Board of Accountancy Finalizes Rulemaking Package Regarding the Definition of Satisfactory Evidence of Educational Requirements

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By Frannie Winters

At its January 21, 2022, meeting [Agenda item XI.A.], the California Board of Accountancy (CBA) considered the public comments received regarding its proposed amendments to section 2.8, Title 16 of the CCR to streamline the Board’s process for receiving evidence of educational requirements from applicants for licensure. The CBA published notice of its intent to amend this section on November 12, 2021. [27:1 CRLR 134] According to the initial statement of reasons, the proposed revisions would provide added flexibility in how educational documentation can be submitted for admission to the CPA Exam or to obtain a CPA license, and potentially decrease the Board’s timeframe for processing licensure applications.

The proposed amendments will allow for applicants to obtain and submit certified transcripts directly to the CBA with their applications. It will also eliminate steps that require educational institutions to print and mail transcripts to CBA and further allow CBA’s application system to quickly pair transcripts with individuals’ applications.

The 45-day public comment period for this rulemaking action ended on December 28, 2021, and a public hearing was held on the same day. At its January 21, 2022 meeting, the Board considered one written public comment received. According to the meeting materials [Attachment 4], the comment requested that the provision dismiss “any and all foreign education credits, certificates, diplomas, and the like from the agenda for inclusion as passable . . . accounting preparation work . . . .” The Board rejected the comment because it was outside of the scope of the proposal which relates to the method and form in which the CBA will accept documentation of educational qualifications.

During the meeting, a board member suggested that the regulatory language specify the envelope must be sealed by the educational institution. The Board voted to reject the specification because they believed the clarification would add unnecessary language to the regulation, and that people would understand the regulatory language without it.

Ultimately, the Board voted to adopt the proposed amendments as written without modification and authorized staff to prepare the final rulemaking package. At this writing, the proposal is pending Office of Administrative Law approval.

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