All A&A Survey Results

Below are the complete results for the A&A survey. If you would like to view only the responses for A&A Practitioners, click here. If you would like to view only the responses for Non-A&A Practitioners, click here.

1. Do you perform any assurance or attest work (audits, reviews, compilations or other engagements under Statements on Standards for Attestation Engagements)?

TotalQuestion 1

2. Do the current Accounting and Auditing (A&A) CPE requirements need to change?

TotalQuestion 2

3. If YES to question #2, please choose only one of the following alternatives to the current 20-hour A&A requirement.

TotalQuestion 3
156A: Remove the current requirement of 20 hours of Accounting & Auditing per re-licensing period and allow those hours to be used for any technical subject matter.
131B: Revise the current requirement to allow for either 20 hours of Accounting & Auditing OR Tax subject matter education OR any combination of the two.
179C: Revise the current requirement of 20 hours to the following: reduce the requirement to 8 hours of Accounting and Auditing with the remaining 12 hours to be added to the technical subject category.
75D: Revise the current requirement of 20 hours to the following: reduce the requirement to 8 hours of Accounting and Auditing and 4 hours of Fraud continuing education with the remaining 8 hours to be added to the technical subject category.
65E: Revise the current requirement of 20 hours to the following: reduce the requirement to 16 hours of Accounting and Auditing with the remaining 4 hours to be added to the technical subject category.


1If changes are made, there should be a drop of A&A to 16 hours. The remaining four hours should be some sort of fraud element CPE.
2What are other states - the best of the best - doing? Will a change impact reciprocity?
3I only do compilations. I find it helpful to have one 8 hour course update on the matter and the rest be up to the individuals needs.
4A CPA should know the areas that he/she needs education on and should be free to choose.
5I understand the requirement for 20 hours of accounting and auditing; however, in most practices the practitioner specializes in a particular area. For example, for those who specialize in the tax area, I can see where mandating course work in an unrelated area would seem to be an unwanted waste of valuable hours. I believe the practitioner should be able to select course work which compliments his or her practice, rather than being mandated to take classes which have little or no meaning.
6As a practitioner dealing solely with tax, the only A & A I need to keep updated on is as related to Fiduciary Income and Accounting. I feel reducing the 20 A & A requirement and adding Fraud would be beneficial to all areas of practice. With fraud on the rise and the expectation of our profession detecting fraudulent activities, any insight into where to look, or what to look for would be most helpful.
7As a CPA in government the A & A requirement is of little benefit for me. By removing the 20 hour requirement would allow me to focus on CPE that is specific to my job.
8Although I can understand that many CPAs don't perform audits or reviews, it is the only area that we are legally protected to practice in. I am concerned that if we make it so that CPAs can focus on just tax education, our profession will ultimately lose its purpose.
9I believe that 8 hours in A&A is very important with the remaining 12 hours to be relative to the individual's needs to excel in their area of expertise or become more diversified in their services.
10I do a limited amount of A&A work - mostly just compilations. I'm in a larger firm that has the "experts" in this arena, so I don't need more than a basic update. I find the current A&A requirement onerous. I rarely use the information I get in these A&A hours - I would much rather spend my time on increasing my level of expertise in other tax areas that I will actually USE in my practice. Go to any A&A CPE currently - you will find the back row filled with tax CPAs
11I applaud the FICPA for taking up this matter. It is long overdue and will benefit its members greatly
12Those performing attest work should be required to have 20 hours OR MORE of CPE in the reporting period. Those who perform NO attest work should be able to mix and match A&A and/or Tax subject matter, based on their assessment of their individual needs. I DO continue to believe that mandatory CPE should be retained. I would not permit CPAs to decide whether or not the needed CPE credits. I've seen work of CPAs which indicates that they probably weren't paying attention to what ever classes they took, but at least requiring the exposure is better than not. Maintaining current knowledge is a hallmark of a profession and it's imperative that this aspect of CPE be remain a requirement.
13I feel the point of CPE should be to enhance your abilities and knowledge as a CPA for the work performed. A change in the CPE requirements that would allow a CPA to focus their education in areas that are most relevant to their practice would be like a breath of fresh air.
14I believe that the FICPA should not waive the A&A rules completely. If one is a CPA one should be taking update courses to at least keep up with the rules related to financial reporting.
15Our profession offers individuals the ability to specialize in areas where A&A is not material. To continually force these individuals into 20 hours of A&A that has no meaning to what they do professionally needs to change. To think they are getting anything from these classes is naive. I have seen some individuals that sit in the back of the class reading the paper or a book or doing work on their laptops. This is a true waste of time for them.
16Most who do not do any attest services do not need extensive a&a training.
17The in the rules could be such that any practitioner not performing assurance or attest work should be able to substitute the A&A hours for his subject of expertise. so if practitioners perform only tax work, then Tax subject matter should count for the minimum 20 hours of A&A. More over, if changing the requirement is not acceptable, then may be allowing for Tax subject matter to qualify as A&A, after all tax is a form of accounting. For other individuals that perform other services such as valuation, personal financial planning, forensic services etc, courses in the subject matter should count towards their minimum requirement. To accommodate these requirements and enhance the education of CPAs, CPE requirements could be modified so that 30% of the CPE courses should include subject matter in the area that the practitioner practices or specializes, such that a practitioner performing attest services and tax services will have to comply with a minimum of 24 hrs of A&A, and 24 hours of Tax subject matter. This without taking away the minimum requirements for other industries, like those who audit governments and non-profit organizations. These matters can be verified through peer review, which must include all attest services not just audits. CPA that are not in public practice, must continue with the minimum of 20 hrs in A&A courses.
18While I do no attest services, accounting theory and audit theory are valuable in the preparation of client books on the tax method. Just because I have seldom used GAAP in preparing income tax returns (maybe once or twice in 35 years) does not mean that I should not be familiar with it and the changes in the profession. Twenty hours is a minimum useful amount of A&A. Perhaps it should be increased to twenty-four. As part of that increase, perhaps there should be a minimum of eight hours devoted to detecting fraud.
19We hold out as Certified Public Accountants to the general public. I want to be able to practice according to the latest standards and I know of no other way to do so other than taking CPE in A&A.
20A compilation & review course of at least 16 hours should be mandatory for CPA's that perform just compilations and reviews. My many years as a peer reviewer convinced me that most of the CPA's I reviewed were "cooking" their reports just to pass the peer reviews. Another 8 hours in theory area's would be also be appropriate.
21For those of us that only do compilations once in awhile, 8 hours of A&A should be more than enough.
22Even though I no longer perform attest work, it is good idea to keep up to date with the changes in GAAP, Ssars etc. However, 20 hours of mandatory CPE makes little sense for CPAs not involved with attest work and, personally, I end up taking CPE courses that contain repetitive, overlapping material just to meet the required hours. We would be better served being able to concentrate our CPE hours mostly in our area(s) of practice.
23I am retired from practice, but am keeping my license current, so my perspective may be in the minority.
24I do NO A&A work in my specialty (forensic accounting), but A&A is, ultimately, the core of what all accountants represent. In order to call ourselves accountants of any caliber or any specialty, we should be expected to keep abreast of and be familiar with A&A and any changes over time. It is all for the sake of public interest and perception, even if not involved in public filings and doing nothing more than litigation consulting, tax preparation, or simple debits and credits.
25We as CPA's are still judged on our general knowledge of accounting by prospects & friends even if we don't perform audits in our individual practice. As we volunteer for non-profit boards, converse & sell the profession to college students picking their career path, or researching financials when picking stocks in our own portfolio, the selection of A&A hours over a 2 year period has always been diverse enough to keep me current and provide me with important information about that side of the profession.
26There is rarely 20 hours worth of update material available in a two year period. Agree that there should be a requirement, but feel that 16 is probably more than enough most renewal periods. Believe us professionals are smart enough to go for more in periods when that might be necessary because of significant or numerous standards changes.
27Attest services are the defining and unique function that can only be provided by CPAs. Practitioners who wish to hold themselves out as CPAs have a professional obligation to maintain at least some current level of knowledge and proficiency in accounting and auditing subjects. If that proficiency is not a necessary requirement of the profession, should we extend the alternative to the CPA exam? Perhaps applicants who wish to limit their practice to exclude attest services should also be exempted from the portion of CPA exam addressing attest issue. But isn't that pretty much all of the CPA exam? If you want to be a CPA, you have to maintain the expertise. Given the complexity of current accounting and attest rules, perhaps 20 hours of A&A isn't enough. Consider requiring 50% of required CPE to be taken on A&A topics.
28Every year I hate taking my 20 hours of A&A CPE, but after taken, every year I am glad that I did. I issue a lot of compiled Financial statements, mostly tax basis, but once in a while I am required to present reports on the GAAP/Accrual basis. The 20 hours requirement keeps me trained to do those engagements. Perhaps you need to provide more different A&A CPE. Like real estate rental accounting, percent of completion, cash to accrual adjustments and vice versa.
29Knowledge of the accounting rules and financial statements and how theya re put together is an essential startng point for return preparation and tax controversy
30I believe that having an understanding of the current A&A topics/developments makes us all more well rounded.
31Add peer review for ANY attestation work that is done and see how fellow CPAs are doing. Most CPAs that I know that do almost all tax still do compilations and maybe even a few reviews for their business clients. They hate doing the A & A CPE and would not do it if not forced to. How would they keep up on the ever changing standards without it? Maybe remove the requirement of 20 hours of A & A if they attest that they do not do any attestation work of any kind. I don't know how this could be monitored. Attestation work is the only thing that sets CPAs apart. You do not have to be a CPA to prepare a tax return. We should take our professional standards very seriously and strive to keep up with the changes.
32 I believe the requirement to obtain at least 20 hours of A&A over a two year period is reasonable. What is worthless is the requirement to take 4 hours of Ethics. Remove the Ethics requirement.
33It is too easy to take worthless CPE classes simply to fulfill the requirement. CPAs are by nature responsible and we take the CPE that will provide the most value to us and our clients.
34I don't feel strongly either way, as you can see from my response. I don't personally think they need to change, but understand why some CPA's would desire the requirement to be not all accounting and auditing and to include tax education. I have been in industry since 1986 and have had no problem obtaining 20 hours of A&A. I do not believe that more than 60 hours should be allowed for technical business or behavorial, though, to ensure that our profession maintains its status.
35One alternative might be to require A&A hours AND Tax hours. Tax hours specifically, not just technical business. I'm also licensed in PA and they require both. If you make the argument that basic accounting is the fundamental starting point and is the underlying basis for preparing a tax return, and, therefore, CPAs that only prepare taxes still rely on and are required to have accounting skills; then the converse argument should be made. CPAs that prepare (compile, review, audit) financial statements should have basic tax knowledge and must be aware of current tax laws, otherwise tax accruals, tax calculations and disclosures on the financial statements may be wrong.
36I think CPA's that prepare tax returns should still maintain a minimum level of education in other areas. No tax return comes without needing some knowledge and understanding of current accounting requirements. Also, if a non CPA asks a CPA an accounting question and they are clueless it hurts our profession.
37With only producing compilations, the A&A is a waste of my resources. The bulk of my time is spent on taxes and tax advising so to spend hours taking courses not related to anything I produce is not productive. I have other resources I use to produce the few compilations, so why must I spend money on useless info. As the rules change, I understand that I need to learn them and force myself to take the needed courses to obtain the knowledge to produce accurate reports. I am also a AICPA member and MD licensed. Neither has the A&A requirement.
38As an auditor, I will continue to obtain the necessary training and CPE relevant to my trade. However, I agree that there should be some revision to this requirement for those CPAs that do not conduct A&A work.
39Revise the current requirement of 20 hours to the following: reduce the requirement to 8 hours of A&A, 4 hours of Fraud, and 8 hours to A&A OR Tax OR any combination of the two.
40Question 2 states whether the A&A CPE requirement needs to be changed; I don't believe it NEEDS to be changed, but do believe that as a professional the 20 hours of A&A might be better spent in other more pertinent subjects now that I'm no longer performing attest services. That's not to say, that I wouldn't take any A&A as some courses could be helpful. I feel that as a professional we ought to be capable of determining the most appropriate type classes to advance within the profession.
41It's ridiculous to me that as a professional who has never done and probably never will do an attestation engagement I have to take 20 hours of A&A every two years. It is useless knowledge to me and my money would be better spent on courses that apply to my field of work.
43I believe all CPA's need to know of changes and updates to Accounting and Auditing, the core of the profession, regardless of whether they perform assurance or attest work. What should be considered instead are changes/updates to the Ethics CPE and training requirements. I have taken the SAME FICPA ETHICS COURSE MULTIPLE TIMES (at least 5, I think) to meet Florida license renewal requirements. The second time taking the course was a somewhat effective refresher; the additional times represented a waste of time and money. Please fix this requirement and the related course!
44I have been a CPA since 1996. I have a tax practice and have learned nothing useful in any of the A&A courses I have taken since that time..
45We fought very hard to establish our profession as a profession. The A & A is work is the only work reserved specifically for CPA's. We gave up the experience requirement for the 5th year (good move) but we have also watered down way too many of our long establish laws, rules and professional standards - commissions, contingent fees, etc. It's 10 hours per year - not a big deal. We are babying the younger set - less work hours, more pay, less rigorous workloads, already. I see this as a further move in that regard and not warranted. IF you want to have the status of CPA you have to comply with the standards and rules including the" rigorous" CPE requirements. if you are working in industry you need to know this stuff as much as the public practitioners. The only ones who can make a genuine case that they don't need it are those with certificates, who really aren't practicing accounting; such as non-CPA-company managers, and entrepreneurs. We should not change it for that small minority, nor should we change it for those simply inconvenienced. It was nice to see Jerry Schine's column! Scott Rhine
46If the requirement can't be removed, then have a two tier CPA license where those that do A&A must take A&A CPE and those of us who do no A&A must certify so and then we can concentrate our CPE in areas that relate to what we do.
47The 20 hours should remain in palce gor those performing an attest function.
48First off, thank you for raising this issue. It is long overdue for a discussion. As a tax practitioner who rarely if ever is involved with a tax provision, I would suggest that the 20 hour requirement be reduced or eliminated. I suspect that option 3 above is a reasonable compromise that would satisfy many of us in the same boat. Getting 20 hours of accounting and auditing credits is difficult. I work in a large firm, and the trainings we once had in the past with the audit department are rarely if ever socialized or made available. And with a fair amount of training going to the online system, the opportunities to get 2, 4 or 8 hours at a time are virtually non existent. I rely on our firms CPE day that provides approximately 5 hours. If my schedule allows, that usually gets me to 10 hours and I fill in the other 10 as I can with online training sessions. The problem is that very little if any of this is applicable to my job and I feel that many of us are only sitting through this to comply with the rules. I would much rather have the 12 hours freed up to take something that would actually apply to what I do for a living. Clearly there are non-audit practitioners who will feel differently. But nothing will stop them from getting 20 hours if they choose to go that path.
49I believe all CPA's need continued exposure to the changing accounting and auditing environment even though they do not practice in this area. The exposure to A&A helps even tax practioners understand the complexities of the regulatory environment.
50it only makes sense to remove this requirement. a CPA doing only taxes for many years should not have to have mandatory A&A, when there is no possibility of using it.
51The above selection was my choice for sake of the best alternative offered. I do recommend those of us performing attest functions requirement of at least 20 hours of A&A.
52I know it would be difficult to police, but it would seem that there should be at least 20 hours of required CPE in the area where license holder primarily practices. For example, and I know I'm a bad example, my expertise is in the area of bankruptcy and insolvency where I serve as court appointed Trustee or receiver and the skill set required is more focused on CLE type courses structured around The Bankruptcy Code and State statutes. To be proficient it is much more important that I foster and stay current in those skills than A&A type education. I sort of feel that the "forced A&A" is not much different than requiring all certificate holders to take 20 hours of "yellow book" courses even if you have no gov't type clients. i also have sympathy for Tax practitioners who I see attending the A&A meetings with their Wall Street Journals for reading material so they don't waste their time on areas that will have no practical benefit to them.
53Believe some hours of A&A important to keep up with latest developments, at least as a broad-brush overview. Believe that California's ability to differentiate CPE requirements for those CPS involved in attestation services, vs those who are not should be looked into. Since I produce no financial statements, I have no requirements for any type of peer review - -- that data base exists, and hopefully can be used as a tool if differentiation is chosen as a solution. Thank you for trying to effect change. Steve
54While I strongly dislike reducing this requirement, Florida does have one of the more stringent requirements for A&A. When looking at the Firm/Individual Mobility push for it to work all US CPA Jurisdictions will have to be closely uniform in their CPA/CPE Requirements. If we act now to "lower our standards" now we maybe able to the keep the requirement that all Certified Public Accountants across the board have an understanding of what is current US GAAP, and not just some. Another argument I have for keeping the A&A CPE requirements (at a reduced level) is that if we are no longer required to be update on US GAAP, then people will start pushing for the Accounting portions of our certification exam to be removed along with the college accounting course requirements to be reduced or removed under the same argument of "I will never use it" that tax prepares are using now thus, lowering the quality of the CPA certification. The public impression that a CPA is a trusted business advisor and not just a "Tax Expert" is something the industry needs to keep intact otherwise we just devalued our certification and the industry. I would also like to add that under no circumstances should we completely remove the requirement or create a two tier CPA in that state.
55A&A is a monumental waste of my time as a tax CPA. It's like asking a podiatrist to study cardiology 16 hours per year. The PUBLIC would be better served by my using those 16 hours for subjects that will benefit them. Jim Schorner Vero Beach Attorney/CPA
56The 20 hour requirement and the 80 hour requirement are both completely arbitrary. CPA's do not receive much benefit from this and it seems designed to please the CPE industry, Get rid of these requirements and mandate a specific 1 or 2 day update on accounting, auditing and tax issues per year.
57Fraud is becoming a bigger issue nowadays, so thats could even be 8 AA, 8 Fraud (helps CFEs) and 4 Technical subject. So that 4 can gradually become 8 down the road. Lets put more emphasis on Fraud and Ethics for those not in attest work, because more and more of us are in non attest areas. The Attest folks already get their updates just doing their work. Its like beling a doctor but I am not a brain surgeon just a podiatrist. Let us be more in line with the 2014 occupations. Good move to ask for our opinion. Congrats on that.
58While not all CPA's in Florida perform A&A engagements, the A&A rules, regulations, etc. are continuing to rapidly change. I believe even a tax-only CPA should be required to stay current on new/updated A&A authoritative literature, thus I feel the current CPE requirements should stay the same and 20 hours is not unreasonable.
59If anything, there needs to be a greater requirement for A&A, especially for smaller practitioners. I might agree that a tax-only CPA does not need 20 hours of A&A every period, but I would never agree that an almost-all-tax CPA practitioner... who performs 1 compilation a year... could skate by with no A&A. That person would need more A&A than anyone else out there. Also, I see small "tax" practitioners who are unaware of SSARS No. 19 (even still) and make errors in this area. A core knowledge about attest services means we need to keep the A&A requirement in place or, if changed, require MORE STRINGENT CPE for those who perform even a single attest engagement.
60For almost 25 years, I've had no problem with the requirements and I do tax and attest work. I hear non-stop complaints from tax professionals about the A&A requirement, but 20 years is not that much, less than 3 days or sessions. Even if they don't practice in that area, it's good to be aware of changes that come down. I advocate to keep the same requirement and don't decrease it.
61I have been in public practice for 50 years. I would estimate that for the last 25 or 30 years I have only done tax work. I do not have anything to do with audits, reviews or compilations. I generally attend the UCF Accounting Conference to get my AA hours. I sit in classes that I have no idea what they are talking about and I have no interest. What am I getting out of these classes NOTHING.
62Those who have been members for over 40 years should have a reduced TOTAL requirement (lower than the 80 hours every 2 years.
63Any of these are good - From a "selling" point, I think it is easiest to sell the tax/audit combo- CPAs tend to be experts at one or the other, but not both. Then we would take 20 hours in tax if we primarily are involved in tax, or 20 hours in audit if we are primarily a+a. Avoid doing the 4 hours of fraud, that's another bucket and it is already part of A+A. We already have 4 buckets counting ethics, we don't need 5. Another idea - have the ethics time count towards A+A since it really should, professional standards.
64It is imperative that CPA's stay abreast of A&A requirements. Since CPA's are the only professionals allowed to prepare financial statements, professionals should keep up with the changes in presentation, disclosure and reporting formats. This would be true even if only preparing a compilation.
65I believe that even a tax practitioner needs to have a basic understanding of A&A principles. I would like to see more in depth Accounting for Income Taxes courses offered. This is an area of high need for anyone that does tax provisions and works with audited financial statements.
66How can someone properly prepare a corporate tax return when one doesn't properly prepare first the trial balance (or financials)? Without A&A how can someone keep abreast of the current accounting guidelines? Even those who prepare non attest bookkeeping statements need to keep on top of the current guidance. Without A&A that cannot be done. The only way a CPA should be able to avoid taking A&A CPE classes is if they do absolutely no business (sole proprietor, corporate, s corporate, partnership) tax work. Given the difficulty of enforcement this is unworkable.
67All CPAS should know what is going on in our industry which includes the massive changes that have recently been occurring in the A&A arena. 20 hrs just keeps us informed/updated. I like this requirement. I do, however, feel that the 4 hours of so called "ethics" is a colossal waste of time. You cannot teach ethics and the current course material is useless as basically it forces CPAs to pay to sit in a class while someone reads from the Laws and Rules book. I would like this requirement removed and the exam brought back!
68 Why would you reduce the 20 hour requirement? My suggestion is to increase it to say 30 hours at least every 2 years. I just went to the CIRA conference and the TB had little if nothing to do with my business. In fact my evaluation included a comment to have more A&A and reduce TB.
6912 Hours would have been perfect, but 16 is preferable over 8. A and A CPAs will always have the option of increasing their A and A hours (over the required hours)
70Not sure what the thinking is here. The only thing our license is good for is to render an opinion. CPA's should keep current on the A & A requirements. They already have 60 hours to pick up needed TB information. Unless the removal of A & A requirements then puts an asterick on a CPA license saying they can not do assurance work the CPE should remain a requirement. I could only support a reduction in this requirement if the overall # of CPE bi-annual hours was reduced proportionally.
71If you perform ANY Attest engagement a minimum of 20 hours should be required (20 hours in a two year period is not that much) - however - for anyone that ONLY performs tax work and never performs attest engagements I feel they should be exempt. The reality is those individuals waste those 20 hours just to satisfy the requirement. Typically, they gain nothing from it and their time could instead be spent improving their tax knowledge.
72I would be in favor of a reduction in the overall number of hours of CPE required. 80 hours is excessive in my humble opinion. If we, as accountants, need to read up on something, we do it while on the job. We don't wait for a CPE course. In this regard, we are actually spending time learning than 80 hours (every 2 years) because we also research things on our own time outside of CPE. Why do CPAs have the most number of hours required for continuing education of any profession? Who are we trying to impress? Doctors and lawyers have much less required hours of CPE to maintain their license. Their fields change just as much as ours does, if not more. Between the time away from work and the extra cost of obtaining more CPE than any other profession, it just doesn't seem worth it to me. So, I reiterate I would be in favor of less hours required for CPE.
73Great idea--the 20 hrs was 25% of total CPE hrs but it meant a third 8 hr day or a 4 hr self-study.
742nd alternative: Revise the current requirement of 20 hours to the following: reduce the requirement to 8 hours of A & A (mandatory minimum) with the remaining 12 hours to be used on any Tax subject matter education OR any combination of the two.
75I feel that the 20 hour requirement is not a hardship.
76 I wouldn't be against a requirement for substituting 30-40 hours of tax subject matter education in a 2-year period, say as a sliding requirement that failure to take 20 hours of A&A would result in a requirement for 1.5 or 2 times the number of hours in qualified tax subject matter, still within the 80 hour 2-year requirement. Example: CPA takes 8 hours A&A in 2-year period, which leaves 12 hours out of 20 hour minimum, times 1.5 or 2, or 18 or 24 hours minimum tax subject matter requirement, the balance of 80 hours to be taken in any other qualified TB courses. This would stop me from having to take A&A standards courses (because none other relevant courses are available to me) that have absolutely no relevance to my tax practice. Another possibility is to make the Ethics course part of any minimum requirement, instead of a separate requirement, or count as A&A. And qualified tax subject matter should include a required IRS Circular 230 course, a minimum of 4 hours every 2 years.
77 I do peer reviews and notice that a lot of compilations done by mostly tax oriented small firms often are lacking in many facets. I believe that perhaps it could be reduced to 16 hrs of A&A but I would like to see my fellow cpas take the A&A more seriously to improve the consistency and quality of the work firms put out.
78Either 1 or 2 would be preferable to current requirement. Thanks
79I understand that what differentiates a CPA is the ability to perform assurance work. However, for those of us doing valuation work, this requirement is very tedious. I could live with a couple of hours of something related to fair value and valuation (combined) but the rest of the requirement is a total waste of my education dollars.
80Accounting and CPA work has become so specialized that the 20 hour A&A requirement does not work anymore.
81A CPA certified public accountant needs to be refreshed every year in the accounting and auditing field so at least 8 hours should be allocated to gain knowledge and refresh the memory. Many CPA 's specialize in tax work or other consulting work such as performance improvement, internal audit, assiting clients with accounting and tax software hence justification for the remaining hours to be allocated as appropriate.
82The only service restricted to CPAs to perform is the attest function. All other services rendered by CPAs may be rendered by non-CPAs. The people who want to do away with the A&A requirement want the social and economic value of the brand but don't want to remain qualified for the one service restricted to the brand. There are dozens of designations out there for people not qualified to do attest work which allow them to identify their area of expertise. Please do not support the dilution of our brand by persons who actually do something other than that service limited to CPAs.
83 We must keep an accounting & auditing minimum hours to keep our members skills adequate. In 33 years of practicing, I have noticed an alarming decrease in accounting skills for staff and this trend needs to change. Very few have good analytical skills and struggle with simple book keeping tasks. Quickbooks is not the answer!!!
84Most public practice CPAs do compilation work so I don't think they should not be required to at least take 20 hours.
85 This change (I assuming for lowering the number of A&A hours) would only work if we create a speciality designation first. The public would need to know those that are competent to do the only service we as professionals have the exclusivity on or not.
86A&A is at the core of what we do. I think it should still be required.
87I am a tax person but even a tax person needs to keep up with the rules regarding accounting and auditing. Business tax returns are prepared from accounting records. . Even small CPA firms needs to keep up with the ever-changing rules regarding compilations. That could take at least 8 hours every two years.
88CPA's knowledge is a cumulative art. Why are CPE requirements of 80 hours every two years the same for a recent CPA candidate with no experience and a CPA with 25 + years of CPE education and experience. Why not credit for time served? Reduce the CPE required for CPA's with 25+ years of experience and history of meeting the CPE requirements to 40 from 80 every two years.
89Maybe there needs to be a requirement that if you do any attest or assurance work then you need to have the 20 hours of A & A and on the flip side if you do not currently do any attest or assurance work then you can't perform these services until you take the 20 hours of A & A. I believe that most CPA's would still take A & A just to stay current with financial reporting requirements.
90Even though I do not perform any assurance or attest work, I firmly believe that every CPA should continue to maintain and update their personal knowledge of the current accounting standards. Mark Burling
91The majority of my practice is in forensics and litigation support work for very complex industry specific work. Therefore, my work requires almost constant continuing education in industry specifics, governmental regulation, legal, fraud, investigative techniques, data analysis, software and a host of other disciplines. In the past the A&A has been the least helpful continuing education subjects and actually takes valuable time that could otherwise be used for training of greatest importance. Of course, I maintain my association membership and read pronouncements and changes in accounting practice requirements and issues. I congratulate the FICPA on reviewing this area particularly as the information age and sophistication of industry specific information and practices are accelerating at an accelerating rate. Changes in the CPE requirements for forensic accountants is a small way of supporting this important practice area of the profession. Thank you
92My practice does not perform any assurance or attest work therefore it is a waste of my time and money completing A&A continuing education. It would be more beneficial to my clients, our profession and my practice to spend my continuing education time and money on subject related to my practice and clients.
93I tend to not learn or retain information that does not apply to my work. I'd rather study areas that apply to my work.
94I'm not a fan of changing things for the sake of it - 20 hours of AA could be classified any number of ways - but I do like the version of 4 fraud and 8 technical on top of the 8 AA. That would be (IMO) the perfect balance - but I'm a fraud examiner and I think that being up to date on fraud is important. Good luck finding a consensus in this group. Please don't just advocate whichever position gets the most votes - if there is a 51% consensus on any of the 5 items, I don't think I'd struggle supporting that - but I wouldn't support something that just had 30%, but more than the rest of the options.
95The CPE requirements do not need to change. The people who have trouble completing either auditing or accounting hours should remember that the requirements are for LICENSED CPAs who with that license can conducts audits and who are by DEFINITION accountants.
96I believe CPAs are diligent enough to pick subjects in the areas they practice. If alternative 1 is not selected, Alternative 2, any combination of accounting or tax hours is good.
97I think that someone who works in the A & A areas should be receiving more than 20 hours per re-licensing period. If someone does not do any A & A work they should still be required to take an A & A Update course every re-licensing period and additional hours in the areas in which they do work.
98Every CPA should maintain a minimum knowing of all aspects of being a CPA, which includes Accounting and Auditing. Even CPA's with that practice exclusively in taxation should be required to maintain the minimum working knowledge. Otherwise, it dilutes the meaning and credibility of the CPA license. I personally believe the requirement should be 24 hours of A&A as a minimum.
99A&A is too important to revise downward.
100Thanks for addressing this matter for those of us that do not do audits.
101I believe that we should maintain a certain level of A&A credit requirement because CPA's should stay up-to-date on latest changes and promulgations. Especially, in this day and age where the profession is evolving (i.e., convergence, private GAAP, etc.). However, perhaps we should entertain how much A&A credits should CPA's have. What is the correct balance? Finally, should the A&A requirement be any different for CPA's that do not perform assurance or attest work.
102Don't become a CPA if you don't prepare financial statements! CPAs know the requirements for continuing education when they get licensed. Thanks,
103The requirement to get A&A hours is outdated as there are so many specialties within the accounting field that spending 1/4 of the hours requirement on something that an individual may never utilize seems incredibly wasteful. In my instance, I am a state and local tax specialist. I would much rather spend my time and money going to a training in my field that I'm going profit from than sitting through 10 sessions on some form of revenue recognition that I'm going to be reading my e-mails in.
104If the purpose of CPE is to protect the public, since I perform only tax services, the public would be better off if I devote no time at all to A&A and increase the hours to technical tax courses. I have been saying this for years. Thanks for this survey.
105Those who do attest functions need to police themselves and not force a requirement on all of us. Maybe require an update course for all of us would not be a bad idea
106The majority of CPAs perform a few or no audits. The A&A requirement is similar to the CPA exam that stresses knowledge of municipal and cost accounting, which also is not used by most CPAs. CPE course requirements should still be required however, let the individual CPA or firm select courses meaningful to their practice areas, rather than have a blanket A&A requirement. As it now stands, tax and technical courses (although substantive in content) are considered like the adopted child or runt of the litter. CPAs as professionals should be able to select courses that are both useful and instructional without the arbitrary burden of taking courses in areas that they will rarely if ever encounter in their individual practices.
107Mike, No doubt there is a great deal of specialization within our profession and that continuing professional education must be tailored to meet the needs of those working in those specialties. There is no limit to the amount of CPE that one can obtain. Traditionally, I obtain far more than is required by state law in order to keep my skills current. Having said that, I do feel it is important to maintain an understanding of accounting and auditing principles and the changes that occur in those principles and standards over time. I do not think it is unduly burdensome on any CPA to devote four hours annually to an A&A update, especially with all the CPE avenues available to our professionals. I like the idea of requiring 4 hours of fraud education as well and I believe we should continue the ethics requirement. In answering this question I am attempting to speak not only for my personal needs and wishes but for the needs of the several hundred CPAs that work for Carr Riggs & Ingram in the state of Florida. If you would like to discuss this further, please feel free to contact me at 850-201-5837. Thank you. William L. "Larry" Houff, CPA
109For those of us who do not practice in auditing, I believe industry knowledge is important and required CPEs in technical would allow more training in the areas that would benefit CPAs practicing in industry. That technical training can encompass both tax and specific industry practices.
110Even though members may not perform attest or assurance engagements they are still CPA's and were required to know this supject matter when they sat for the eaxm. New CPA's had to demonstrate that they had a sufficient level of knowledge to pass the exam and attain the title of CPA. I do not think that the 20 hour requirement should be changed
111A&A if little use in my practice do no audits or reviews. I am also not planning on doing audits or reviews in the foreseeable future. Only do very few compilations. Most of my practice work is in the area of taxation
112the requirement for most CPAs to take A&A credits when the loin's share of the practices will not deal with the majority of issued required by the PCAOB would lead me to believe that A&A is not as important to the CPA who is in public accounting. Internal Auditors, Public firm auditors should still be required for the minimum 20 Hours. Allowing for a combo amount would be beneficial so that if I am a tax practice drive shop, we would still be exposed to A&A thru the conferences that are attended.
113And while at it, reduce the ETHICS to about an hour a year. My practice in NO Enron!!!!!!!!! djb cpa :~)))
114Although I am involved almost exclusively in tax and related planning issues, I would feel quite remiss if I let my A & A knowledge slip more than it currently does.
115Two days of A&A is not too much to ask for when you have 8 other days of topics for your particular specialty and interests. Additionally, observations from past A&A seminars shows that this time is used by some to catch up on reading newspapers, magazines, napping and other miscellaneous things which they may not be able to do in the non-A&A seminars.
116The current environment of regulations in Accounting and Auditing is changing so fast it is very hard to keep up with the changes( Not counting what is happening in the area of tax). I feel it would be a mistake to reduce the required hours of 20 hours for Accounting and Auditing. Even if a CPA does not do attest work to be licensed he or she needs to have some knowledenge in the area of Accounting and Auditing to have the overall knowlegenge of the profession. Individulals practicing in the area of attest again with the fast changing world of Accounting and Auditing should be taking more than 20 hours of continued education to be able to stay current with all the changes. If a CPA is doing Corporate Tax Returns they also need to understand what regulations effect the structure of the financial statements. The continuing education is expensive and takes a lot of time for an individual especially for a sole practitioner but I feel it is needed to keep us competitive and the quality contorl of our practice. I hope this helps. This is my personal opinion.
117The A&A requirement is a waste of time and money for non-auditors!
118For those of us who do not do auditing, but do compilations, a lot of tax work and litigation support and fraud investigation, it seems like there could be a better system for getting credit for the very technical training we get in all of these areas. The fraud courses are included under A&A usually, however, there are too few of them. Many of the courses focus on fraud in the audit. The topic is much broader than that and I would like to see an expansion of the topics. I would like to be able to get my AA hours attending classes that improve skills for the work I am doing. Very few of the courses really cover the topics that we deal with in Litigation Support or Forensic Accounting. Another point is that I attend the FVALS Conference in Ft Lauderdale every January. It is a great conference, but this year it looks like there is one hour of AA. The rest is TB. Last year there were 2 hours of AA. How can you have a two day conference on Forensic and Valuation and only have one hour of AA? It makes me think the definition of what constitutes AA is not properly defined in this area. I appreciate your work in this area. It would be nice not to have to sit through 8 hours of material I will never use. Thank you!
119Those of us who practice exclusively in tax and are at a point in our career where a return to the world of accounting and auditing is highly unlikely, would benefit greatly by eliminating the A&A requirement. The primary benefit is additional CPE in our technical fields that would enhance our useful knowledge base. Let's face it, there are very few CPA's that are taking CPE beyond the 80 hour requirement. Those 80 hours should be spent productively!! The reality is that we tax practitioners who do sign up for A&A hours are oftentimes not focusing on the material contained in the CPE program and are simply "going through the motions" when it comes to our A&A credits. The younger CPA's practicing in tax can choose to add A&A to their CPE requirement if they wish to maintain some skills needed in the event they ever switch over to the A&A side.
120A&A is at the core of what most CPAs do and 20 hours is only 25% of the total CPE required per reporting period. I would like to understand the reasoning behind the desire for a change. Perhaps an exception for those CPAs that only (i.e., 100%) provide tax services, are tax educators, or tax consultants?
121A CPA not required to at least stay somewhat abreast on what is happening in the financial statement presentation and attestation arena? Wow! Where have we gone as a profession!
122I think the current requirements are fine. Although most of my work is in tax, I think all CPAs should be familiar with current A&A requirements.
123I happened to stumble on this survey. It should be emailed to all members to get an accurate view of membership.
124If one does A & A work, then the CPA should take on the responsibility to keep up to date on A & A but not be forced or required. The A & A requirements to obtain the initial license should remain. I usually laugh as I sit through the A & A CPE seminars since some of the topics are the results of the failures of those who had not follow the standards. There seems to be this disconnect between the profession and the real world. The profession deals too much with old stuff - stale historical data. At times I think the profession has lost its way in this area yet our nation's financial info and SEC are still the best because of our profession. The reason why I may attend an A & A course is that I can identify what may be M-1 adjustments on the tax returns. But I prefer not to have the requirement.
125Need specialty designations so that a CPA primarily performing assurance or attest engagements is identified as different from one that strictly prepares tax returns. Perhaps consider specialty designations like attorneys have.
126 This is a long time coming and I hope the rules will finally be changed. The genesis of this rule and it's popular name years ago was "The Dooner Rule". I loved Lou Dooner and was blessed to follow in his footsteps at the FICPA but Lou Dooner believed that a CPA was not really a CPA unless he was engaged in some audit work. Therefore, Lou used his influence as Chairman of the Florida State Board of Accontancy to have the A&A requirement set into motion and made a requirement that long ago outlived it's usefulness. My hat's off to those who are finally doing something about bringing the FICPA into the 21st Century. Art Stites
127As a licensed CPA in indurstry, I find it difficult to complete the 20 hour A&A requirement with material that is useful in my job. I do usually take the annual accounting update so that I stay informed of new changes, but struggle to find other usefule courses. I believe that there is a large number of CPAs that are in industry and not public accounting and there needs to be some choses for them to acquire uselful information and not just file a requirement. CPAs in public practice can of course take more than the required amount if they choose to.
128While I do only tax related work, I think a CPA should have a little continuing update of A & A.
129Auditing and Accounting updates are important to create a balance of knowledge in all areas regardless of a CPA's area of concentration.
130forty hours is too much every year, it should be 24 hours in either, accounting, tax, or auditing, or some other combinations.
131Is the perceived need to change CPE A&A requirements substantiated by analysis/feedback from peer reviews regarding auditor quality?
132This should only be available to those who do not take peer review because they do not do financial statements.
133Because ONLY CPAs can perform attest work, ALL CPAs should have the requisite knowledge to do so. That is what the public's perception is.
13416 hrs of A&A per reporting period seemed to work well in GA.
135I was in Corporate accounting for 39 years after 4 years in public accounting. A&A courses are relevant to all CPAs whether an auditor or an auditee. And we are all accountants. Plus, the 20 hours of A&A is only 1/4 of the 80 hour CPE requirements. NO CHANGE IS NECESSARY.
136The only service CPAs provide that other accountants can not is to opine on financial statements. Since, during a CPA's career, one never knows when they may be asked and agree to opine, they should at least be somewhat current on A & A.
137Strongly recommend NO CHANGE. Every CPA is involved in reading financial statements and the background knowledge learned in staying up on the subject matter is critical. I have served on the board of accountancy probable cause panel for more years than anyone in the state of Florida and too many times Florida CPAs get into areas that are beyond their expertise and then they come before us. It is my opinion that the number of complaints would increase if the 20 hour requirement was reduced or deleted. We do not need to put our CPAs in harms way by the lack of understanding of current financial statement format, presentation and report levels by CPA services. I know certain tax attorneys would like to see this change, however they still need to understand the proper format and disclosure with financial statements. These CPAs are issuing letters and are in litigation around this product all the time, they need to stay current. I strongly recommend that NO change be made to the requirement. Byron Shinn CPA Current Florida State Board of Accountancy Probable Cause Member ( OVER 12 YEARS)
138I usually do my education on line and do enjoy some of the accounting and auditing classes even though I am a CPA in industry and most is not pertinent to my field. I would much rather see a reduction in the number of CPE hours per 2 year reporting . For some of us in industry, we do not have the benefit to get CPE through our employer nor is the employer paying for the time out of the office and the courses. Which is why I usually cram a ton of hours in one year by taking a one year special fee course, like Surgent McCoy. ( I do enjoy their A& A classes) In comparison to other professionals, the number of CPA CPE hours is enormously more. Attorneys have 30 hours every three years, Insurance professionals have 28 every two years, nurses ( ? 20 a year) . Thank you for taking the time to review our educational requirements.
139At a minimum, I think every CPA should have an 8 hour A & A update - like our 4 hours ethics requirement (personally I think it should be every year, not two year reporting period). If we were to go this route I think the 8 hour updates should be state approved. If the A & A requirement went away I believe it would devalue our license with other states.
140I believe the CPA industry is professional enough to be able to determine what type of CPE will best benefit itself. For firms that do not handle any attest work, the 20 hour requirement is an unnecessary time and financial burden, with those resources best directed at material more beneficial to the practitioner.
141The A&A knowledge always seems to pay for itself for our tax partner. We do not specialize but financial statements and the underlying basics, are things clients expect of CPAs. We've told them that this is one of the reasons we are different. So now we are going to say, yes we are different, but we are also too lazy to take 20 hrs of cpe over TWO YEARS so that we know how to answer your question on revenue recognition. I guess all tax only CPAs will now need someone like me to either adjust their clients books to be correct GAAP, or for larger firms, the A&A staff will need to help the tax staff convert the financial data into tax data. Great for the firm - nto a real good deal for the client.
142For those practitioners that do not perform assurance services, we can be better serviced by taking other types of education in our field of practice. It would be an ethics violation to perform work that we are not competent to perform and therefore, we should not be allowed to perform assurance services unless our CPE is caught up and current in that area. Personally, I specialize in only valuation and damages work and have not performed A&A type work for over 20 years. Requiring me to take this 20 hours takes away from better areas of education that I actually get anyway but the cost of the AQ&A in time and money is a waste. If my Business Valuations work is for financial reporting, I would be taking subjects that qualify for A&A but there may not be 20 hours worth. I encourage eductaion but it should be relevant to the area of practice. Those of us that are credentialed from the AICPA or other organizations have to take education in out practice area to keep our accreditations. Hopefully, the state will recognize this is they are informed of our requirements. Thanks.
143 The cost of continuing education for those of us who are retired or semi-retired has become prohibitive (I have one compilation client) . I strongly suggest that the FICPA pursue legislation establishing, statutorily, a special licensing category in this regard; i.e. 40 hours bi-annually including 8 hours of Accounting and Auditing. Qualifying criteria could be age (over 75 and services performed).
144The requirement for 20 hours is too much when no work is done that requires that function. Thank you for pursuit of this needed change. I also recommend changing the four hours of fraud.
145I believe the profession should match the performance of engagements to the CPE required. Practitioners who are devoting full time to tax preparation should be able to focus on 80 hours of related subjects with no attendance at A & A seminars. However, such practitioners should be precluded from performing any step within an office review process which represents a quality control step in office processing of any compilation, review or audit engagement. Either they attend the 20 hours of CPE for A & A or someone else assumes responsibility. Sole practitioners performing any compilation or review services would be required to adhere to the 20 hour requirement.
146A&A is the heart of being a cpa, why water it down!!
147My practice is strictly tax returns and cash basis accounting. The 20 hours of A&A is overkill.
148I am a tax person. Having to comply with this A&A requirement has been painful. It is long past time for this to go away.
149None of the above. I believe that those who do not perform A&A engagements, e.g. tax personnel, should either have the 20 hr. A&A requirement eliminated or reduced to maybe 8 hrs.
150I only do a couple compilations, so the majority of my work is tax and consulting. While I am not a fan of A&A, I think CPAs must continue to be required to take 20 hours per reporting period. I not, it is entirely likely that some practitioners would let their A&A skills diminish over time, which would hurt the CPA brand. So, I do not think it would be a good idea to reduce or remove the current requirement.
151The 'A' in CPA stands for Accountant. It stands to reason that there should be some amount of required accounting CPE. But rather than allowing CPAs to allocate the required 20 hours to A&A or tax as they choose, I also believe there should be a required amount of tax CPE. I believe that those who practice in the tax arena generally do receive a lot of tax CPE, but those who don't practice tax preparation should still be required to maintain some knowledge of taxes. We all have to have some knowledge of taxes to pass the CPA exam and receive our license; why shouldn't we have to maintain that knowledge as a requirement of maintaining the license?
152We should reduce the CPE hour requirements overall. 80 hours is much higher than the lawyers. How about 30 total hours per year
153How are the Ethics hours to be considered? The choices given do not seem to address this issue. I do think some A & A should be required as there are many changes afoot in the accounting profession and one never knows how useful the information may be in the future or the direction one's career will take. It appears this request to remove the A & A requirements is from the older accountants such as my self who go kicking and screaming but never sit in the sessions if they are attending a live CPE session.
154For those CPAs where the attest function is not part of their practice, I don't feel the A&A CPE provides much benefit. We are professionals and should be able to manage our time and CPE course loads in a manner that maximizes our time outside of the office. This may also cause A&A presenters to tailor their materials to more focused to particular areas where attendees will take more away. Right now, the beginning part of A&A presentations seems very broad and low-level. If I'm doing work in that arena, the assumption should be made that I understand the groundwork. Likewise, if all I do is a few tax basis no disclosure compilations, I'm interested in different information entirely.
155Thank you for reviewing the current 20-hour A&A requirement. I am in the financial advisory sector now and feel an update on A&A of 4-8 hours over 2 years is good, 4 hours on Fraud is important, and the balance of hours in other topics that would meet my needs is much better than the current rule.
156As per question 1, I do not do any A&A work. However, I do and can appreciate what the designation "CPA " means and represents. I also believe that even CPA's who do no A&A work still should have a basic understanding of debits and credits and financial reporting, etc. So I believe an 8 hour bi-annual "update" course developed just to keep us informed of the basics would be prudent. It is always good to have a basic understanding just so we don't inadvertently do something that runs us afoul of the rules. That said, I could also see an additional alternative, or an expansion of the first alternative and/or a variation of the others. Perhaps, if you do not do any A&A work the requirement could be 0 A&A hours, but then you cannot sign or do any A&A type work including compilations. If do only compilations, then have an 8 to 16 hour A&A "compilation" CPE requirement (CPE focused just on compilations ), but have a 20 hour requirement if you do reviews, audits or other A&A work. Simply put, if you do not take any "specific" A&A CPE course, you cannot sign an A&A report of any kind. Make the CPE fit what you do. If you have skipped a few years (i.e. taken no A&A courses because all you planned to do was tax work, for example), but then want to go back into doing A&A work, you could have a rather stringent "re-certification" requirement, so to speak, for say 32 hours of A&A before you can begin signing A&A reports of any kind.
157I am a sole practitioner. I only do tax work. currently 50% of my CPE courses do not deal with tax. this does not help me or my clients. I would prefer to be able to take more tax courses and less auditing and accounting subjects.
158The Florida statute Section 473.302 (8)(b) has significantly broadened the definition of the practice of accounting to include many non traditional A&A areas including "services involving the use of accounting skills, or one or more types of tax, management advisory, or consulting services" Indeed many Florida CPAs are not practicing in the traditional A&A areas and instead only do tax, management advisory services and/or consulting services. It is thus, in my humble opinion, an outdated approach to require 20 A&A hours on all. This requirement does little or nothing for those who don't practice in A&A areas. I hope and pray the AA CPE requirement is adjusted to recognized the diversity in the practice of accounting as is delineated in the definition of the practice of accounting.
159Since A&A are not a significant portion of my practice I would like to have the ability to take courses in the areas I presently concentrate on in my work, as well as take courses which will improve my leadership, writing and speaking skills.
160I issue compilarions only to my clients who are basically mom and pop type businesses and used for internal purposes and income tax preparation only. I feel that the 20 hrs that I spend for A & A could be much more beneficial to my practice if I could obtain these hours in other areas of my choosing.
161I think the 20 hour requirement is important to the future of CPA's in that it keeps us up to date on what CPA's do. This is important whether you are in public practice or other area of practice where you are holding yourself out as a CPA.
162For those of us that just do taxes, 20 hours of A & A is a waste of time and money.
163I believe it would make more sense to have 2-3 'board certified" kind of sub-designations, which would be required to serve the public in those areas, and have a 20 hour minimum in related subject matter for each of those. For example, A&A for those who want to do audits reviews, tax for those who want to provide tax services as a CPA, or personal finance for those who want to provide personal finance services as a CPA. CPA's in private industry should be able to select subject matter most relevant to their jobs.
164We prepare very basic compiled financials with no disclosures. The FASB is just about irrelevant to my experience and to my clients' businesses. Please allow me to spend precious (and expensive) CPE time on tax and business topics that will add value to my practice. Kudos to FICPA for listening to it's constituents. We appreciate that.
165I think that it should continue to be 20 hours of A&A if you do any manner of AUDIT work. The adjustment / reduction of A&A should only be available to those who do no Audit work. I don't do any accounting work for clients, but I believe that if you hold yourself out as a CPA, you do need to stay abreast of the latest general trends in accounting. I believe my selection, above, was the closest to this interpretation.
166I am an Enrolled Agent, a Certified Public Accountant, and a Chartered Global Management Accountant. Those that do not desire to meet the requirements of continuing education for the "CPA" designation should become Enrolled Agents as the continuing education requirements for the "EA" designation are purely tax + 2 hours of ethics each year. I became a CPA because I wanted the credibility, and public recognition the credentials hold. I have held the EA designation for 10 years prior to becoming a CPA and there were numerous potential clients that I was not able to obtain because I did not have the CPA credential even though I was licensed to practice before the Internal Revenue Service. To change the requirements of continuing education would diminish the credentials that not only myself but all Florida CPAs have worked so hard to obtain and continue meeting the high standards of our license. The continuing education requirements are a minimum requirement of the state to keep our license and let's face it continuing education today is very inexpensive as offered not only through the FICPA but also through numerous vendors that compete for our continuing education dollars. I exceed the minimum requirements on a consistent basis because I want to learn more and be the best CPA I can. Thank you for allowing us to voice our opinion concerning this issue. Sincerely, Donald L. Drummond, EA, CPA, CGMA Partner GunnChamberlain, P.L.
167Only do compilations no audit or review
168We should do nothing to reduce current requirements. It is also important not to allow those practitioners performing attest services to substitute credits from other areas like tax
169I agree that there probably does need to be a minimal standard (core hours) for general knowledge throughout all areas, but 20 hours of A&A for a non A&A practitioner is too much. Possibly we could develop a system similar to Lawyers where we become "Board Certified" in the various practice areas. I vaguely recall that the AICPA and the GA Society of CPAs attempted something like this concept. A Board Certified Tax practitioner may be required to have 60 hours of Tax during each period. A Board Certified Audit member could be required to have at least 60 hours of A&A during each period. It could be a minimal standard that all members have the other 20 hours: 4 hours of Ethics, 4 hours of A&A, 4 hours of Tax, 4 hours of Fraud awareness, and 4 hours of behavioral. If a member wanted to be Board Certified in both Tax and A&A, they would be required to obtain 140 hours (20 core hours, + 60 hours Tax + 60 hours A&A) during each reporting period. I afraid, with the rapidly changing standard and tax laws, that the days of being a generalist are over, any CPA who thinks they can adequately perform both Audits and Tax are deceiving themselves and probably doing their client a disservice.
170A&A CPE seems to offer the broadest array of learning experiences that are technical enough to provide a real learning challenge,
171To require 20 hours of A&A for someone who doesn't do any auditing or review work is not particularly productive use of that person's time and education. Personally, the only attest work that I do is one or two OCBOA compilations without disclosures per year. I think it would be appropriate to require that I take an 8 hour course on this topic every 2 years for as long as I continue to prepare such financial statements. I am sure that there are others who fall into a similar category of work product and would welcome the ability to select courses that enhance their tax practice knowledge.
172Every CPA needs a baseline understanding of GAAP and GAAS
173I could live with a change in the number of hours of A&A required (but probably no fewer than 15). However, I am opposed to eliminating the requirement. I'm an accounting educator and perhaps I'm old school, but I know that the only real service a CPA can perform that no one else, by law, can perform is attest work. A CPA license is a nice credential for a corporate accountant or tax provider (etc.), but is not required. To me, anyone with a CPA license should be up to date on change to GAAP, regardless. Not sure how you can be a certified public ACCOUNTANT without keeping up with A&A, at least at some level. I don't find the current requirement overly onerous.
174Knowledge of current accounting standards is critical to every aspect of what a CPA can do. The current requirement doesn't make anyone take auditing courses if they don't perform attest functions. Keeping the A&A requirement continues to keep us focused on the bedrock of the profession. Taking this away would make all the tax practitioners no different than non licensed tax preparers.
175In my practice, I do NO auditing. It is a waste of time and money to require me to do 20 hours of AA. I would rather be spending my dollars on an area that would be beneficial to me, such as tax. Tax should have as much weight as AA.
176Even though we do not perform attest services, we have an obligation to stay current on the audit and financial reporting standards that our license is based on. One does not need a college education to do taxes or keep books, that can be done by training. We must be very cautious not to become mere technicians - India is as close as your Electronic device of choice.
177Due to the varied areas of the profession, I believe more flexibility should be allowed so professionals have more of a choice.
178I feel that to be a well-rounded accountant, you need to be current in the accounting areas as well as tax and other areas. I think that the current requirements are where they should be.
179Getting the minimum accounting and auditing hours is time consuming, can be expensive and oftern involves taking courses that have no useful application to the work I perform.
180While I wouldn't object to a requirement to attend an annual 4 hour accounting / auditing update class, the problem is the remaining 16 hours for the current requirement. You end taking some random accounting class that you never use just to get the hours where you could be spending those hours in the area in which you practice.
181As a sole proprietor, I do not perform any audits or reviews, but do perform 4 compilations. One on a monthly basis and three on a quarterly basis. All of my other work is tax related. I think 20 hours of A&A is not necessary for CPAs, particularly sole proprietors, who only perform a few compilations. I think 8 hours would be sufficient.
182Every self-respecting accountant should keep up with accounting and auditing, even if all they do is tax work. Otherwise, we have nothing to distinguish us as a group from enrolled agents. There is nothing wrong with being an enrolled agent, but a certified public accountant should be just that.
18320 hours every two years is 25% of the total 80 hours required.
18420 hour requirement should not change at all.........CPA's are accountants first
185While the 20 hour A&A requirement is rigorous for those of us who only do compilations, it does keep us in tune with what is happening in the profession.
186There are many CPA's who choose to maintain their license and not perform attest work. It seems silly to require those folks to sit through 20 hours of A & A when that time could be better spent updating their skills in more relevant topic areas.
187The profession's hallmark is the attest function, and so I believe that the requirement should be retained. However, for a practitioner who only performs compilation services, I believe one full day per year is sufficient to stay current with revisions. Clearly, those who concentrate in this area will obtain more A&A hours than the minimum.
188Everything is fine.
189I think that the younger CPA's who may not have set their path towards one area of practice over another would still benefit from required education because they are more likely to need a broader base of knowledge. I also agree that we should keep one level of licensing . Even a tax man produces a financial statement here and there and can still benefit from some A&A.. There are enough choices from online and face to face classes that make A&A relevant to everyone's practice.
190The reality of CPA practice today is that CPAs have become specialized. With the complexities of tax and auditing practice today, no one should try to be a jack-of-all-trades. There is simply too much to know. Requiring a tax CPA to take A&A is wasteful of his or her time, ignores these realities, and is not beneficial to the profession.
191I have been a practitioner in tax only for the last 20 years and I HATE having to do A&A. You don't require auditors to have a certain number of tax hours!!! I moved from North Carolina in 1997 to Florida and refused to transfer my license to Florida because of the A&A requirement. I finally had to because I left a large corporate tax department to start my own tax practice, so I had to transfer my license at that point, now I dread the 20 hours of A&A I have to do every year!! PLEASE change it!!!!
192 It is a bit frustrating that I am required to take A&A CPE hours when I've earned 158 hours in 2014 to date. I obtained my CFE and have completed 3 of the 4 ASA course requirements in the process. I decided to go this route because it is relevant and adds value to my career on a daily basis. Further, both designations will be extremely beneficial for my career long-term. I think the requirements should allow for CPAs to fulfill what is needed through interest in the many career paths chosen. I think we are using an outdated model with the set subject topics and need to evolve along with our profession.
193Based on my limited exposure, requiring 20 A&A CPE hours appears tilted toward the higher end compared to other States. Also, requiring only 8 hours seems insufficient for any CPA to be confident of his or her skills as a 'Professional', regardless if engaged (or not) in writing a report covering standards related to any level of reporting on financial statements. Therefore, given the limited choices available in this survey, I've selected the last option.
194The existing 20 hour required A&A should be maintained if and only if you or your firm/employer are engaged in audit work or preparation of financial statements. If you or your firm/employer do not do audits/preparation of Financial statements and do not carry malpractice insurance for the same, then no CPE should be required.
195Although I primarily prepare individual and busuness tax returns I consult regarding tax planning and the best business form to use. I find that taking GAAP update and review courses allows me to keep up with required asset classification and income recognition methods. Also, I believe it keeps up the CPA professional image and respect. I prefer the 16 hour requirement as it allows me to satisfy it with two 8 hour courses. I would also like the remaining 4 hours to be the Fraud CPE. With the 80 hour requirement I have ample hours to get tax preparation CPE. NOW, if you want to consider reducing the required hours to 60 every two years I am all for it!
196I don't really like any of the options under #3 even though I selected the second option. I think the CPE should have a general focus on A&A and tax for every licensee, perhaps 16 to 24 hours divided equally. Then licensees should have a secondary requirement for additional hours in a specific subject matter. For instance, if the licensee is primarily a tax professional then another 24 hours in specific tax topics. Or if the licensee is primarily an assurance professional then another 24 hours in A&A. The licensee should be required to indicate on their annual license renewal what proportion of their time is spent on assurance, tax, or other services and then report hours consistent with that breakdown. No change in the total hours per period and no change in the ethics requirement either. One change I think is necessary is to require a passing grade on a quiz given at the end of a training program to get the CPE hours for the program. I have seen too many people attending training with their laptops going and not, apparently, listening to the presentor. I have seen others sign in for the day then leave. That behavior really bothers me. It strikes me that some practioners feel as though the are just buying the CPE credit to meet a requirement without even attempting to enhance their skills, which is the main intent of the CPE requirements. I also think license holders that are not in public practice should only be required to meet the minimum for A&A. However, should a not in public practice licensee return to public practice they should be required to get a heavy dose of A&A during their first period back in public practice. Perhaps twice the standard requirement. I don't favor having two kinds of CPA licenses, one for assurance and one for tax. But I do think the CPE requirements ought to reflect the licnesees primary focus.
197The A&A requirement is not relevant to my practice, which is 100% tax planning & preparation. The A&A requirement represents a cost to my practice, because I must pay for CPE that I cannot use. I would much rather take 80 hours of tax CPE, which would be of greater benefit to me and to my clients, especially with all of the recent changes in tax law. I am also a licensed New Mexico CPA and they do NOT have the A&A requirement.
198Thank you for conducting the Survey. I think that CPAs who do not prepare financial statements are being unfairly burdened with the need for A&A CPE under the current rules.
199I suggest that if a member performs ANY accounting and/or auditing services or is responsible for review of such, that the 20 hours be mandatory.
200The A&A requirement should be required only for professional issuing audited financial statements in public practice. A&A requirement for CPAs specializing in tax, IT, MAS or Private industry is a poor use of time. The required A&A training is wasted time and greatly reduces the effectiveness of the CPE training for those who specialize in audit work. More and more individual CPAs are moving away from auditing because of the risk both professionally and financially. CPAs are, or should, be professionals and able to select CPE courses that pertain to their particular field of professional interest.
201As CPAs what distinguishes us from other accountants is strictly the attest function. The question is not if we perform attest engagements the question is do we have the ability to do so. If we have the ability to do so we should be knowledgeable enough to know how to perform or when to decline. 20 hours is not much in view of the whole.
202I'm not wedded to the particular hours in the choices, though I understand you had to create discreet choices. Spirit of the Law from my perspective: for non-attest (tax, PFP & consulting) CPAs, 20 hrs of hard-core A&A topics is a waste. I see the merit in requiring some A&A, and I definitely like the idea of fraud awareness.
203This will permit the CPA to at least have an update on the accounting and auditing changes and then provide additional hours for CPE in the area that his/her practice is providing to the their clients.
204If a change should occur it should be to increase the A&A requirement not to reduce.
205We should be required to have some A&A to keep abreast of standards. However, for the tax CPA, it's difficult to meet the requirement and doesn't give real value.
206Only rarely do I perform a compilation. Even then, it is an OCBOA (tax basis.) 8 hours of A&A would suffice.
207am a tax guy but find times where I need to have A&A knowledge to answer client questions. A level of A&A is good for all practitioners no matter what we specialize in. The CPA certificates all look the same.
208I picked what I hoped would be the most reasonable and popular response but I would personally happier with choices 1 or 2. Lawyers only need an average of 10 hours a year and CPA have 40, no reason why the legislature should not be willing to make a change. I think this survey would have been much more useful if you had allowed us to rank our choices of 1 to 5 and if you dont' get a clear picture from this you might want to send it out again with that format. Lynn
209I believe the Accounting and Auditing requirements of 20 hours per every two years is not a burden. The requirement is an important part of keeping CPA's abreast of changes in the financial accounting requirement that affect every aspect of work done whether it be tax or attest in nature.
210For a CPA who primarily performs the attest function: 1) Requiring 20 hours of A&A should be remain mandatory. 2) The 20 hours A&A could include 4 hours of fraud continuing education. Except for the 4 Ethics hours, the remaining hours can be used for tax or the technical subject category depending on the CPA's need or personal preference.
211 Florida Attorneys need 30 credit hours every 3 years - that is ONE QUARTER the requirement of CPAs. Florida Medical Doctors need only 40 credit hours every 2 years - that is HALF of what CPAs need. Forty (40) hours every year is too high for CPAs. I am a strong advocate of education - and firmly believe it should never stop - In fact - I personally have to date averaged much more than that over my career - I have already spent more than a full year of my life getting continuing education - but the education should relate to the subject matters of my work. And the market place will sift through the competent vs. the incompetent professionals. I have taken class after class to satisfy the requirement that has absolutely nothing to do with my work, then turned around and taken more classes that are relevant. As the rules stand now - a CPA that works only in the tax area, could get only Accounting and Auditing (and ethics) classes - with NO TAX updates - and comply with the rules -but would you want that person preparing taxes? And what about a controller or CFO of a company in industry? Sure they could benefit from a brief update in accounting, auditing and tax - but what they probably need most are classes that relate specifically to their industry, motivational and personnel issues - with industry probably being the most beneficial. Continuing Educational Requirements should better the person in his/her career - not just be a file stuffer. Other areas of work could be listed, but I trust you get the point. You did not give this choice, but what I would have voted for is a total of 20/year like Doctors - 2 of which should be Accounting/Auditing; 2 should be Tax and the rest should be discretionary to the individual but relate to their job/career.
212I believe that those who will be performing audits will have to be taking A&A anyway, and I would hope that Peer Review would be looking at that information as well...while not as a requirement for CPE, but as an indication of whether or not the individual and/or firm is doing their part to continually improve. Those of us CPAs involved in consulting endeavors would be able to use that time to become more proficient in our field of expertise as well...providing a better quality product to our client and reinforcing the importance of the designation.
213My comments reflect that 8 hours would be the minimum for A & A but additional A & A hours can be allowed. This change would allow CPAs who practice accounting and auditing to obtain more A & A while at the same time allow CPAs in Industry to obtain additional Technical Business in areas that are of interest and relevancy to them.
214Some A&A requirement is good, but not overkill.
215As an alternative to the general CPE requirement, please adopt a 24 hr concentration in a particular field such as auditing, fraud, taxation,governmental, non-profit, etc. This will enable accountants who specialize in an area to effectively use their CPE in the area in which they work.
216I do a lot more tax work and compilation work without footnotes. I like to have one yearly update class on compilation and review. I also take classes on identity theft, so 8 hours would generally cover the A&A requirement. I take at least 48 hours per year of tax update courses and I am a trainer on network marketing subjects, so I like the 8 hour requirement with the option to use other technical business subjects to round out my curriculum.
217I think it is important for all CPAs to "brush up" or at least get a review of current A&A topics, regardless of the amount of time spent applying this knowledge. Eliminating the A&A requirement completing or drastically reducing it would devalue the CPA license.
219I would recommend that the 20 hour A&A minimum be maintained if the CPA works for a firm that performs audits. I would also be in favor of reducing the A&A requirement to zero if the CPA is in tax practice and performs no attest services.
220There is such a diversity of A&A continuing ed available that practitioners should be able to find something that applies to one of their service offerings and improves their skills while still relating in some way to accounting.
221While not involved in assurance work, still believe 8 hours every two years to be necessary just to stay on top of developments in the area.
222Your practice will dictate the CPE that you need to take in any year. A requirement of a certain field of study id not necessary.
223As a former BOA member, I understand the mission the Board has to protect the citizens of Florida. And I believe that at one time the requirement for continuing education was important to that mission. However, the times they have changed and at times it seems the CPE requirement is our punishment for being a CPA. I am not sure how we ever determined that 80 hours was the magic number rather than the lower alternative. I guess if some is good, then more has to be better. Whether this provision for 80 hours really protects the citizens of Florida, or whether the natural forces of the marketplace are more responsible - I have never really been able to determine. When I became a CPA the opportunities for continuing education were very limited and the ability to keep up with changes in the profession were not easily accessible. By contrast, today I receive at least 6 newsletters per day to update me on accounting and tax issues. I can access all types of information online to support my practice. As a firm we provide all of our staff with constant training, not just to meet some hour standard but to make us competitive in the marketplace. In summary I think the days of requiring 80 hours of CPE have passed and we should be looking for a new system to protect the citizens of Florida.
224While many practitioners do not have attest services in their practices, in order for CPE to be meaningful and substantive, we cannot remove the A&A requirement. Since there is no other requirement at present, theoretically all of the CPE can be completed with just TB or Behavioral and that takes away the rigor from the profession. What is worth discussing is whether we should split into specialties for CPE purposes, so that practitioners can pursue CPE related to that field as long as it is substantive enough. For example a series of tax CPEs, or technology CPEs for respective specialized practices.
225There should be more flexibility since there's no need for 20 hours of A&A for CPAs not performing assurance or attest work.
226The current cpe requirement for A & A is not applicable to many small or one-person firm practices.
227Too many organizations trying to change everything at the same time. Taxes, Obamacare, IFRS, The quality of work that I am seeing and am probably performing is being impacted by the massive changes taking place and the irrelevance of most current accounting information due to the lack of comparability being brought about by these changes. There should be more not less A&A CPE however since there are more and larger penalties associated with everything businesses do, understanding technical issues or what would have been considered technical CPE should be reclassified to A&A due to the scope of issues encountered in simple A&A engagements.
228I do not perform any attest functions. While it is important to be current on this subject I believe 20 hours is overkill. I have a license in both FL and OH. In Ohio you get your majority CPE in the discipline that you are working. I currently don't practice at all but I chose to maintain both licenses because I worked very hard for my credentials and I don't want to let them go. Forcing 20 hours of AA on someone like myself that would have NO impact on the profession and NO impact on my current employment seems very restrictive. I believe they should look at the services provided by the CPA and assign the requirements from there.
229As an auditor, I am comfortable with the current requirements for A&A since it is applicable to me. However, for those CPAs who do not perform attest engagements, I believe more flexibility for courses more relevant to them would be reasonable.
230no audites or reviews / only issue compiliation report - I feel should only had to take a compilation update course each cycle and concentrate upon tax and consulting courses
231I feel as professionals, we will seek the CPE that relates to the services we preform.
232Ethics should be increased to 8hrs.
233The profession has expanded to many areas beyond tax and a&a and the educatijn requirements need to keep up.
234If you want to be a C.P.A., and the body of knowledge requires expertise in A&A, you should be ready to complete work product with sufficient knowledge. You never know what tomorrow will bring. If you are not practicing, go to inactive status and do whatever is necessary to maintain your license. I would even support a higher percentage of hours in A&A.
235If a CPA is preparing only compilations and not reviews or audits the max number of A&A hours should be no more than 8 hours. The FICPA should develope an 8 hour update course that provide these CPAs with the important relevant information related to performing compilation services. If nothing new has occured this might be done in 4 hours rather than 8. This discussion is late in coming. Thank you for finally moving on this.
236for those that don't perform audits, the requirement should definitely be lower.
237It is important that the CPA be able to educate/reinvent his or herself in an area of need. Many of us are specialized in this day and age. It no longer is prudent for us to spend 20 hours in A&A education classes, when our practice and/or specialty is not in this area.
238I only work on attest work so have to comply with the Yellow Book and will always require 80 hours of A&A. However, my partners who only work on tax issues need more T&B and less A&A hours. Why not have a two prong approach depending on type of work actually performed?
239For those CPAs who do not perform any audits, reviews or compilations, the A&A requirement serves no practical purpose. It would be much more beneficial to be able to take courses that apply to the work we do. Thank you for your consideration of this long-overdue issue.
240We know what cpe would be beneficial so let the CPA decide
241Although the public generally perceives CPA's to be "auditors", a vast number of CPA's do not perform any assurance or attest work. I believe the 20 hour requirement is too much for those CPA's. I also believe that the 20 hour requirement should not be eliminated entirely. As CPA's, even though no attest work is performed, we should at least be "aware" of changes in that area. I would suggest possibly a 10 hour requirement.
242As a 30+ year tax accountant, any time I spend in A&A is a waste of time better spent elsewhere.
243Since I no longer perform attest work, I would prefer to use those 20 hours in tax education.
244As a practitioner who occasionally prepares a compilation, I feel that compilation & review (A&A) is all that should be required, unless there is a peer review issue.
245I would like to see the A&A hours remain at 20 with an additional 4 required in Fraud or fraud related guidance. There are still too many issues, and as with SSARS 21 and the preparation engagement for those not aware, would they even know about the new type of engagement if they hadn't done CPE?
246As accountants we can't afford to stray too far from our designation or risk diluting its power. We will always be held to a higher standard as to A&A and thus have a duty to stay at least marginally informed.
247Even people who do not perform auditing work need accounting updates; however most A&A update classes talk about philosophical issues surrounding proposed changes to accounting standards. Most people just want to learn what has actually changed since they last went to school. The reality is that people must have continuing education so they will seek out what is most useful to them in their respective positions. It is hard to sit through 8 hours of a topic that doesn't apply to them.
248In many seminars, there are CPA's in attendance that are FORCED to take A&A and you can see it's a waste of time for them as it is not part of the work they do. I can use the A&A hours but sometimes I find it repetitious and would prefer to take a NON-A&A course to expand my horizons.
249I do like the idea of adding a continuing education requirement on Fraud.
250I am a CFO for a private company and during the current reporting period I had over 100 hours of CPE, unfortunately none under A&A. I have had to take another 20 hours of CPE to fulfill this requirement.
251While I specialize in tax, I feel that the A&A requirement is necessary. There are plenty of A&A classes that are still applicable to tax such as internal control and forensics. We sometimes need to be forced out of our box to maintain perspective.
252I think that 20 hours is a good number of credits to keep all of us abreast of any changes. Even though I do not perform any audit nor attestation functions it is good for me to have a basic knowledge in this area.
253Limit the scope of A&A hours to 8. Not all CPAS are doing attest services. 8 hours allows CPA to take courses that will cover general updates on financials and report standards. And will allow for those 12 hours to be used on areas that they are currently involved more like taxation.
254As a professional with over 46 years of experience who has worked initially with the audit department of an international accounting firm and later on as a professional solely in a tax practice, I feel that the individual is well qualified to determine what continuing educational program will benefit the most for his/her needs..
255An elimination of the 20 hours of A&A requirement would be more in line with the new SSARS 21.
256I think the A&A CPE requirements should be separated based on the level of assurance/attest work performed - 8 hours annually for those who only issue compilations, and 16-20 hours for those that issue audits, reviews, or other engagements under SSAE.
257Many of us do little or no accounting or auditing, and the hours would be much better spent in areas in which we actually practice.
258I support reducing the Accounting and Auditing requirement because I do not do any assurance or attest work with financial statements. I always have a difficult time finding AA hours. If a CPA does assurance or attest work, then the requirement should continue.
259I work in industry and the 20 hours of A&A needed is excessive. I have a hard time finding enough courses relevant to my needs.
260Thank you for doing this. We are not all 'big 4' firm CPAs. I like to tailor my CPE to the needs of my practice, to the extent possible. Keeping in mind that as a CPA, with the inherent responsibility of the privilege, any assurance or attest work would be preceded by voluntary education fitting the need. You might want to create a requirement for compilations, as this work may be more prevalent.
262I don't have a problem with the twenty hours in A&A... 1. I have a problem with 80 total hours, which is an entire work week per year. Should be lowered to 40 or 50 for a two-year period. 2. I have a problem with ethics being required within every two-year cycle. It is repetitive and has little impact. Maybe shift that to once every other cycle rather than every cycle.
263Many CPAs do not do tax or audit work. My primary business is forensic and audit and accounting cpe is irrevelant to my work and is a waste of time and money.
264I opened my sole proprietor practice in 1985 and have never had any form of attest engagement and never expect to in the future.
265Too many ignorant, uninformed and obviously non-current CPAs do not need another excuse to learn nothing and know nothing. Leave the requirement alone and hope those who complain actually stay awake in the CPE sessions they are "forced" to attend.
266As a tax practitioner I get nothing out of the A&A CPEs. You can always tell who is in tax at those presentations - the ones who are not paying attention because they neither know, nor care, about the topic. We do not make auditors sit through 20 hours of tax CPE so I do not understand how this makes sense or is even fair.
267A large number of members no longer perform attest work due to liability invoved and the requirement could remain for those who wish to practice in this area.
268I have been a Florida CPA for 30 years. I have a substantial practice that is totally devoted to tax, business consulting, estates and trusts. It is a total waste of valuable time to spend 20 hours every two years on A&A when I could be devoting more CPE time to the field of accounting that I totally devote all my time. When I take A&A seminars, I look around the room and sadly see the vast majority of the class either doing work on their laptops, answering emails or reading the newspaper. When I am in the tax update seminars, the overwhelming majority of the class is actively engaged in the topic, asking questions, etc. It is time for our licensing bureau to take its head out of the sand and address reality. Sincerely, Jeffrey Hahn, CPA
269Allow us to choose how we get our CPE. Even though a person may not do any assurance work, they may find a course to be interesting and want to attend anyway.
270As a professional you should be aware of whats happening within your profession and that's all that this requirement is doing. It certainly will not provide the in depth training to do auudits or prepare complex financial statements. Many non audit or non attest clients are are sophisticated. Financial statements , the PCAOB and accounting changes are covered in the business section of most major daily newspapers as well as financial publications. We should at least have a general knowledge of these matters and that is all this training does. It may also create opportuniities for practitioners to go to the next level.
271Good luck on the law change. It is really needed!
272There is no minimum requirement for any other CPE area why should A&A be any different? I think there should be a minimum of 8 hours in both A&A & Tax with the balance left to the practitioner to apply to whatever areas they specialize in. As the accounting world continues to only get more complicated practitioners are forced to specialize so why force our CPE to have hours delegated to areas that may have no impact for certain practitioners.
273I perform a minimal amount of Compilations annually and do a substantial amount of consulting and tax compliance. While it is important for me to stay on top of issues regarding GAAP, I believe that I can be the best judge of the amount of hours I need annually above the 8 hours.
274I believe as a CPA we should be award of "all" accounting issues, not "just" tax
275As a tax professional, the A&A requirement is too large. 20 hours of A&A out of 80 total yields a 25% concentration in a subject that is less than 5% of most tax professionals' time.
276Twenty hours of A&A is a lot for a tax person who does no audit work. I can usually find accounting or fraud topics that fit into the category but at least one or two of the sessions is a waste of my time, and I would rather spend my time on a tax topic. I like the idea of having fraud in the mix because it has become a hot topic. My second choice would be to make it 20 hours of either A&A or tax.
277I am a Florida CPA and Florida Attorney. I do tax planning and estate planning. I think all CPA's should have 8 hours dealing with the attest function including fraud, and the balance of the hours should be technical.
278I think it is important for all CPAs to keep reasonably current on accounting issues. Even tax preparers get involved in accounting issues. I see no need for a change.
279I believe ALL CPAs should have A&A understanding and education every year. The current requirement is adequate.
280More and more, there is a segregation between tax, audit and consulting as with the increased complexity and cost of compliance practitioners are becoming one or the other but not both. I am predominately tax, but also do business valuation work, which has a CPE requirement, and to meet the needs of all that I do, and including the A & A hours, I am immersed in CPE each year. Practitioners who need CPE in specific areas generally seek it, and should be allowed to structure their own CPE to meet their practice needs.
281I am a CPA with a Masters in Tax Law and I never have any need for any hours in A&A. I was licensed in Massachusetts where they did not have a minimum for A&A and I could enjoy new management business type programs which were very helpful to any partner in a firm with several employees. The 20 hour requirement is a waste of my time and my money. Sharon Ryan, CPA
282I do not do any audits only tax and compilations, so more tax matter education would be beneficial to my firm and me. Thanks, Mike Lowe, CPA
283How can you prepare a tax return if you don't know accounting? Book to tax differences....
28420 hours is way too much A&A for someone who does not do and assurance or attest work.
285IF the Board finds favor in requiring a minimum number of A&A hours, four (4) hours a year for updates should do it for those of us who only perform Reviews and Compilations.
286It would also seem that one should not be limited in the areas of other business and technical CPE because in today's rapidly changing world, we as CPAs need to have a basic understanding of so many areas. I also think we should be able to take more behavioral CPE depending on the job.
287We all need to keep abreast of current standards and pronouncements. I believe that a course should be required within the first six months of each year reviewing all new standards that have been officially adopted during the prior year. If there are no new adoptions in a given year, then the course could be replaced with a course of the licensee's choosing.
288The ONLY exclusive service that the CPA license bestows is the ability to provide assurance on financial information. When the CPA license holder no longer has education in the ONLY exclusive area that the license provides then the reason to have the license evaporates. While other jurisdictions have bowed to the whims of those vocal folks who just "don't want to take A&A", many of which are lawyers and tax people, the long view is that the license becomes meaningless if the license holder no longer knows about the ONLY exclusive subject matter licensed. When A&A is taken out of CPA then the value of the CPA becomes much more like the CMA, CFP, CVA, CFA and other "trade association" designations - none of which have a state issued license. In the not to distant future lawmakers will become aware that the CPA license does not require A&A and will then move to limit the licensees to those that just do financial statements. The loss of membership for both state and national CPA "associations" will be huge as large numbers of current CPAs are no longer licensees. The long view from my point of view is that the license provides many benefits but ONLY assurance is exclusive to the CPA. In order for the CPA license to be relevant then the licensee needs to remain current in the ONLY thing the license exclusively provides.
289HOWEVER, licensees that state on their renewal application that they are not responsible for, and do not sign accountant's or auditor's reports should be able to substitute technical subject matter, at their option, for all of the current 20 A&A hour requirement.
290I am fine with 8 hour requirement but fine if it is optional. In what I do, it is not necessary for me to have A&A.
291I perform only litigation and oil-gas accounting related consulting. I am licensed as a CPA in Texas and generally take only enough accounting hours to remain current on reporting topics related to oil and gas. A rule change in FL would allow a much more efficient use of my CPE time and dollars. Thanks
293CPAs that do no compilation, review or audit work should not have to study areas that do not concern them.
294I believe we need at least 8 hours of A&A to maintain the relevance of being able to perform attestations.
295Eight hours per year of Accounting & Auditing CPE should be sufficient for maintaining a CPA's working knowledge of the professional standards related to accounting and auditing. The nature of a CPA's practice, not some outdated statute, should dictate how a CPA allocates his or her time spent in pursuing continuing education. In all likelihood, given greater flexibility in choosing CPE would result in an increase in the likelihood that the CPE obtained is pertinent to his or her practice. True, the current requirement of 20 hours assures that the CPA exposes himself or herself to 20 hours of CPE in A&A, but this shotgun approach does nothing to assure that he or she benefits from the requirement. Allowing CPAs to chose programs appropriate to their practices is far more likely to create an environment in which they actually learn something from the experience.
296The vast changes being made to "catch up with the Intl Standards" look silly when the size of the FIFA audit failure is seen, and the ridiculous 'record whatever income you 'feel' will be proper for the year would be a travesty. Lawyers and insurance companies and practitioners would miss the camels while gagging at all those gnats. I think the smaller time increments (less than 50 minutes) would be an improvement. More record-keeping, but it mirrors the way we learn right now. The cont ed is just piled on top of our self study.
297Although I do a minimum amount of A and A work I feel it is imperative to be aware of current standards
298As a tax practitioner, anything to reduce that 20 hrs would be great - I like the idea of 4 hrs of fraud, also.
299It is really a waste of time and resources to require 20 hours when a CPA may be specializing in other areas. Instead of 20 A & A, it would make sense to allow additional CPE in areas being practiced by a specific CPA. I have obtained my PFS and am continuing to increase my services accordingly. But now not only am I required to obtain a certain number of CPE hours in this field, a good idea, but t I still have to waste my time doing 20 hours in a field that I have chosen NOT to utilize at all. Our firm has chosen NOT to do audits or reviews and I have chosen not to even do compilations but to work with Tax and financial consultations. This ongoing requirement is more like regulations espoused by government entities and not what I would expect from an organization that acts to assist us in being professional and updated in our areas of expertise. That's my 2 cents worth. I hope that the organization takes this feedback and stops putting CPA's in a one size fits all world of prior generations when the emphasis over the past decade or so has obviously been for expanding our horizons and specializing in various areas. This ain't my mothers CPA world anymore (or my brothers or my wife's, a family of CPA's). Each of us have practiced as CPA's in different areas and the AA requirement is not relevant to any of us. (except I do get to read my newspaper or do Sudoku while sitting through another boring AA course-boring because it has no relevance to me.) Thank you for this survey. Now I hope it is also followed up on. I really find the arguments in favor of it to be somewhat spurious. Keep it in place to keep us "better" than ordinary accountants? Not logical. Keep us professionally trained in our areas of expertise. This would continue to separate us from others.
300I would like to add that the 20 hours of A&A include the 4 hours of Ethics, 8 hours of A&A, and the remaining 8 to be tax, technical subject at the CPA's choice or Change A&A to be 24 hours of A&A to include 4 hours of Ethics, 8 hours of AA and the remaining 12 to be tax, technical subject at the CPA's choice
301I believe 20 hours of A&A is unnecessary, although I think some smaller requirement should be retained. But I would prefer no A&A requirement to the other proposals. Adding Fraud would only complicate the system even more. Reducing it to 16 hours is not much of a change.
302My choice stresses that tax is a needed requirement for all CPAs, even Auditors.
303Technology is a large component of the work most CPA's perform, whether in public accounting, industry or government. I would like to be able to spend more of my CPE hours keeping abreast of the latest technological developments and a little less on the still very important topics covered in A&A CPE.
304 It appears to me that the A & A FL CPE is geared to the larger firms. With myself and one other non-owner CPA, we do not perform reviews or audits. Most of my work is tax, administering family trusts, litigation support and expert testimony (probate, estate & trusts). Compilations are only for fiduciary accountings. Need to make the change to needed CPA for small firms.
305While I agree that all licensed CPAs should maintain their primary skill of A&A, I believe that 20 hours is excessive for those who do NO attest or financial statements engagements. Perhaps this portion of the CPE requirement could remain at 20 hours for those in the peer review program, but reduced for those whose practice is limited to Tax.
306If carefully selected, 8 hours should be enough to get a cursory review of what is going on with A&A for those of us that perform no attest function engagements.
307A&A is at the core of being a CPA.
308I think the Tax experts need to be able to focus on their area, and the Financial side on the AA area.
309Not performing audits or reviews, and with the increasing time pressures of having a tax intensive practice, I find myself searching for the cheapest,easiest A&A CPE just to satisfy the requirement. Those 20 hours could be better spent learning about subject matter that I would apply to my practice.
310I have no interest in performing any A&A services for clients. I think my CPE hours would be better spent getting additional education in tax, which is the area that I practice in.
311The current requirements are ridiculous as it applies to me.
312I do not do any A&A work. But I believe it is still my responsibility as a CPA to be aware of the A&A provisions because they might impact aspects of my tax return practice. One meaningful A&A update seminar per biennial period should be enough for those not engaged in A&A practice.
313Unfortunately the way most courses are set up, if a CPA not interested in A&A education can get their 20 hours of A&A without paying any attention to the material. Therefore there is no real A&A education occurring. I'm not sure you can correct it though, no matter what you change it to.
314We are CPA's. Quit diluting the designation. Yes, public accountants should be current on accounting issues.
315Even CPAs who do only tax work could do well to have a well rounded body of accounting knowledge. No change is necessary.
316Good move folks!
317The requirement for 80 hours (for 2 years) of A&A for yellow book audits needs to be reduced to 50 hours or less.
31880 hours of CPE is the highest for any Florida profession. The hours needs to be reduced to 40 hours biennial. Florida engineers 18 hours biennial. Florida pharmacist 30 hours biennial. Florida Attorneys 30 hours every 3 years. Florida physicians 40 hours biennial. Florida Veterinarians 30 hours biennial. Suggest FICPA take a survey of FICPA members asking the number of hours they think the CPA profession should have biennial.
319For myself the removal of any auditing requirement would be very meaningful. I only do Write-ups and tax returns for my clients. I am semi-retired and have not intention of do any audits, reviews or compilations nor have I do any in the past 35 years. I would rather take more tax, computer and technical course which would better meat my needs in the profession. I hope that the change will be made very quickly.
320I am a PFS credentialed CPA and do not perform A&A services for my clients. My tme is wasted going to TWENTY HOURS of A&A classes each two year cycle. My CPE education could be greatly enhanced if I could take more classes dealing with financial planning to improve my planning skills in the areas of cash budgeting, retirement and estate planning. I agree some A&A should be required but 8 Hours would be sufficient to keep me abreast of changes occurring in the A&A area. I take several hours of courses beyond the 80 hours every two year cycle to maintain my knowledge in the ever changing field of financial planning. If it were necessary, I would be sign a statement that I do not perform A&A services if necessary to reduce the hours I waste sitting in A&A classes. Besides the time lost out of my office to attend the A&A classes, I incur costs (registration and transportation costs) to attend these classes. Would it not be better to be in my office productively helping my clients plan, execute and monitor their spending habits (budgeting), investments and retirement resources? The change to reduce the A&A hours would result in a win-win: more time to serve the public from professionals who have been able to attend relevant education to become more proficient in the services we offer to the public!
321 Reduce total required hours from 80 to 40 with 4 hours of Accounting and the remaining 36 hours in any other subject. Those of us in the accounting and tax business need to keep up with the changes in the tax law and would do so without a requirement. My study group meets for 2 hours 20 times a year with 1 hour devoted to A & A and 1 hour to tax. We watch a tape by Bisk as subject matter and there is great interest in the hour of tax but not much in the hour of A&A. The most interest is when we exchange between ourselves our experiences with tax subjects or what is going on with the IRS and the State of Florida Department of Revenue. At today's session we discussed how the State is performing wage and hour exams on S corps and classifying all S distributions as wages, and assessing payroll taxes, penalties, and interest without regard to the fair and reasonable standard the federal courts have applied to S wages v distributions. I would favor making those CPA's who want to provide auditing, review, and compilation services to have different education requirements than the rest of the profession and a more intensive peer review as well as recertification requirements every few years. Those of us who do not meet the requirements would be barred from performing those services.
322 All of us are adults and are aware of the requirement to be proficient in those areas that we practice. Therefore, the choice of subject matter should be left to the individuals so that they can make the best use of their time and their dollar expenditures.
323While it is important to persuade us to take some A&A, I believe 16 hours is adequate and a more practical requirement. This would work out to one 8 hour day per year, which should be enough to stay informed on current A&A updates.
324I cannot imagine a CPA who doesn't earn ANY hours of A&A. The "A" in CPA means Accounting. 20 hours every 2 years is only 10 hours a year. Surely this amount isn't an undue burden.
325Those of us that do not audits....too many of the courses in the A & A area are meaningless. As a responsible CPA, we should be able to decide what are the most appropriate courses to keep up to date for our practices. Personally, I generally end my 2 year period with over 100 hours of CPE but always struggling to find and take A & A that interest me!
326The CPA license is not required to provide tax services. Fraud should not be singled out. It should remain as a part of A&A but not be spelled out like Ethics. If the CPE requirement for 20 hours of A&A is changed then the law that licenses CPA's should be changed also to license CPA's to provide tax, fraud and/or various other services. In that case then a specific CPE requirement should be added to cover the specific service(s) offered.
327As a tax specialist, there is no redeeming value to me in obtaining 20 hours of A&A. Those 20 hours would be beneficial to me and those who I service. By taking all my CPE is tax, I would be better informed about matters that my clients are expecting.
328I think 80 hours every 2 years is more than is needed to keep current, most of us spend more than this amount of time reading anyway but just don't get credit since it is not done in a CPE environment. I think 80 hours is ridiculous, I would say 40 every 2 years in any subjects the practitioner thinks they need to be proficient in the type of work they currently do. It is just a money maker for the course sponsors and a real burden on practitioners in both time and money. The biggest cost being lost time.
329In my business, for the past 35 years is do monthly bookkeeping, financial planning (PFS) and tax services. I do no audits, reviews or compilations. Its time for a change. when I do my 20 A & A, I take the classes for just the hours, not the knowledge, like I do in Taxes and Financial Planning. Thanks for considering a change.
330Although I don't do attest or audit work, I am a corporate controller and my books are audited. I need to know the latest A&A changes but 20 hours is overkill. I normally get my A&A hours with Fraud classes so I'm only in favor of this choice if Fraud classes will still count for A&A .
331In response to this comment quoted in the 12/17/15 NewsFlash: "Key to this is the concept that the CPA credential differentiates us from accountants and bookkeepers by allowing us to perform the attest function, which those without a license cannot do. Therefore, completing proper education in A&A subject matters each licensing period is necessary to retain the expertise that makes us CPAs." As a CPA who has practiced solely in TAX for her entire 25+ year career: although my CPA licensure might "allow" me to perform attest functions, 20 hours of A&A CPE every two years is NOT sufficient for me to perform attestation. My doing so would be malpractice, whether allowed by our licensing and CPE requirements or not. From a practical perspective (as noted by another commenter), CPAs tend to choose continuing education that is relevant to their professional practice; those that perform attest functions focus on auditing and accounting education, those that are tax practitioners focus on tax law areas of specialization and general law updates, etc. Florida should also take into account the educational requirements in other states. Do other states require ALL CPAs to obtain a minimum amount of auditing and accounting continuing education, regardless of whether or not they perform attestation? I have friends with CPA licenses from several other states, and none of them have similar CPE requirements for A&A to Florida. Bottom line: we are professionals. Let us decide which technical areas of continuing education are appropriate for our specific job responsibilities. Thank you.
332I am the compliance officer for my company, yet maintain my CPA license. Since I am not practicing as a CPA, the A&A hours are largely wasted on me: it would be much more beneficial to my company (and my own professional development) if I used some of those hours on continuing education that is more relevant to my career.
333We should continue our education in all areas. If we don't --- then we fall behind if an issue comes up.
334My real response is to reduce the number of hours required to 40 per reporting period. No other profession (attorneys, doctors, teachers) that I know of requires the number of hours of CPE that this profession does. I don't think it's necessary.
335The 20 hour requirement is different from all of the other states and need to be at least the same not more than all other states.
336I would prefer to be able to obtain credits that apply to my daily job functions. As EVP & CFO of a Foundation, accounting is only a small portion of my job responsibilities. A change should be made to align with the AICPA and CIMA's partnership which realizes we are more valuable than just looking at and recording the numbers.
33720 hours of A & A credit, 25% of the total CPE credits required over a two year period is minimal. Everyone should stay abreast of current changes in reporting requirements for assurance and attest work. There have been major changes to report letters, engagement letter requirements, etc. recently and there are several changes coming down the pike. All CPA's in the State of Florida should be required to have A & A CPE and 20 hours (10 hours per year) is not asking a lot of anyone.
338The practice I work in focuses mostly on tax. However, we do have occasion to prepare compilations and reviews. Even though I'm not a big fan of A & A CPE, I recognize the contribution it makes to my understanding of how to prepare those types of financial statements. Being forced to take those courses keeps me up to date on new promulgations and rules in an area that I might otherwise neglect if not for the requirement. However, if a CPA practice/practitioner performed only tax work, I think it would be acceptable not to require A & A.
339I would amend that the four hours of Fraud to include either A & A topics, or tax topics.
340I do not perform any A&A & therefore the CPE time spent on those is wasted.
341I think being licensed means that you meet the requirements of the designation whether you do attestation services or not. Therefore, remaining current on accounting and auditing standards is paramount to holding one's self out as a CPA. I think a reduction in A&A to 8 or 12 hours would still provide sufficient exposure to the subject matter. I think a part of the dissatisfaction is also because so many conferences offer technical hours rather than A&A hours and the A&A coursework has not been as readily available to obtain. I also feel that there are limited opportunities to obtain ethics hours. I think 80 hours over such a short period has become a burden for many and consideration should be given as to how to best proceed with this requirement. It may be that you keep the same hour requirements but lengthen the time to a 36 months licensure period.
342I believe that as professionals we are able to gauge what the appropriate amount of continuing education we need is in order to maintain a current knowledge of the different areas of accounting in which we engage as a firm. From my 30+ years of experience in the field of public accounting I have always felt that the 20 hours is very redundant for the areas of A&A in which I have engaged in my years of practice. I do believe there needs to be a minimum of 8 hours required every 2 years and if the individual firm recognizes that there is a higher need due to the type of A&A engagements they provide then they should be astute enough to take the courses and number of hours they feel will keep them current and up to date in the A&A realm. There is nothing stopping a firm from taking more than 8 or 20 hours if there is a need for additional A&A but to mandate that every licensed CPA should have a minimum of 20 hours of A&A regardless of the type of engagements they perform and services they provide has never seemed appropriate, fair or necessary in my opinion.
343I think the 20 hours A&A Credit requirement every two years is adequate and not excessive.
344We must remain mindful of what sets us apart.
345Having knowledge of issues impacting CFO's of private companies, especially small businesses, is infinitely more meaningful.
346CPA's should not have to designate on license what king of practice they have; will lead to specialization issues, advertising claims etc If CPA's do not want to keep up with A & A, they should give up the CPA license and just become accountants/bookkeepers/tax preparers. without the higher designation Dilutes the license/brand/designation!!
347JONATHAN S. INGBER c/o KWAL + OLIVA Alfred I. du Pont Building [Suite 800] 169 East Flagler Street Miami, Florida 33131-1296 (305)-577-4333 [Downtown Office] (954)-632-3714 [Cellular] (954)-384-4716 [Home Office] 2544 Jardin Lane Weston, Florida 33327-1511 Sydney Traum, Esq. c/o Levy, Filler, Rodriquez, Kelso & Magilligan, LLP 1688 Meridian Avenue [Suite 902] Miami Beach, Florida 33139-2712 December 8, 2012 Dear Sydney: As requested by your e-mail dated October 18th, having the requisite hiatus in my travel schedule, I will now respond, in the order appearing in your proposal, to the ten points raised, explaining why I am not in agreement with the change that you are advocating: 1. Without commenting on Governor Scott, whose signature may be required for other enactments sought by the Florida Institute of CPAs, concerning the need for administrative regulations, permit me to recommend a perusal of Bull by the Horns: Fighting to Save Main Street from Wall Street and Wall Street from Itself by Sheila Bair, former Chairman of the Federal Deposit Insurance Corporation. Ms. Bair is a Republican and former Kansan. 2. While public perceptions are not to be ignored during the legislative process, it should be noted that members of the bar and enrolled agents are also exempt from the continuing education requirements imposed upon registered tax return preparers. Whether or not “CPAs are [in fact] the most knowledgeable tax return preparers”, much of the preparation process is dependent upon accounting skills, and, surely, the ability to appreciate the distinctions between generally accepted accounting principles and federal tax accounting rules is dependent upon a knowledge of the former to better appreciate the differences of the latter. 3. Your stated dichotomy of “tax work” and “accounting and auditing” implies that the former is not dependent to a considerable degree on the latter. I respectfully disagree. One example should suffice. Often, the accounting records of an “eligible entity”, such as a partnership, arrive in our downtown Miami office in other than pristine condition. It takes a talented set of accounting professionals to transform the untidy mess, a not unduly harsh description, into a format that then permits an equally talented set of tax professionals to begin the process of preparing a partnership income tax return. Without the preliminary accounting work, ultimately supported with the requisite documentation, the ability to apply the more abstruse provisions of subchapter K would be severely diminished. 4. The relatively small number of mandatory twenty hours of continuing professional education courses in accounting and auditing suggests to me that the Florida legislature has fully recognized the fact that the professional’s practice includes many other tasks beyond the preparation of compiled, reviewed, and audited financial statements. 5. The solution to the problem of a limited number of continuing professional education accounting courses that contain tax-related materials is to commission the creation of additional courses, not to eliminate the requirement of such courses. The coin of the realm expended to preserve one’s designation as a certified public accountant is clearly not a waste of one’s money. Having made continuing professional education presentations since December 1973, it is the attitude that professionals bring to the day’s work of attendance that produces the waste of time. 6. For the sake of argument, I will assume that stating that it is “more important” is not the equivalent of asserting that it is unimportant for a tax professional to be familiar with the content of the FASB Codification found in ASC 740 Income Taxes or its predecessor FASB 109 as well as the interpretative FIN 48 [Accounting for Uncertainty in Income Taxes]. Would our dauntless tax person be prepared to complete Schedule UTP [Uncertain Tax Position Statement] for domestic and foreign corporations or would such a person, persistent on maintaining her ignorance of such matters, be able to properly respond to an Internal Revenue Service request for tax accrual workpapers, which, according to Announcement 2002-63, “refers to tax accrual and other financial audit workpapers relating to the tax reserve for deferred tax liabilities and to footnotes disclosing contingent tax liabilities appearing on audited financial statements”? 7. I do not think that the issue is the total number of continuing professional education credits to be earned during the two-year renewal period; rather the issue relates to course content. Semi-rhetorically, does one believe that a full palette of “tax-oriented” accounting courses, a veritable plethora of such offerings, cannot possibly be developed? Besides the perennial favorites of fiduciary accounting and deferred income taxes, one should consider the following list with the related Internal Revenue Code references, many of which sections draw distinctions between tax and accounting concepts: a) Amortization of goodwill and going concern value [I.R.C. Sec. 197(d)(1)(A&B)] b) Capital expenditures [I.R.C. Sec. 263] c) Capitalization and inclusion in inventory costs of certain expenses [I.R.C. Sec. 263A] d) Effect on earnings and profits [I.R.C. Sec. 312] e) Certain stock purchases treated as asset acquisitions [I.R.C. Sec. 338] f) Definitions relating to corporate reorganizations [I.R.C. Sec. 368] g) Treatment of certain interests in corporations as stock or indebtedness [I.R.C. Sec. 385] h) General rule for methods of accounting [I.R.C. Sec. 446] i) General rule for taxable year of inclusion [I.R.C. Sec. 451] j) Special rules for long-term contracts [I.R.C. Sec. 460] k) General rule for taxable year of deduction [I.R.C. Sec. 461] l) General rule for inventories [I.R.C. Sec. 471] m) Last-in, first-out inventories [I.R.C. Sec. 472] n) Mark to market accounting methods for dealers in securities [I.R.C. Sec. 475] o) Adjustments required by changes in method of accounting [I.R.C. Sec. 481] p) Allocation of income and deductions among taxpayers [I.R.C. Sec. 482] Nota Bene: If Fiduciary Accounting in Florida, a marvelous course presented by the inimitable dynamic duo of Gordon Spoor and Ralph Poe, which has considerable tax content, is allocated eight full credits in accounting and auditing, there is no logical reason not to allocate some accounting and auditing credits for courses based on any combination of the above listed sections of the Internal Revenue Code. 8. While “some” people are prone to say almost anything as “some of the people [are fooled] all of the time”, I still believe that the underlying rationale for the accounting and auditing continuing professional education course requirement is the “attest function”. Note that Florida Statutes Sec. 473.302(8)(a) & 473.302(8)(c), which define “public accounting”, relate solely to audited, reviewed, and compiled financial statements. In addition, Florida Statutes Sec. 473.302(8)(b) that is cited in your e-mail begins with “one or more types of services involving the use of accounting skills” before the statute refers to “one or more types of tax, management advisory, or consulting services.” In all sincerity, the thrust of the public accountancy statute relates to the “art” practiced by public accountants, distinguishing them from a second class of accountants who, up to now, has received no specific statutory status. Only the Internal Revenue Service, and only most recently, to curb the preparation of fraudulent individual income tax returns, has established the new category of registered tax return preparer. 9. Assuming the correctness of your assertion relating to our Board of Accountancy, I think that the Board believes that it lacks the authority to issue such an interpretative regulation under the existing statute. Permit me to remind you that the attempt to bring specialization to the accounting profession, similar to that of The Florida Bar, died more than two decades ago, presumably because of the United States Supreme Court litigation involving the issue of “holding oneself out” as a certified public accountant. More importantly, governmental auditing clearly falls under the rubric of accounting and auditing, unlike sterling taxation, and, in addition, Florida Administrative Code section 61H1-330035 [Continuing Professional Education/Government Auditing] represents an increase in the minimum requirement to twenty-four hours, which is the absolute opposite of reducing the minimum requirement of accounting and auditing to ground zero. 10. It should be “crystal clear” from the above nine comments that I do not agree with your ultimate conclusion. So in wrapping up this part of the conversation, permit me to raise one more hardly rhetorical question. Looking at the “emptiness” of Internal Revenue Code Sec. 1502 [Regulations], why did the Congress in promulgating the Internal Revenue Code of 1954, and most assuredly even before the Internal Revenue Code of 1939, assign the task of issuing not merely interpretative, but rather legislative regulations to the Secretary of the Treasury? The answer is quite simple my learned colleague. The blessed regulators are presumably the only ones with sufficient expertise to draft and then print the final regulations in the Federal Register. It would surely appear that the preparation of consolidated income tax returns for an electing affiliated group demands an understanding of the definitive relationship between accounting and tax concepts in that more than abstruse arena. Very respectfully, Jonathan
348we need change !!!! i perform compilations, but no reviews or audits .... it is a total waste of time and money for me to take courses that have no relevance to my practice ... the 20 hour requirement is just another example of government determining what's best for us ... as a cpa i feel that i can make my own decisions ..............
349CPAs are professional and should recognize their need for AA CPE if needed for their specific practice.
350There is no more value to me as a tax practitioner of 20 hours of A and A than an A and A practitioner required to have 20 hours of Tax Updates. I always try to take courses that have value to me in practice, and because I do not provide Assurance or Attestations Services it is a waste of time and money to be required to have 20 hours of A and A. It is time to change because the technical skills in each segment of practice has advanced so much in the past 4 decades. Other than Ethics, practitioners should be permitted to choose those courses that best serve their own practice areas.
351I am the Managing Partner of a tax only CPA practice. The 20 hour A&A requirement is a waste of my time and money, my partner's time and money ,and my associates time and money. This requirement should be eliminated.
352Why must the FICPA/AICPA continue with the promulgation of new/changing rules and regulations? Of course the "standard answer" to that question is to "protect the interests of Florida CPAs". Some of us who have been at this for awhile are wondering if the real objective is to give the FICPA/AICPA a reason to exist. If you wonder why there is flagging membership you need look no farther than the never ending rules proliferation in an effort to "help us". Please stop trying to help us!!
353I think that many tax courses contain A&A components and should qualify for joint credit i.e. tax and A&A so as to allow practitioners that are most tax still get A&A credit for the courses that enhance and are necessary for their specialty of practice. As I understand it, it is judgement as to what part of a course qualifies for A&A but if it had dual credit that might help solve the problem. Also, giving credit for writing articles and reviewing articles should provide incentive for members to do research and write articles for the CPA Today Magazine and are a special benefit to all members of the FICPA. There are many activities that are technical in nature that CPAs do that they don't get CPE credit for or don't know if it is available. There seems to be confusion out in the hinterland about what does and does not qualify so the question of A&A credit is broader than what you have outlined.
354This needs to be changed. If you are doing no compilation or review or audit work, it is truly a waste of time and money.
355I believe the technical hours option for the full 20 hours should be allowed for CPAs not performing assurance or attest work. For example my practice is heavily in business valuation and forensic accounting with separate AICPA CPE requirements.
356I wouldn't object to an 8-hour standardized A & A course (similar to the standardized ethics course) to provided a general update of changes in the last couple of years. But for me, at least, 20 hours every two years is a waste of about 10 - 12 of those hours.
357The only thing that sets a CPA apart from every other tax preparer or bookkeeper is our ability to attest. If we have a CPA certificate, we should keep current with A&A hours. A general up to date knowledge of the issues is imperative to maintain our competitive edge as a profession and to continue to set us apart and defend our regulatory preferred status.
35820 hours over two years is not a lot.
360Change CPE to a total of 16 hrs per year: 4 A&A, 12 Tax or other technical.
361I'm a member of the SWFL chapter and we used to have more monthly meetings that were A&A which made getting the 20 hours easier. Lately, the participation at the meetings has diminished and there has been less A&A and more TB. Part of the problem (of diminished attendance), it seems, is that the FICPA has started offering more online CPE so there's less of a benefit to attend the monthly meetings. Which is unfortunate for me because I prefer to get my CPEs from attending meetings rather than doing online CPEs. I also encourage students to attend FICPA chapter meetings so they can network with local professionals. In the past it was a good networking opportunity...not so much lately. The 20 hours of A&A is beneficial. It would be nice if it was easier/less expensive to get the hours. I can get 2 hours of CPE at an FICPA meeting for $30 ($15 per CPE), which includes a meal. I do not fully understand why the cost per CPE online from the FICPA is so high.
362I strongly believe that cpe must even include a higher dosis of AA in order to be called a cpa.
363my specialty is litigation support, and the A and A requirement shpould be repalced by other technical courses, not A and A.
364If anything, should be more. Learning is more limited for CPA's in industry relating to A&A.
365 The Current System Works.
366All the questions are about maintaining or reducing the A&A requirements...The survey ignores the potential to increase the requirement and further represent the value of ongoing A&A education. With the increasing complexity of financial reporting, the potential impact if IFRS and scrutiny upon the profession, is now the right time to water down the education requirements? The page prior to the survey almost brags about the work experience. The reality is one year of work under supervision of a CPA does not necessarily make one qualified to carry the credentials. Instead of watering down the requirements of the profession, we should challenge our colleagues to step up. Let's not turn the CPA into another CGMA or other ridiculous, meaningless "credential"...Show me a CGMA, and I'll show you someone who paid for a certificate that in no way represents any value that individual can provide, he simply paid the membership dues prior to the exam implementation. Now is not the time to water down the value of the CPA license. I welcome your response. Aharon Yoki, Tampa.
367Taking Accounting & Auditing (A&A) classes when my practice consists of 100% of tax engagements is a waste of my time and money. With the continuous increase Fraud and Due Diligence being required by the IRS in completing tax engagements I believe we should have an option to opt out of all attestation engagements (confirm this at each renewal) and be allowed to take education courses that will be more beneficial to us. By still requiring 20 hours of A&A to those firms not doing this type of work makes the classes extremely boring and I believe most CPA's are doing other things throughout the seminar.
368Those who want to hold a Certified Public Accountant certification should continue to be held to a higher standard than accountants and bookkeepers and therefore required to maintain at least a familiarity with all regulations affecting their profession and professional certification. Whether CPAs are performing assurance or attest work, industry work, or tax work, the public perceives the CPA to be knowledgeable in all aspects of the profession. The elements of accounting and auditing, fraud prevention and detection, and tax law overlap in each branch of accounting, i.e. assurance and attest work, industry, and tax work. A CPA should be well rounded and at least marginally familiar with legislative and regulatory changes to the profession. This could be accomplished each renewal period with: 8 hours of Accounting and Auditing 4 hours of Fraud 4 hours of Tax 4 hours of Communication, written or oral All other Certified Professional Education requirements could remain the same.
369More flexibility should be added to allow CPAs to focus on areas of CPE which are most applicable to them. As a tax preparer that does not engage in any A&A work, I would like to focus more on tax or other technical business related CPE.
370I think those who prepare and review attest work need to keep up and should keep up with A&A hours. My firm does A&A but I do not review this work minutely, We have specialists do it. I sign off on tax returns and the burden of getting 20 A&A is simply that- a burden.
371In my opinion, we all need to keep updated in the A&A updates regardless of our specialty. We are all professionals and are expected to have a core knowledge. Even if my practice is primarily a Tax practice, there are still clients that require compilations. Our firm has an A&A Department. I can assist in selling A&A services to our tax clients or new clients that need that need our firms A&A services. So having the core A&A knowledge helps me in expanding those firm services to clients. In my opinion 16 hours of A&A would be sufficient to keep updated in the A&A world.
372I have no problem taking the current 20 hrs. of A&A. I do mostly tax and consulting or teaching clients staff to do their own accounting. The hours of A&A actually just keeps me abreast of anything coming up. In particular, there seems to be more and more discussion about thorensic accounting. This topic seems to be more and more relevant to all our client businesses.
373I believe that our profession (as accountants) need to retain A&A hours. I would ask that some of the "TB' courses offered be reviewed to make sure that they don't have some A&A information also. I would like to see the hours lowered to 16 hrs that would accommodate 2 8 hr courses.
374I feel that minimal number of A&A hours should be required, but if one does not work in the attest arena, 20 is too many.
375I often feel like I miss good courses that are relevant to my clients at conferences because I have to sign up for A & A to meet the requirement. I feel some is important for cpas such as myself who issue an occasional compliation report, but 20 hours is definitely too much for a tax practitioner.
376While specialization may improve profitability, I believe a Certified Public Accountant should be well aware of the standards and issues pertaining to the entire universe each of us faces every day. By requiring 20 hours of A&A we can choose to invest in a very narrow or broad spectrum curriculum covering the profession as a whole. Lastly, I would suggest that the 20 hour requirement every two years is hardly onerous.
377I think the current standards are fine,
378With the additions of the ethics requirements its more like the current requirement is 24. The board should consider having a higher (20 or even more) A&A requirement for those individuals performing attest function work for compensation, such as audits and review level work. I rather see the CPAs handling my firm's tax work able to take more tax seminars and less A&A.
379I always end up with one to two courses in Governmental or some other area that I do not need. It seems pointless to take the extra course, I do not wan to see the A&A hours disappear because even if you have a tax practice, if the books are on an accrual basis they should still fall within GAAP which changes continuously. i do not believe that dropping the hours to eight or less will give a broad enough overview to assist practioners to stay current.