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The uniformity challenge.


The following remarks are excerpted from a presentation by Robert C. Ellyson, a partner of Coopers & Lybrand, as he accepted NASBA's first William H. Van Rensselaer Public Service Award.

What first inspired my interest in this profession--and what has sustained that interest--is the challenge. Unfortunately, change--particularly self-imposed change--comes slowly and only after much debate and compromise. But that doesn't mean we shouldn't keep rising to the challenge.

I'm proud of what NASBA has done over the past several years in tackling the problems we face. As state board members, you have been and will be confronting a number of issues critical to the profession's future. What we continue to need are people of vision to move these and other issues forward.

For example, take mandatory peer review (or practice monitoring, or positive enforcement, or whatever you choose to call it). NASBA has been attempting to get state boards to adopt meaningful, positive enforcement programs for well over 10 years--and progress has been slow and uneven at best. And yet, today we're on the verge of having mandatory peer review as a reality.

The profession has seen the need--has even agreed on who the implementor should be. And yet, while most of us would acknowledge that we don't need more than one program, several state boards are concerned because they already have their own plans in place.

The difficulty in achieving any uniformity among the states is obvious. Getting 54 state boards to agree on something and then getting 54 legislatures to adopt substantially identical legislation has been extremely difficult. So we've made the change to an AICPA quality review program, where reasonable uniformity can be achieved.

This is not to suggest that boards should ignore positive enforcement requirements for relicensure. Such a relicensing requirement for all practicing CPAs is appropriate. But boards need to recognize that a uniform and evenhanded approach to this issue is more important than who administers the program.

I strongly endorse the concept of a NASBA-sponsored quality review oversight board. At first, I thought the findings of the oversight board should be made available to all state boards, but now it appears they will be made available only to the state boards that require positive enforcement for relicensing and will accept participation in the quality review program as satisfying that requirement. This suggests to me that we can achieve maximum coverage and uniformity only among states that require positive enforcement for relicensure.

Another issue--the 150-hour education requirement--is one where boards have a unique opportunity to achieve uniformity.

The committee on education and experience requirements for CPAs (known as the Beamer committee) proposed it in 1968--and since then, only eight states have bought in.

I'd like to congratulate those eight--and I urge the others to do the same. But a word of caution: There can't be 54 or 20 or even 5 different sets of requirements. The large firms aren't going to accept inconsistent entry and reciprocity requirements--a concern the megamergers will exacerbate.

If the state boards can't arrive at some national consistency and uniformity, the large firms could feel compelled to push for federal licensing. Because the minute state licensing and regulation become too onerous, federal licensing--even with federal regulation--could be seen as the lesser of two evils.

So I urge the state boards, through NASBA, to arrive at a generally acceptable definition of the 150-hour requirement and use a consistent approach in drafting legislation and rules. A broader definition, consistent with AICPA and AAA studies, would be preferable. If the definition is narrow and stresses technical subjects, it will make uniformity more difficult, which will not serve the profession well.

While state board members and NASBA have emphasized uniformity for years, too often parochial state views and individual expression have prevailed. With the enhanced visibility of state boards with Congress and federal agencies, uniform licensing and regulation of our profession is critical.

Differences between states will not be understood in this national and even global environment and eventually will not be tolerated, either by those affected within the profession or by elected officials at the federal level.

Accordingly, I urge state boards and NASBA to undertake a serious and concerted effort to maximize uniformity in both the requirements to enter our profession and its regulation.

If state boards are indeed the catalysts for quality, then this is but one more challenge you can rise to.
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Author:Ellyson, Robert C.
Publication:Journal of Accountancy
Date:Feb 1, 1990
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