Academy of Business Research Journal, Vol.

III, 2013 57

Shifting Experience Requirements for Obtaining Initial Certification as a CPA

A Study of Changing Standards and Experience Requirements

Cheryl Crespi
Central Connecticut State University

Marie G. Kulesza
University of Saint Joseph

Credentialing as a Certified Public Accountant (CPA) is critical for professional practice in

accounting. Historically, such certification required training within public accounting settings
with CPA firms and specifically in the area of attestation. In response to input from public
accounting firms and, more broadly, the accounting profession, there have been notable
regulatory changes in experience requirements for CPA certification. Connecticut, for example,
recently modified its experience requirements for initial certification as a CPA. While previously
experience was solely satisfied through public attestation experience this is no longer true. In
fact, in part by appeals from both large and small public accounting firms, new regulatory
amendments were enact to effectively mollifying barriers on the areas from which candidates
may satisfy the experience requirement for the initial CPA certification. By removing the specific
attestation experience requirement, candidates may now obtain the requisite experience from a
broader range of practice areas of practice without having to obtain the specific attestation
experience in public accounting settings. This article explores the changes in Connecticut’s
experience requirements for obtaining the initial CPA certification and addresses two questions:
1) is there a trend in broadening experience requirements for CPA certification and 2) what are
the consequences of allowing CPA candidates to gain the requisite experience in accounting
positions outside public accounting settings.

Introduction
Credentialing as a Certified Public Accountant (CPA) is critical for professional practice in
accounting. Historically, such certification required training within public accounting settings
with CPA firms and, specifically, in the area of attestation. Of interest, though, in response to
input from public accounting firms and, more broadly, the accounting profession, there have
been notable regulatory changes in experience requirements for the CPA certification.
Connecticut, for example, recently modified its experience requirement for initial certification1
as a CPA. While previously experience was solely satisfied through public accounting
attestation experience, this is no longer true. In fact, in part by appeals from both large and small
public accounting firms, new regulatory amendments were enacted effectively mollifying

1 Connecticut allows for three levels of professional designation: Initial CPA Certificate only; Initial CPA
Certificate and Certification Registration; and Initial CPA Certificate and Initial CPA License. Each level must
satisfy education, examination, and experience requirements and expands the applicant’s professional authority. The
Certificate alone provides no authority to practice public accountancy whereas the Certificate and License will
provide the applicant the ability to obtain a permit to practice public accountancy.

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 58 Shifting Experience Requirements for Obtaining Initial Certification as a CPA
A Study of Changing Standards and Experience Requirements

barriers on the areas from which CPA candidates may satisfy the experience requirement for the
initial CPA certification. By removing the specific attestation experience requirement, CPA
candidates may now satisfy the requisite experience from a broader range of areas of practice
without having to obtain specific attestation experience in public accounting settings. This article
explores changes in Connecticut’s experience requirements for obtaining the initial CPA
certification and addresses two questions: 1) is there a trend in broadening experience
requirements for CPA certification and 2) what are the consequences of allowing CPA
candidates to gain the requisite experience from positions outside public accounting settings
when, historically, candidates obtained requisite attestation experience only in public accounting
settings with CPA firms. With the recent passage of mobility legislation in neighboring
Northeastern states, the authors further analyzed the experience requirements of the states of
Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont as well as New York.
Differences between states and trends among states of experience requirements for initial CPA
certification are of particular concern to both candidates progressing towards their CPA
certification and any CPA firms facing recruitment and retention challenges. Different
jurisdictional experience requirements are also important to currently licensed CPAs applying for
reciprocity to service clients outside their principal state of business. Furthermore,
understanding these differences and trends are critical for any future progress towards a uniform
national standard for the accounting profession.

Background

It is a well-known premise that it is in the public interest to certify, license, and regulate
individuals who hold themselves out to the public as qualified in the field of public accountancy
(Whittington & Pany, 2010). Courts, state legislators and the accounting profession all agree on
this foundation. In fact, to-date, all fifty states (as well as the District of Columbia, Guam,
Puerto Rico, and the U.S. Virgin Islands) have enacted laws governing the practice of public
accountancy. Moreover, since the first certified public accountancy law was enacted in 1896 in
the U.S., the requirements for the practice of public accounting have continually evolved.
Nevertheless, the three-pronged requirements for initial certification– education, examination,
and experience - which can be visualized as a three-legged stool - are ever changing.

The Three E’s: Education, Examination, and Experience

Education

Education may have always been a point of contention and a topic of discussion in the realm of
accounting. In 1895, Anson O. Kittredge, editor of some of the first U.S. accounting journals,
suggested that business schools did not adequately prepare students in accounting (Romeo &
Kyj, 2000). Improvements in accounting education ensued in the following decades, however,
as recent as the 1950’s, the state of Mississippi allowed correspondence courses ‘merely related
to accounting’ to satisfy their state’s education requirement for CPA certification (National
Association of State Boards of Accountancy, 2008). In 1979, the American Institute of Certified
Public Accountants (AICPA) endorsed the150-hour education requirement (up from a typical
120 hour bachelors degree) to sit for the Uniform Certified Public Accountant Examination.
Florida became the first state to implement the 150-hour education requirement in 1983 and most

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Academy of Business Research Journal, Vol. III, 2013 59

states subsequently adopted the increased credit hours to satisfy the education requirement.
Thereafter, the education requirement became bifurcated with separate requirements to 1) sit for
the examination and 2) to become certified.

Examination

The Uniform CPA Examination began as a paper and pencil examination in 1896. The
examination changed in duration from nineteen and one half hours administered over a three-day
period in the months of May and November to two days in 1992 when the content of the
examination was reorganized. The examination was altered again in 2004, this time to a
computer-based format. Under this format, the examination strives to assess candidates’
research skills and knowledge of current technology using spreadsheet and database software. A
further change in the CPA examination format divides the calendar year into four ‘windows of
opportunity’ in which candidates may take one or more sections (in the first two months of each
quarter of the year) of the examination. In 2011, significant changes were implemented to the
examination, reflecting changes in the profession that incorporate the International Financial
Reporting Standards and the Financial Accounting Standards Board Accounting Standards
Codification as well as new content such as Professional Responsibilities and Global Business
Concepts.

Experience

The changes in the education requirements as well as the structural and content modifications to
the CPA examination over time were in direct response to significant changes in the accounting
profession and the practice of public accountancy. Throughout the numerous and significant
changes affecting the education requirement and examination structure, however, the experience
requirements remained fundamentally intact until recently. In 2009, Connecticut enacted an
amendment to Conn. Gen. Stat. § 20-280-24, which, in effect, broadened the areas of practice
from which CPA candidates may obtain requisite experience to satisfy that prong of CPA
certification requirements. In doing so, Connecticut joined other Northeastern states, New
Hampshire, Rhode Island, and Vermont, in broadening the experience requirement for initial
CPA certification and lifting restrictive attestation requirements.

The Connecticut Experience

Larger public accounting firms in Connecticut were concerned about the ability to provide the
necessary attestation hours to enable tax professional staff to fulfill the specific attestation
experience requirements. These larger firms reported that 45% of their services provided are in
the realm of attestation, which has dropped steadily over the years (“The 2012 Big,” 2013).
Smaller firms voiced similar concerns. Arthur J. Renner, Executive Director of the Connecticut
State Society of Certified Public Accountants (CSCPA) noted “In addition to the situation at the
larger CPA firms, we were also concerned that smaller firms with little or no attest work were at
an extreme disadvantage in attracting and retaining talent because of the difficulty in getting
them the attest exposure required.”

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 60 Shifting Experience Requirements for Obtaining Initial Certification as a CPA
A Study of Changing Standards and Experience Requirements

In May 2008, the CSCPA made a formal request to the Connecticut State Board of Accountancy
to review the current experience requirements and consider enacting changes. Ultimately, the
State Board of Accountancy reviewed the regulations from the neighboring state of Rhode Island
where these very concerns were previously addressed with enacted legislation.

Rhode Island, six years earlier in 2002, modified its experience requirements, thereby allowing
candidates applying for initial CPA certification to obtain the requisite experience (one year)
from any type of service or advice to clients involving the use of accounting, attest, management
advisory, financial advisory, tax or consulting skills all of which must be verified by a licensed
CPA meeting the regulation requirements (Accountancy Act of 1995, (Supp. 2002)).
Furthermore, this experience may be obtained through positions either in public accounting
practice, industry, government, or higher education.

Drawing upon the 2002 Rhode Island statutes, Connecticut amended its experience regulations in
2009. The new regulations, however, continue to require two years of total experience but
eliminated the condition requiring six months of attestation experience. The eliminated
condition, in essence, previously limited the settings from which CPA candidates could gain the
requisite experience. The amended regulation now allows the two years of total experience to be
obtained from a broader range of areas of practice. To satisfy the new regulations, however, the
CPA candidate must provide services or advice involving accounting, management advisory, tax
return preparation, consulting, or attest skills. No change was made to CPA candidate
supervision: A licensed CPA or public accountant (PA) must directly supervise the candidate
(Uniform State Accountancy Act, (1992 & Supp. 2012).

The new Connecticut regulations provide CPA certification opportunities for college graduates
with proper education requirements who choose to go into government or the private sector.
Arthur Renner further noted, “Career change is more and more frequent for individuals and the
physical barrier presented by doing entry level attest work for individuals aged thirty and up may
deter them from the profession.”

Northeastern States

Also in 2009, New Hampshire and Vermont enacted revised statutes modifying their older and
restrictive experience requirements. Both states require two years of experience until June 30,
2014, after which the requirement converts to only one year. Vermont allows a broad portfolio
of experience in either public accounting or non-public accounting settings to qualify for CPA
certification experience. The Vermont Accountancy Rule 5.9(B) requires that the experience
should be of such non-routine accounting nature that continually requires independent thought
and judgment. Vermont’s revised statute repealed the previous requirement of 500 hours of
experience providing audit services and 200 hours preparing compilations.

New Hampshire’s experience requirement allows CPA candidates for initial CPA certification to
obtain requisite experience in either public accounting practice or in government settings.
Similar to the Connecticut and Vermont regulations, the experience obtained in New Hampshire
may consist of services involving the use of accounting or auditing skills, management advisory,
financial advisory, or consulting services, in addition to the preparation of tax returns or

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Academy of Business Research Journal, Vol. III, 2013 61

furnishing of advice on tax matters, or equivalent, under the direction of a CPA or PA licensed in
any state (Accountancy Act of 1999, (Supp. 2012)). Additionally, the New Hampshire statute
requires experience acquired in government settings to be in the areas of auditing or reviewing
financial statements.

Similar to New Hampshire and Vermont, New York enacted changes to their CPA regulations in
2009. In conjunction with newly enacted education requirements, New York reduced the
requisite experience needed for CPA certification from two years to one year, akin to New
Hampshire and Vermont. Furthermore, New York broadened the scope of services that qualify
as requisite experience leading to CPA certification. The requisite experience may now be
acquired in public accounting practice, private industry, government or higher education settings
involving the use of accounting, attest, compilation, management advisory, financial advisory,
tax or consulting skills (Education Laws, 2010). The regulations, effective July 26, 2009, also
eliminated the requirement that 75% of a CPA candidate’s experience be acquired in the areas of
auditing services and financial statement preparation. A CPA licensed in the U.S or a PA
licensed in New York must also attest to all qualifying experience.

Not all Northeastern states are broadening their CPA regulations, however. Narrower experience
requirements are still in place in Massachusetts and Maine. While candidates for CPA
certification in Massachusetts only need to complete one full year (defined as 1,820 total hours)
of experience, the experience remains narrowly confined to the areas of practice in either public
accounting or its government/nonpublic accounting equivalent (Public Accountancy Act of 1963
(Supp. 2002)). Governmental/nonpublic experience may qualify as requisite experience,
however, only if it is deemed equivalent at the Massachusetts Board of Public Accountancy’s
discretion at which time, the Board would only grant one year of experience for every three years
of service in a position above entry-level (Public Accountancy Act of 1963 (Supp. 2002)).

In Maine, the CPA certification experience requirement is satisfied with two years of relevant
experience that must be under the supervision of a CPA licensed in Maine or another state. The
requisite experience also must consist of a minimum of 400 hours in the areas of audit, review,
or compilation and a minimum of 200 hours must be in the areas of management advisory,
financial advisory or consulting services, preparation of tax returns, or furnishing advice on tax
matters (Public Law, 2009). Experience in government or not-for-profit settings may qualify as
equivalent to that obtained in public accountancy at the discretion of Maine’s Board of
Accountancy. Further, experience in examinations of personal and corporate income tax returns
qualify as equivalent experience but on a fifty percent basis. Despite having changed their
education requirement, Maine and Massachusetts have not yet amended the experience
requirements for either duration of experience or type of settings acceptable for equivalency.
Table 1 below summaries the number of years and types of employment currently necessary for
initial CPA certification.

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 62 Shifting Experience Requirements for Obtaining Initial Certification as a CPA
A Study of Changing Standards and Experience Requirements

TABLE I

EXPERIENCE REQUIREMENTS IN YEARS AND AREAS OF EMPLOYMENT

STATE YEARS SECTOR

Connecticut 2 yrs P, PI, G
Maine 2 yrs P, G (50% rate credit)
Massachusetts 1 yr(1,820 hours) P, NP*, G*
New Hampshire 2 yrs until June 30, 2014 P, G
1 yr on or after July 1, 2014
New York 2 yrs prior to August 1, 2009 P, PI, G, E
1 yr after August 1, 2009
Rhode Island 1 yr P, PI, G, E
Vermont 2 yrs until June 30, 2014 P, NP
1 yr on or after July 1, 2014

Key to Sector * one year equivalent credit for three

full years at Board’s discretion
P – Public
PI- Private Industry
NP- Not-for-profit
G – Governmental
E – Education

Trends
Accounting Landscape

The three E’s of initial CPA certification, education, experience, and examination, are intended
to assure the public that newly certified CPAs are well educated and possess business acumen to
meet the demands of the every changing business environment. In response to the demands of
the marketplace, the AICPA and many states have modified the CPA examination and education
requirements to assure competence. Several factors in particular facilitated the modifications
such as globalization of business, expanded utilization of information technology, broadening
scope of services provided by CPAs, current regulatory requirements, and a shift in
demographics in the accounting profession.

The content of the CPA examination has been expanded to test the candidates’ knowledge and
understanding of economic concepts, financial management, International Financial Reporting
Standards, and implications of technology in the business environment. While the current
structure of the CPA examination provides an assessment of the candidates’ technical skills and
application of knowledge by incorporating task-based simulations using authoritative literature,
spreadsheets, and databases, it does not address the broadened scope of services or shift in
demographics that are encountered by accounting professionals.

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Academy of Business Research Journal, Vol. III, 2013 63

CPA Firms

For many years, auditing and accounting services generated large sources of revenue for the
large national public accounting firms as well as mid-size and smaller firms. With the
globalization of business, emerging technology, and sweeping regulatory statutes, the national
public accounting firms with their ample resources were able to attract audit clients and add new
advisory services to their operations. Large national firms expanded through mergers, creating
more diversification in auditing and accounting services that they were able to provide while the
mid-size and smaller firms began to lose market share. This diversification allowed the large
national firms to focus on developing specialists with designated areas of expertise to provide the
services their clients expected and to attract new business. The AICPA’s 2011 report, “Trends in
the Supply of Accounting Graduates and the Demand for Public Accounting Recruits,” noted
that while accounting and auditing remains the most common areas of assignment for new hires
by CPA firms, it has not maintained pace with other areas of growth such as advisory services.

The smaller firms bore economic strains in attempts to comply with rules and regulations in their
respective states regarding attest services. Costly required peer reviews and continuing
education for staff has made attest work a hindrance to any firms’ revenue stream. In addition,
many of these firms’ clients have opted for agreed-upon procedures as opposed to attest
engagements, if possible, to control costs. The smaller firms have moved in the direction of
providing a range of specialized services such as taxation and business evaluation and firm
members have become certified in these specialty areas.

As accounting firms’ operations became more specialized, attracting entry-level accountants who
wished to become CPAs became challenging. Many small firms were unable to provide the
necessary attest experience to staff members who needed the experience for initial CPA
certification. This caused firms to face difficult challenges in recruitment and retention efforts.
Entry-level accountants who wished to become CPAs but who also wished to work in a specialty
area faced difficult choices when exploring career options. The need to acquire attest experience
forced entry-level accountants to seek positions with public accounting firms to obtain the
requisite experience for initial CPA certification yet the firms lacked opportunity for candidates
to obtain experience in their desired areas of interest. This dilemma results in a loss for both
public accounting firms and the CPA candidates: the firms are unable to attract talented
employees while the CPA candidates work in a field of little or no interest.

The large national public accounting firms were vocal in advocating changes to the experience
requirement citing burdensome tracking of CPA candidates’ time and scheduling of staff. This
information gathering process, including detailing time in the necessary areas to qualify for
initial certification, is a major issue in public accounting firms. The new experience requirement
allows CPA candidates to work in specialized areas without hindering their ability to become
certified. The enactment of the new experience regulations provides relief to smaller firms,
allowing them to operate more effectively in recruitment and in providing professional services.
In addition, the new experience requirement allows CPA candidates to move more swiftly
through the initial certification stage so that they may then concentrate on honing their skills in
their area of expertise.

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 64 Shifting Experience Requirements for Obtaining Initial Certification as a CPA
A Study of Changing Standards and Experience Requirements

Education, passing the CPA examination, and broad-based experience acquired in the business
environment should be reflective of the skills needed to succeed in the current accounting
profession. Increased specialization by firms should not mitigate the expectation of the basic
skills and body of knowledge a CPA should possess. CPAs need to remain objective, provide
analytical skills, communicate effectively, and be more computer-literate. Competency in
specialty areas should be measured by the initial CPA certification requirement coupled with
continuing education and practical experience gained in the specialized areas.

The Nation’s Response

As a joint effort between the American Accounting Association and the AICPA, the Pathways
Commission was created to explore the future structure of higher education in accounting and the
accounting profession. Formed in August 2010 in response to recommendations by the U.S.
Treasury’s Advisory Committee on the Auditing Profession, the Pathways Commission explored
a wide range of perspectives on current and future challenges and opportunities for the
accounting profession and developed recommendations for educational pathways to engage and
retain the strongest possible community of accounting professionals (Behn, 2010). Issued in July
2012, the Pathways Commission final report offered significant recommendations for accounting
education and the accounting profession.

A total of seven recommendations were developed which are expansive in scope and
demonstrate the need to address difficult issues facing higher education and the professional
accounting community. In particular, one recommendation highlights the concerns of CPA firms
and demands of the market place: Recommendation #5: Improve the ability to attract high-
potential, diverse entrants into the profession (Behn, 2010). The Pathways Commission report
recognizes the varying career pathways into the accounting profession and encourages a
coordinated effort to demonstrate these broaden opportunities. The national response confirms
states’ actions on new legislation broadening experience requirements for initial CPA
certification as a positive movement to attract quality entrants into the profession.

Future Study
Tracking the results of these changes provides guidance for future legislation. The changes
noted above and the rationale for making the changes may or may not provide the expected
results. For example, many college graduates with a degree in accounting may not enter public
accounting and choose another setting by which to obtain the requisite experience. The private
and government sectors employ an estimated two-thirds of all new accounting graduates in all
facets of the profession (AICPA, 2009). Quality of life issues and balancing work are more
important now than they were even one or two generations ago. Finally, globalization and the
economy may cause businesses and public accounting firms to change the manner in which they
hire staff and provide the necessary services.

Summary and Conclusions

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Academy of Business Research Journal, Vol. III, 2013 65

Certification as a CPA represents a critical and important credential for professional practice in
accounting. This in hand, changing regulatory standards for certification is important for
aspiring CPA’s, educators, employers, as well as the public. In fact, all fifty states regulate CPA
certification with specific education, examination, and experience requirements. Critically,
though, while historically it was required that CPA candidates acquire experience in public
accounting settings with CPA firms and specifically in the area of attestation, recent changes in
some states have modified this experience requirement. This paper has examined this issue.

In 2002, Rhode Island reduced its experience requirement to one year and allowed CPA
candidates to obtain requisite experience in non-public accounting settings. Using Rhode Island
as a model, Connecticut broadened the areas of practice from which CPA candidates were
allowed to obtain requisite experience for CPA certification, allowing experience outside public
accounting settings and attestation services. Connecticut left intact its two-year experience
requirement, however. New Hampshire and Vermont modified their experience requirements as
well. Both states will require, commencing in 2014, only one year of experience. Vermont
allows a portfolio of experience obtained in public accounting or non-public accounting settings
and New Hampshire allows experience in either public accounting or in government settings.
New York also enacted changes in 2009 reducing the requisite experience to one year and
broadened the requisite experience beyond public accounting settings (Education Laws, 2010).

Massachusetts and Maine continue to require narrower experience requirements. While

Massachusetts requires only one year of requisite experience, it narrowly confines that
experience to be in public accounting settings or in government/nonpublic accounting if deemed
equivalent (Public Accountancy Act of 1963 (Supp. 2002)). Maine’s requisite experience must
include audit, review, or compilation as well as experience in the areas of management advisory,
financial advisory or consulting services, preparation of tax returns, or furnishing advice on tax
matters (Public Law 2009). Maine and Massachusetts have not yet amended the experience
requirements for duration of experience.

In short, this discussion, which has explored experience requirements in the Northeastern states,
has illustrated that a number of states are changing their experience requirements for initial CPA
certification. While not all states have modified requirements, the shifts that are noted are
significant and worthy of discussion. Minimally, it suggests a notable change and shift away
from public accounting experience requirements to a broader array of practice settings that may
satisfy state standards. At the same time, issues of portability suggest a concern until greater
uniformity is standardized.

What changes can we expect in the future? With such notable changes occurring in less then a
decade, it would appear, using this purposive sample, greater changes and flexibility are likely to
occur in the future. This article has certainly highlighted notable changes. Where do you stand?
Where does your state and state CPA society stand? With such changes occurring so rapidly,
discussion is important. This article was written to help stimulate such a dialogue.

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 66 Shifting Experience Requirements for Obtaining Initial Certification as a CPA
A Study of Changing Standards and Experience Requirements

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