the slow, painful death of the 150-hour rule

ending a 50-year mandate, now “competency” counts (again).

by rick telberg
卡塔尔世界杯常规比赛时间 research

after a quarter century of campaigning to get the 150-hour rule passed by all 50 states, overcoming opposition that seemed at one time as if it would rend the profession’s institutions, and after another quarter century of finding that the rule was failing by all critical measures, the aicpa and nasba are rolling out a workaround that could kill the rule.

more 150-hour rule  | download the exposure draft

the organizations are offering a “competency-based” hurdle for cpa licensure that signals abject surrender.

this is the story, 50 years in the making, of (mostly) good intentions gone bad, unintended (but not unforeseen) consequences, and how rank-and-file cpas (eventually) overcame the power plays of multinational firms.

the aicpa and nasba are proposing the cpa competency-based experience pathway as a flexible option for cpa licensure while maintaining the necessary rigor. the goal addresses challenges such as declining cpa exam candidates, financial and time constraints in completing education requirements, and the need for evolving competencies due to an aging workforce.

key points of the pathway

the new pathway allows candidates to meet initial cpa licensing requirements by demonstrating competencies in professional and technical areas. candidates must still earn a bachelor’s degree, complete one year of general experience, and pass the cpa exam. the pathway was developed to address challenges in the cpa talent pipeline and is based on various frameworks and feedback from industry stakeholders. the intent is to create a competency-based licensure model that could be included in the uniform accountancy act.

proposed licensure requirements:

• candidates need a bachelor’s degree with relevant state board education requirements in accounting and business.
• candidates must have experience certified by a cpa evaluator, with acceptable work in industry, government, academia, or public practice over at least one year and 2,000 hours.
• an additional year of general experience is required, totaling at least 4,000 hours.
• completion of the cpa exam is mandatory.

the required competencies are divided into professional and technical. professional competencies include ethical behavior, critical thinking, communication, collaboration, self-management, business acumen, and a technology mindset. under technical competencies, candidates must demonstrate one of the three technical competencies—audit and assurance, tax, or business and financial reporting. under the new plan, cpa evaluators (licensed cpas with at least three years of experience) would certify that candidates have demonstrated the required competencies. candidates who work across different roles or employers may need multiple evaluators.

adoption of this pathway will vary by jurisdiction, as some boards of accountancy may need to update their laws. a five-year maximum period is proposed for candidates to complete the pathway. a nasba tracking system may be developed to report the completion of competencies.

comment until dec. 6

aicpa and nasba are seeking feedback on the pathway from various stakeholders until dec. 6, 2024. the questions aim to clarify the framework and competencies’ relevance, applicability, and sufficiency.

the proposed cpa competency-based experience pathway offers an alternative to the traditional 150-hour education requirement, typically involving obtaining a bachelor’s degree plus additional coursework or a master’s degree. under this new pathway, cpa candidates can meet licensure requirements by completing a bachelor’s degree and demonstrating their competencies through practical experience rather than completing up to 30 additional credit hours.

this does not eliminate the 150-hour rule but provides a parallel option. candidates must still fulfill the other requirements, such as one year of general experience and passing the cpa exa. still, the emphasis has shifted from formal education to competency-based experience.

the approach could make the cpa licensure process more accessible by reducing the financial and time burdens of earning the additional credit hours typically needed to meet the 150-hour rule.

ultimately, the pathway could address barriers to entry while maintaining the professional standards needed to protect the public interest, offering flexibility without compromising the quality and readiness of cpa candidates. however, implementation would vary by jurisdiction, and individual state boards of accountancy would decide whether to adopt this alternative pathway.

 

 

 

150-hour blamed for a host of ills

yes, the 150-hour rule has been identified as a challenge for many aspiring cpas and is considered a contributing factor to some key issues within the profession.

completing 150 credit hours often means pursuing additional coursework beyond a typical bachelor’s degree, which can require more time and money. this extra educational requirement can create financial barriers for students who may already be dealing with the high cost of undergraduate education. for some, this can mean delaying entry into the workforce or incurring additional debt.

the cpa profession has seen a decline in accounting graduates and new candidates taking the cpa exam, partly due to the extended education requirement.

the 150-hour rule can discourage some potential candidates from pursuing cpa licensure altogether, contributing to the current talent shortage in accounting, especially when many current cpas are nearing retirement.

the rule does not specify how the additional credit hours must be obtained, which can lead to inconsistency in the educational backgrounds of cpa candidates. some students may pursue a master’s degree or additional business coursework. in contrast,e others might take unrelated courses to meet the requirement, which does not necessarily enhance their accounting knowledge or skills.

some candidates view the additional 30 credit hours as providing a limited return on investment (roi) because the extra coursework may not necessarily prepare them better for the cpa exam or their future work as a cpa. this perception and the financial and time costs can deter pursuing licensure.

the financial and time burden associated with the 150-hour rule may disproportionately affect students from lower-income backgrounds and underrepresented communities, impacting the diversity within the cpa profession.

why 150 hours?

the 150-hour rule was instituted to enhance the qualifications and preparedness of cpa candidates in a rapidly changing world. as accounting standards, tax laws, and financial regulations became more complex over the years, a higher educational standard was necessary to ensure that cpa candidates were well-prepared to navigate the evolving professional landscape.

more education was intended to provide a broader and deeper understanding of accounting and auditing principles and related areas such as business law, finance, and management.

this additional education was viewed as a way to foster stronger analytical and communication skills, which are crucial for cpas.

the rule was also meant to align the cpa profession with other professions (e.g., law and medicine) that require advanced degrees or extensive education beyond a standard undergraduate degree, helping to elevate the status of the cpa designation. the rule aimed to bring u.s. accounting education standards closer to international standards, as many countries required more extensive education for their equivalent accounting credentials.

just misguided?

does the new pathway suggest the 150-hour rule was misguided? the consensus today is: probably. it certainly recognizes the challenges and unintended consequences the rule has created over time.

while the rule may have been well-intentioned, the new pathway proposal signals that the 150-hour requirement created barriers to entry into the cpa profession.

the financial and time constraints of meeting the additional education requirements have contributed to a shrinking pipeline of candidates, and the rule has been questioned for its impact on diversity and access.

the pathway focuses on practical, competency-based experience as an alternative to the additional credit hours, suggesting that experience and demonstration of skills can be just as valuable as formal coursework. this shift recognizes that real-world experience may better prepare candidates for the profession’s demands than extra coursework, which may not always be relevant.

the pathway is more about addressing the current needs of the accounting profession than outright declaring the 150-hour rule a bad idea. it’s an effort to modernize cpa licensure to reflect changes in the job market, work environment, and educational landscape, offering a more flexible and potentially more effective route to ensure cpas are adequately prepared.

the new pathway is not intended to lower the standards of becoming a cpa but to balance maintaining professional rigor with increased accessibility. it reflects a realization that while additional education is valuable, it may not be the only or the best measure of readiness for all candidates, especially considering the needs of a changing workforce and business environment.

whither the rule?

yes, there are various opinions about the future of the 150-hour rule, and discussions about its necessity and impact are gaining momentum as the accounting profession addresses talent shortages and evolving workforce needs.

some believe the 150-hour rule should be reformed to make the cpa pathway more accessible. they argue that requiring additional coursework without a clear link to cpa readiness places an unnecessary financial and time burden on candidates, contributing to the decline in new entrants to the profession.

proponents of a competency-based experience model, like the one in the aicpa and nasba proposal, argue that practical experience and demonstrated skills should be valued alongside formal education.

these stakeholders are pushing for the 150-hour rule to be more flexible, allowing a combination of education, experience, and demonstrated competencies to meet cpa requirements.

defenders of the 150-hour rule believe that additional education is essential for ensuring cpas are well-prepared for the profession’s complex demands. they argue that advanced coursework provides depth in critical areas such as business, technology, and communication, which are increasingly necessary for cpas in a changing business landscape.

others worry that relaxing or eliminating the 150-hour rule could dilute the cpa credential, reducing its perceived rigor and potentially weakening public trust in the profession. some stakeholders fear that lowering educational requirements could lead to inconsistencies in the preparedness of new cpas across jurisdictions.

obsolete before it’s time

to be sure, there’s a growing conversation about whether the additional 30 credit hours required by the 150-hour rule could be replaced with more practical alternatives. some suggest that these hours could be achieved through industry certifications, intensive boot camps, or more hands-on, practice-based training directly related to professional skills.

with the rise of micro-credentials and specialized skills (e.g., data analytics, it auditing), some argue that allowing these to count toward the additional 30 hours would better prepare candidates for modern cpa roles than traditional coursework while maintaining the benefits of the extended education requirement.

since cpa licensure is governed at the state level, opinions on the 150-hour rule vary widely by jurisdiction. some states are exploring potential alternatives or additional pathways to licensure to respond to local talent needs. in contrast, others remain committed to the existing rule as a standard for maintaining quality.

one challenge is balancing the need for uniform standards, allowing cpas to have licensure mobility across states and the flexibility to address local needs.

any changes to the 150-hour rule would require broad agreement among state boards to ensure consistent standards.

with a shortage of accountants and a competitive job market, firms are urging faster and more accessible routes to licensure to attract and retain talent. there is a belief that rethinking the 150-hour requirement could help expand the pipeline of qualified cpa candidates and make the profession more attractive, especially to those who cannot afford the time or cost of additional education.

as technology changes the nature of accounting work, there is also a discussion about whether the current educational requirements are aligned with the skill sets cpas need in today’s tech-driven environment. some argue that the rule should evolve to prioritize competencies in emerging technologies, data analysis, and advisory services over traditional academic credit hours.

while there is significant support for reforming the 150-hour rule to make the cpa pathway more accessible and aligned with modern needs, strong voices also advocate for its retention to uphold the profession’s rigor and quality standards. the new proposal by aicpa and nasba for a competency-based experience pathway reflects a growing interest in exploring alternative routes to licensure, suggesting that the future of the 150-hour rule may involve more flexibility and options for candidates. the ultimate direction will likely depend on the profession’s ability to balance accessibility with maintaining high standards and public trust.

a fractious debate

politically, the opinions on the 150-hour rule vary among different groups and stakeholders within and outside the accounting profession.

many state boards are responsible for licensing cpas and have historically supported the 150-hour rule to ensure a high standard of competency and professionalism. they see the additional education as critical for meeting the growing complexities of the accounting field. boards that favor the rule typically prioritize maintaining the uniformity of standards across states to protect the profession’s reputation and ensure public trust. they often argue that the rule aligns with similar rigorous standards in other professions, such as law and medicine.

some universities and accounting programs support the 150-hour requirement, as it aligns with their curriculum structure and helps them maintain a high standard of education. schools that offer specialized master’s programs or five-year accounting tracks have a vested interest in retaining the rule. these institutions often believe that the additional coursework allows students to gain a more well-rounded and deeper understanding of business concepts, ethics, and emerging topics in the accounting profession.

established cpas who completed the 150-hour requirement themselves often support the rule, seeing it as a necessary rite of passage that maintains the rigor and integrity of the profession.

some large accounting firms, namely the big four, support the rule because it ensures that incoming staff have additional education and training, which they view as necessary to handle complex client needs, particularly in areas like auditing, advisory services, and international taxation.

on the other hand, many students and aspiring cpas see the 150-hour requirement as a significant barrier due to the time and financial costs of obtaining an additional 30 credit hours. they often argue that it delays their entry into the workforce, increases their debt, and discourages potential candidates from pursuing the cpa designation. student advocacy groups, particularly those focused on making education more affordable and accessible, have been critical of the rule.

smaller accounting firms are generally more critical of the 150-hour rule because it affects their ability to recruit talent. these firms often do not have the same resources as larger firms to provide educational support, and they tend to see the requirement as an obstacle to growing their workforce. given the current talent shortage in accounting, these firms argue for alternative pathways to licensure, such as the proposed competency-based model, to help attract more candidates.

not all state boards of accountancy uniformly support the 150-hour rule; some are exploring ways to offer alternatives or modify the rule to attract more talent. cpa societies in certain states also advocate for greater flexibility in licensure requirements to address the talent pipeline issues. support or opposition often depends on the state’s economic and professional needs. states with a greater demand for accountants and a noticeable decline in cpa candidates are more likely to oppose the 150-hour rule.

various business advocacy groups, particularly those focused on small businesses or workforce development, often argue against the 150-hour rule. they see it as an unnecessary barrier that prevents qualified individuals from entering the accounting profession and meeting the market demand for cpas. some groups are pushing for more emphasis on practical skills, on-the-job training, and experience over formal academic requirements.

the powers-that-be surrender

while aicpa and nasba have historically supported the 150-hour rule, they increasingly acknowledge its limitations and actively seek alternative pathways to cpa licensure. the new cpa competency-based experience pathway” proposal addresses concerns about the rule’s impact on the talent pipeline and the profession’s accessibility. their current position reflects a desire to balance maintaining high standards with modernizing and making the cpa pathway more flexible and inclusive.

views among lawmakers vary widely. some support the 150-hour rule to maintain professional standards and protect the public interest. however, others see it as a regulatory hurdle that limits workforce growth and prevents diversity in the accounting profession. policymakers’ positions often depend on local labor market needs, educational policy views, and feedback from their constituents, including business communities and educational institutions.

the support for or opposition to the 150-hour rule is largely divided by educational interests, professional standards, workforce needs, and economic considerations. as the accounting profession addresses talent shortages and adapts to new market demands, positions on the rule are evolving, with many stakeholders seeking a more flexible and balanced approach to cpa licensure.

key figures and organizations in the debate

various individuals and organizations hold opinions on the 150-hour rule, some of which have been vocal about their positions. support for or opposition to the 150-hour rule largely aligns with different professional priorities, whether maintaining the cpa profession’s high standards or making the path to licensure more accessible. the evolving stance from major stakeholders like aicpa and nasba suggests that the rule may have historically been widespread. still, there is now more openness to exploring flexible alternatives to meet the profession’s modern needs.

some state boards of accountancy strongly support the 150-hour rule, particularly those from states with established, strict educational standards for cpa licensure. specific boards haven’t often made public statements as individual entities, but collectively, through nasba, they have historically supported the rule.

barry melancon, the ceo of the american institute of cpas, has been a proponent of maintaining the high standards of the cpa credential, including supporting the 150-hour education requirement.

historically, the aicpa has backed the rule to ensure the profession is well-equipped to meet public protection and professional standards. it’s more than ironic and maybe a bitter pill to swallow, considering that melancon is ending a three-decade term at the aicpa that began with his ardent and controversial advocacy for the rule.

many professors from universities with established accounting programs have defended the 150-hour rule, seeing it as a way to improve the breadth and depth of knowledge for cpas. for example, faculty members from top accounting schools like the university of illinois, the university of texas at austin, and brigham young university have historically favored maintaining rigorous educational requirements. the american accounting association, an academic organization for accounting educators, has traditionally not opposed the rule, aligning with the idea that extended education benefits cpa candidates.

the big four accounting firms–deloitte, pwc, ey, and kpmg–have generally supported the 150-hour rule as it aligns with their need for highly educated professionals who can handle complex, global business environments. while their official stances may have evolved to embrace more flexibility given the talent shortage, they have historically endorsed the standard. they are considered the birthplace of the idea and the center of the campaign to get it enacted.

against the 150-hour rule

while the national association of state boards of accountancy had supported the 150-hour rule, it now advocates for more flexibility. ken bishop, the ceo of nasba, has spoken about the need to address the profession’s pipeline issues and explore pathways like the competency-based experience model as an alternative to the rule. some state cpa societies are critical of the 150-hour rule. for instance, the illinois cpa society (icpas) and the minnesota society of cpas have expressed interest in re-evaluating the rule to improve access to the cpa credential and expand the talent pipeline.

leaders from small and mid-sized cpa firms, such as rehmann (a midwest-based firm), baker tilly, and marcum llp, have expressed concerns about the 150-hour rule making it difficult to recruit talent.

while not all have issued public statements, many leaders from these types of firms advocate for reducing barriers to entry, arguing that practical experience should carry equal weight to academic credit hours.

organizations focused on access to the accounting profession, such as the national association of black accountants and the association of latino professionals for america, have noted that the 150-hour rule can disproportionately affect students from underrepresented groups due to the added financial burden, thereby reducing diversity within the cpa talent pool. accountancy student organizations and business school groups have also opposed the rule, arguing that it presents a significant financial and time barrier for students seeking to enter the profession.

meanwhile, sue coffey, ceo of public accounting at the aicpa, has emphasized the need to modernize the cpa licensure model and address the pipeline challenges, including considering new routes like the competency-based experience pathway.

state rep. angelica guerrero-cuellar (d-illinois) has supported discussions around loosening or offering alternatives to the 150-hour rule in response to workforce needs and the profession’s talent shortage. sen. paul bettencourt (r-texas), a tax adviser by trade, has also shown interest in exploring alternatives to the 150-hour rule, particularly in supporting small businesses and reducing barriers to professional entry. groups like the u.s. chamber of commerce and american enterprise institute have generally advocated for reducing regulatory barriers in professional licensure, including exploring reforms to the cpa licensure requirements. while not always directly naming the 150-hour rule, their push for workforce reform and talent development aligns with opposition to the rule’s rigidity.

there are strong opinions on both sides of the debate.

at the aicpa, coffey emphasizes the importance of the rule for maintaining high standards and ensuring the ability of cpas to work across state lines. coffey argues that while creativity and effort are needed to address the cpa talent pipeline issue, reducing education requirements could negatively impact cpa mobility and send the wrong message about the profession’s commitment to rigor and education. rick david, principal at danlex solutions, defends the 150-hour rule, arguing that dropping the requirement would not solve the underlying issues affecting the talent pipeline, such as low salaries, mundane work, and burnout. he suggests that while standards should evolve, lowering educational requirements risks “dumbing down” the profession.

opposition to the 150-hour rule or advocacy for reform

blake oliver, host of the accounting podcast and founder and ceo of earmark, estimates that obtaining a master’s degree in accounting can cost over $100,000 in tuition, living expenses, and opportunity costs. oliver points out that the rule deters candidates from entering the profession, costing an estimated $2.1 billion annually for all students collectively without proven benefits to the quality of cpas. he suggests that the rule should be reconsidered or eliminated if additional education costs do not provide significant benefits.

ed wilkins, adjunct professor at vanderbilt university and former deloitte partner, critiques the expectation gap in firms where new hires believe they will immediately work on more challenging tasks but instead start with mundane work. he notes that students are being misled about the nature of early career work, and this disconnect, combined with the 150-hour rule, contributes to the profession’s talent pipeline issues.

bob hartwig, whose son chose not to pursue accounting due to the 150-hour requirement, argues that the cost of an additional year of education (up to $40,000 or more) and the delay in starting a career make the rule unappealing. he suggests that the profession consider how practical experience could be more effective than the current educational requirement.

concerns about flexibility and cpa mobility

some professionals fear that altering the 150-hour requirement on a state-by-state basis could threaten the cpa’s ability to practice across states, a significant advantage of the current licensure model. a uniform education, examination, and experience standard is critical to preserving cpa mobility and reputation.

the debate isn’t over.

those favoring reform point to the cost and accessibility challenges, while those against argue for maintaining high standards and professional rigor. overall, the profession is groping for a balance between maintaining the prestige and consistency of the cpa credential and adapting to modern workforce needs.

at this rate, it may take another 30 years to unwind the 150-hour rule completely.

but how long for the profession to fully recover from the self-inflicted damage?

 

posted on october 3, 2024