California Board of Accountancy approves comment letter criticizing national competency‑based pathway draft

The California Board of Accountancy on Nov. 4 approved a draft comment letter urging national committees to rethink aspects of a proposed CPA competency‑based experience pathway and to provide clearer, evidence‑based protocols before states adopt model language.

Michelle Center, chief of the licensing division, told the board staff’s review of the AICPA/NASBA exposure draft (the “pathway exposure draft”) shows the proposal would create a pathway to licensure that requires a bachelor’s degree, certification of competency‑based experience, one year of general accounting experience and passage of the CPA exam. But Center and other staff said the draft lacks a body of evidence tying the recommended foundational competencies to entry‑level public protection.

"The pathway exposure draft does not have a body of evidence to support the use of the foundational competencies for this purpose,” Center said, adding that the document relies on decentralized scoring and an evaluator rubric that is “extremely vague." She noted optional NASBA training for evaluators would not, by itself, prevent inconsistent scoring across firms.

Board members raised technical questions about hours and license scope. Nancy Dong asked why the exposure draft uses a 2,000‑hour minimum for competency‑based experience; she noted that 2,000 hours is close to a full work year but questioned how the draft arrived at that figure. Patricia Bachelor cited the document’s treatment of combined competency and general experience, saying the draft can create a combined minimum of about 4,000 hours for candidates without 150 semester units; staff confirmed the draft’s design would generally produce roughly two years of combined experience for those candidates.

Staff recommended the board request that the UAA committee reconsider the pathway approach and delay further exposure drafts until a "thoughtful and technically sound" model is ready. The board moved to prepare and send a draft response found in attachment 3, amending the final paragraph to ask that any future drafts be responsive to California’s concerns about minimum competencies; the amended motion passed on a roll‑call vote with all recorded members voting "Yes."

Jason Fox of the California Society of CPAs provided public comment in support of the board sending a letter and thanked staff for the analysis.

The board’s action does not change California law; it authorizes staff to transmit the board’s comments to the UAA committee and to finalize edits under the president’s authority by the December deadline.