By Connor Greth

At its January 14, 2021 meeting (Agenda Items II. A and B (recording)), the California Board of Accountancy (CBA) heard an update from representatives of the National Association of State Boards of Accounting (NASBA) and the American Institute of Certified Public Accountants (AICPA) regarding a pilot program for a remote-proctored CPA Exam that they are administering in partnership with test-center administrator Prometric. The representatives reported that exam testing centers were shut down from March 18 through April 30, 2020, due to the Covid-19 pandemic, and have since been restricted in their capacity. Due to the delays, they have temporarily extended the period within which candidates must successfully pass all sections of the CPA Exam. The pilot remote proctored exam is a proposed solution for the Covid-19 pandemic and similar future emergencies. It would utilize Prometric’s ProProctor web-based application to allow the CPA Exam to be taken outside of a testing center using human proctors and artificial intelligence to monitor the administration. The pilot is set to begin in the second quarter of 2021.

After the presentation, Board members expressed their concerns and asked questions of the presenters with respect to the security of the web-based exam, bathroom breaks, and internet connectivity. The presenters explained that they are doing their best to replicate the in-person security measures when administering the remote exam. For example, the exam check-in identification process involves a remote human proctor and requires a webcam that can be used to scan the test-taking room. Then a proctor observes the test-taker throughout the examination, and artificial intelligence is also used to flag unusual circumstances. The proctor can stop the test at any time and ask the test taker to rescan the room.

Following the January meeting, Colleen Conrad, Executive Vice President and Chief Operating Officer of NASBA, sent a letter to all Accountancy Board Chairs and Executive Directors, including CBA, following up on a white paper and FAQs about the pilot program, and asking each board to advise whether it will accept CPA exam scores from the pilot project to maintain uniformity among all jurisdictions.  Accordingly, the Board considered this issue at its March 25, 2021 meeting (Item II.L (recording)).  In its memo to the Board (p.52), staff reported that although there are no California candidates participating, candidates from other jurisdictions participating in the pilot tests may seek licensure in California.  After consultation with legal counsel, staff prepared a draft response to Ms. Conrad for the Board’s approval, advising NASBA that the Department of Consumer Affairs legal counsel conducted a review of California statutes and did not find any statute that would authorize the Board to refuse to accept scores from the pilot administration of the CBA exam if the AICPA determines them to be valid (p. 85).  Therefore, the letter advises that California will accept scores from candidates participating in the remote testing pilot for CPA licensure in California. After a brief discussion, the Board voted to approve the letter and send it to NASBA as written.

It is worth noting that staff included a Supplemental Memo in the agenda materials (p. 86) addressing an article in the Professional Licensing Report regarding the American Civil Liberties Union (ACLU) of Northern California’s critique of remotely proctored exams. According to the ACLU, as they exist now, remotely proctored exams are inequitable for misidentified minority groups and for those who live in small dwellings and also raise concerns over the security and privacy of personal information. The memo suggests that these concerns will be considered when making future decisions with respect to the remote administration of exams. While the Board is keeping abreast of new developments in the licensing exam, such as the CPA Evolution initiative, which is expected to launch a new Uniform CPA Exam in 2024, at this writing there is no indication as to whether the exam will be offered remotely.