A.  Thanks.

     

    Joe Schaeffer, CPA

     

  • Adam Drapczuk | Nov 28, 2018

    I respectfully disagree with the comment we should all have 24 hours of A&A because "it is the professional thing to do."

    By that logic we should still have the 8 Tax CPE requirement because the general public always assumes a CPA is a tax professional.

    I am perplexed as to why we would not have a more black and white definition of "participating".  I think most people would prefer something concrete even if it means a tax practitioner ends up earning 24 A&A hours they might not otherwise have to earn with a less clear definition. 

    I might also add if you are practicing in attest services you most certainly reach the minimum attest hours under the old rule, in which case why do we even have a new rule increasing A&A credits?  How many people truly perform attest services without first having worked under an Audit partner and/or Manager?

     

  • Anonymous Coward | Nov 28, 2018

    The purpose of a professional license is to indicate minimum competency in the practice of that profession by the licensee.

    Since accounting and auditing are the core functions of a CPA, whether involved attest activities or not, and that is the competency that we hold ourselves out to the public, end the questions about what constitutes "participating" and require 24 credits in A&A across the board.  

    Any CPA should obtain 24 credits in A&A whether or not "participating" whether or not it is legally required, because it is the professional thing to do.

     

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