Competency Model Exposure Drafts

The exposure draft process is YOUR opportunity to provide feedback to those responsible for writing the laws and rules that govern the profession. YOUR responses will determine if these changes are implemented as is or amended. Once the Uniform Accountancy Act (UAA) is amended each state considers the changes and decide if they will adopt the recommendations. In Montana, this language will likely not be considered until the 2027 Legislative Session, but your opportunity to comment on the proposal happens between now and December.

There are currently two exposure drafts open for comment related to initial licensure and mobility for CPAs: 

1. UAA contains changes that would add a new pathway to licensure and update substantial equivalency language which allows CPAs to practice in other states. 
2. CPA Competency-Based Experience Pathway provides details on the framework the new pathway references. 

The Montana Society of CPAs Board will discuss these proposals during their November 5th meeting. We would appreciate any thoughts you would like to share related to these proposals. Please email allen@montana.cpa with your thoughts. 

Below are some specific issues to keep in mind as you review these proposals based on specific roles:

CPA Candidate Employers / Supervisors – this proposal would ask more of those verifying the experience of CPA candidates. When reviewing the program please think about how you would ensure that staff you directly manage could obtain the competencies listed, in a way that you would be comfortable signing off on their experience. 
Question for consideration: could the language be changed to make it easier for you to feel confident in administering this program for new hires joining your organization?

Current CPAs – this proposal would change the provisions that allow CPAs to practice in other states.  When reviewing that language think about how your ability to serve clients in other states or your ability to engage with CPAs from another state may be impacted.
Question for consideration: does the language provide enough clarity on who can and cannot practice in jurisdictions that adopt the language?

Educators – these proposals retain the current pathway while adding a new pathway which may become attractive to some students and employers.  When reviewing the language please keep your program in mind and consider how your current curriculum might need to adapt to fit the needs of students pursuing each of these pathways. 
Question for consideration: could the language be changed to make it easier for your program(s) to easily fit within both pathways to licensure? 

Students – these proposals are creating a new pathway that may be more attractive than the current pathway based on your personal circumstances.  The timing of when these proposals are implemented and when your school is prepared to offer programs that fit with this new pathway will be important to monitor.  We encourage you to follow this process and recognize that your school will also be working to stay up to speed on where the process is.