1. What was the impetus for CPA mobility efforts nationwide? How were the laws and regulations developed?
In 2006, the AICPA and NASBA, working with state boards of accountancy and state CPA societies, developed a plan that would allow clients to receive timely services from the CPA best suited to the job, regardless of location, without the hindrances of unnecessary filings, forms, and increased costs. At the same time, they wanted to make certain that any system which eliminated the artificial barriers to interstate practice also maintained the regulatory system that protects the public interest.
The AICPA and NASBA decided to amend the Uniform Accountancy Act to allow interstate mobility, by adding a provision stating that a CPA with a valid license from a state with CPA licensing criteria "substantially equivalent" to those outlined in the UAA could practice in another state without obtaining another license. Substantial equivalency is commonly described as those states requiring the "three E's" – examination (passage of the Uniform CPA Examination), experience (the one-year experience requirement), and education (the 150-hour education requirement).
The idea was that licensed CPAs should be able to practice across state or jurisdictional lines — personally or electronically — as long as they were in good standing in their jurisdiction of principal residence and met the substantial equivalency criteria. The new mobility laws also help protect the public and enforcement efforts by the state boards since a CPA practicing under mobility is automatically subject to the jurisdiction of the state boards without the requirement of an official registration or filing.
2. What was the scope of the research done to build this tool? How can I be sure it is thorough and correct? How is it updated?
The research began with a questionnaire being sent to every state board for their response. Then each state's laws, rules, forms and websites were carefully reviewed by a team of NASBA and AICPA attorneys and other staff to determine the requirements for mobility. Furthermore, whenever there was a need for clarity, direct email correspondence was sent to the state boards for their input. We maintain the Tool by monitoring websites daily for any changes to the boards' information. Noted changes or changes requested by the boards can be updated on the Tool and pushed live within 24 hours or less after consultation and agreement between NASBA and the AICPA.
3. What is a "quid pro quo" mobility state?
A "quid pro quo" state is a jurisdiction that bases its mobility requirements on the mobility requirements of the non-resident CPA's home jurisdiction. For example, if a CPA is located in Alabama and seeks to exercise practice privileges in Massachusetts, then the requirements for mobility in Massachusetts are going to "mirror" the requirements that would be imposed upon a Massachusetts CPA by the Alabama Board if he/she were trying to exercise practice privileges in Alabama.
4. Why does the Mobility Tool not look at the many non-attest services that CPAs perform for clients?
The Tool currently focuses on services that are most likely to trigger a firm registration requirement in a target state. Most states included language in their mobility laws that predicated firm registration upon the performance of services rendered in accordance with SAS, SSAE, SSARS or PCAOB standards. Therefore, this terminology was used in creating the Tool in order to be consistent with state requirements.
5. If I am preparing a tax return or providing other tax services, does mobility apply to me?
Only licensed CPAs are eligible to provide services in other states through mobility. If you are not a CPA, then you should contact the state in which you will be providing services to inquire whether they require registration of tax preparers, etc. Most states allow CPAs to perform tax services through mobility without requiring any individual registration or firm registration in the target state. CPAMobility.org will answer your questions regarding registration for tax preparation. However, agreed upon procedures, forecasts or other services included in "tax consulting" may trigger the need for a firm permit issued by the target state. If your services extend beyond tax preparation, then you should contact the target state's board directly for additional information.
6. Is the information on the CPA Mobility tool the same information found on the state boards of accountancy websites?
There should not be any inconsistency between the information found on a state board's web site and the data provided in the Tool. However, in many cases, the Tool is more thorough because some boards may be limited in their ability to update their web site when circumstances change. If we have access to updated information, then the Tool can be updated almost immediately.