Comment Letter

Baker Tilly comment on AICPA and NASBA proposed experience pathway

April 29, 2025

April 29, 2025

Thomas Neill, CPA
Chair, AICPA UAA Committee
American Institute of Certified Public Accountants
1345 6th Avenue, 27th Floor
New York, NY 10105

Dan Vuckovich, CPA
Chair, NASBA UAA Committee
National Association of State Boards of Accountancy
150 4th Avenue, North
Nashville, TN 37219

Via The Joint AICPA / NASBA Portal: 2025 Comment Form: Proposed UAA Changes

Re: Joint AICPA / NASBA UAA Committee Exposure Draft, Amendments to UAA Sections 5: Education Requirements and 23: Practice Privileges

Dear Mr. Neill and Mr. Vuckovich:

We appreciate the opportunity to comment on the proposed amendments to Sections 5 and 23 of the Uniform Accountancy Act (UAA) as included in the exposure draft referenced above

The proposed amendments are both timely and responsive to important issues currently facing the profession. We believe that allowing individuals with: 1) a bachelor’s degree with an accounting concentration (or equivalent) and 2) not less than two years of work experience (both as defined by the applicable licensing Board) a pathway to licensure would provide both necessary and appropriate increased flexibility to qualified CPA candidates while continuing to safeguard the public interest. Furthermore, we believe that transitioning from a mobility model predicated on jurisdictional-based substantial equivalency to one predicated on individual-based practice privileges would not only simplify the mobility process, but would also protect current and future CPAs from potential future state-specific licensure changes which, absent the proposed amendments to Section 23, could jeopardize their cross-jurisdictional practice privileges.

We appreciate the opportunity to provide the above comments and are available for further discussion with the Committee if that would prove useful to the process. Should you wish to discuss any of these comments, please contact David Johnson