On November 26, 2024, COCPA President and CEO Alicia Gelinas, CPA submitted an official letter to the Association of International Certified Professional Accountants (AICPA) and the National Association of State Boards of Accountancy (NASBA) in response to the CPA Competency-Based Experience Pathway Exposure Draft released earlier this year.

This proposal represents a transformative shift in CPA licensure, paving the way for more diverse pathways through experiential-based learning. By aiming to ease the time and cost burdens of education, it seeks to create a more accessible accounting profession. This proposal marks a significant first step toward aligning licensure with competency-based outcomes rather than traditional time-based inputs.

Why This Matters to Colorado CPAs

COCPA is committed to ensuring that any changes to CPA licensure reflect the needs and priorities of the profession in Colorado. While we support the competency-driven framework, our feedback emphasizes the need to address several critical areas to ensure its success:

1. Evaluator Readiness and Oversight:
   COCPA advocates for increased clarity, guidance, and liability protections for CPA evaluators, as well as a proposed increase in the experience requirement from three to five years to ensure consistent and fair assessments.
2. Competency Framework Development:
   We recommend conducting regular practice analyses to refine the competency framework and ensure it focuses on practical, observable universal skills rather than aspirational behaviors or focused practice areas. This will better prepare candidates for the evolving demands of the profession.
3. Simplification and Practical Execution:
   Simplifying the framework by separating high-level principles from detailed guidance and combining competency-based and general experience into a single requirement will make the model clearer and easier to implement for candidates, evaluators, and the public.

Balancing Immediate Needs with Long-Term Solutions

COCPA recognizes the urgency of addressing the accounting profession’s talent shortage while ensuring a sustainable, robust licensure framework. We urge AICPA and NASBA to balance short-term solutions with thoughtful, long-term strategies to uphold the integrity of the CPA profession.

COCPA remains committed to supporting this initiative’s development and will continue to advocate for a licensure model that strengthens both the profession and Colorado’s workforce.

For more information or to read the full letter, please visit our Resource Library.