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CBA explains 'supervised practice' condition for probationers; seven licensees currently subject to term
Summary
Staff described how supervised practice functions as an optional probation condition, the criteria for practice monitors, reporting expectations, and sanctions for noncompliance. The committee asked about participation and compliance; staff said seven licensees currently have the term and most are in compliance.
The Enforcement Advisory Committee received an informational overview of the CBA's supervised-practice condition for probationers on May 1. Enforcement Chief Carrie O'Connor said supervised practice is an optional probation term used in stipulated settlements, proposed decisions, or license-reinstatement orders.
“Supervised practice is an optional condition of probation that may be included in stipulated settlements, proposed decisions, or when a petition for reinstatement of a license is granted,” O'Connor said. She explained that when the condition is ordered, the probationer must submit a plan of practice within 30 days identifying practice areas and a proposed practice monitor — a qualified CPA who will review sample engagements and file quarterly reports with the CBA.
O'Connor described strict criteria for practice monitors: they must hold a license in good standing, have expertise in the probationer's practice areas, and maintain an independent professional relationship. The plan must be approved by CBA staff; if staff deny the proposed monitor or plan, the probationer must submit a revised plan.
The quarterly reports prepared by the practice monitor list engagements reviewed, assess compliance with professional standards and note deficiencies. CBA staff can request engagements identified as problem areas for further examination by an investigative CPA or by enforcement staff. O'Connor said the CBA sometimes tailors the supervision term at settlement to specify the practice area, review frequency or whether reviews occur pre-issuance or post-issuance.
Committee members asked about program scale and compliance. O'Connor said, “We have 7 licensees currently with this supervised practice term.” She added that compliance with quarterly report requirements has been generally good, and that the CBA would pursue disciplinary avenues — including filing a petition to revoke probation and implementing the disciplinary order — if a probationer failed to comply.
The committee discussed recent form revisions. Staff added a monitor affirmation that there is no personal or professional relationship with the probationer, a statement that probationers pay monitoring costs, and an acknowledgement that probationers must maintain confidentiality of information provided to the monitor.
This item was presented for feedback; the committee did not take formal action. Staff invited suggestions to improve the plan of practice language and forms.
