The Board has now implemented the statute change of July 1, 2010 to M.G.L. chapter 112, sections 87A to 87E1/2, and has interpreted the new law as amended per the provisions set forth as of July 1, 2011. As such, the Board has ruled that no permits to practice will be created by rule and issued to provide temporary practice in the Commonwealth for individuals and firms licensed in other Substantial Equivalent states who enter our state for more than 90 days in this first fiscal year. This provision of the new Mobility law expired as of July 1, 2011 and there was not need to create a permit for extended practice in this first year. Therefore, as of July 1, 2011, a CPA whose principal place of business is not in MA, and who holds a valid CPA license in any other Substantial Equivalent (SE) state shall have all the rights and privileges of a CPA in our state without the need to file a notice, or register and ay a fee, and obtain a license in MA, as long as the state Board where the CPA is licensed does not restrict the practice privileges of MA CPAs who enter that other state. As far as the Board can determine, all fifty states are included on the Substantial Equivalency (SE) list as published by NASBA and as authorized by their National Qualification Appraisal Service. Our statute change also requires that the SE state on the NASBA list has adopted and implemented a 150 semester hour education requirement for licensure, and if so, that the licensee has been issued the license prior to January 1, 2012. Inquiries on the NASBA list and other state Board rules can be made at www.nasba.org.
A few other jurisdictions (District of Columbia*, Puerto Rico, and Virgin Islands) do not allow MA CPAs to enter their jurisdiction and practice on a temporary basis, so CPAs from these jurisdictions cannot enter MA to practice under our new Mobility law.
However, if the state or other jurisdiction does require written notice (and/or a fee) for an individual MA CPA or MA CPA firm in order to provide any CPA service in that state, an out-of-state CPA or CPA firm providing this same service in MA must obtain a reciprocal CPA license in MA to provide that service in our state. Simply stated, all CPAs (individuals or CPA firms licensed in any state or jurisdiction) can enter MA on a temporary basis and provide any service that a MA CPA can provide in that other state without “notice or fee”. This Mobility for CPAs from other states to practice in MA is limited by any requirement or restriction of a permit or other written notice (whether a fee is required or not), and each CPA from another state is required to contact the state Board where licensed to confirm that there are no service restrictions in that state for MA CPAs to enter and practice without “notice or fee” under their Mobility or other laws.
The Mobility law does allow any CPA licensed as an individual (sole practitioner) or as a CPA firm in our state and licensed in any other state to transfer any CPA licensed in any other state (employee or owner of the firm) into MA without “notice or fee” to work on a temporary basis in our state. The CPA licensed in any other state can work for the licensed entity in MA until such time that this CPA moves his/her residence to MA or is permanently assigned to the MA office of the licensed MA entity. This means that all large and medium CPA firms already licensed in our state can transfer in any staff CPA to work in MA as of 07/01/2011, and that staff CPA must only maintain current CPA licensure in the other state. The Board maintains that the true substance of the Mobility initiative (and now law) was to lessen the multiple individual license burdens of individual CPAs from larger firms. Our Board, as of 07/01/2011, will allow the temporary transfer of any CPA firm member (staff or owner) Into MA for any period of time without “notice or fee”.
These CPAs (licensed in the other states) must comply with the practice provisions as set forth in our new law, and agree to be subject to and account for any violations of MA rules and statutes while practicing in our state. However, the CPA or CPA firm he or she is working for would already be licensed here and thus, also subject to responsibility in any investigatory proceeding.
We also include other scenarios in the various sections of our FAQS set forth below, but if anyone has a specific question one can e-mail the Board directly through our web site page. All other recent rules changes remain as detailed in this FAQS section, and our rules 252 CMR and statue are available at this web site.
Exam Issue Questions
- If I cannot sit for the CPA exam and my conditional credit is expiring, what can I do?
- What are the new Reciprocity requirements under the Mobility statute change as of July 1, 2010?
- Based on the new rule, can I sit for the CPA exam before I meet the 150-hour requirement?
- What are the new educational requirements one must meet if one chooses to sit for the exam with the bachelor's degree and 120 credits?
- Does my college-level education need to include any other specific coursework?
- Can I sit for the exam during my final semester before graduation?
- Is there a time limit to meet the 150-hour certification/licensure requirement if I sit for the exam with 120 credits?
- Can I sit for the exam before I receive my official transcript certifying the completion of my bachelor's degree and required accounting and business courses?
- How the ratio is calculated of graduate course value vs. undergraduate course value under the new education rule 252 CMR 2.07(2) (a)?
- Does this mean that I will need a graduate degree to become a CPA?
- How does the Board qualify candidates with foreign college degrees or qualifying foreign accounting or business courses under these new rules?
- If a candidate sat for the examination prior to November 2002, what is the education and experience requirement when the candidate finally passes the CPA examination?
- When is the CPA Exam given, and what are the application deadlines?
- Where do I obtain a CPA exam application?
- Will on-line university courses be accepted in the new educational requirements?
Certification Issue Questions
- What is the education requirement for becoming a CPA?
- What is the experience requirement for CPA certification/licensure?
- What if my public accounting experience does not include 1000 hours in the attest function?
- How can I receive full license privileges to allow me to sign off on financial statements once issued the non reporting license?
- How the old experience requirement is affected by this new rule change with regard to the 252 CMR 2.07(2) (b)?
- What is the new Reciprocity rule as of January 1, 2007 and the SE statute change as of July 1, 2010?
- What if I move to another state? Will my license transfer with me?
Renewal and Other Issue Questions
- How do I renew an expired license?
- What are the Continuing Professional Education Requirements?
- How can I verify if my Continuing Professional Education is accepted by the Board?
Firm Licensure Questions
- Where do I obtain applications to register a firm?
- Can CPA firms admit Non-CPA owners as of September 24, 2001?
- What are the license renewal requirements as affected by the mobility statute change as of July 1, 2010??
- Can I practice as a CPA and have a separate unlicensed practice similar to the practice of public accountancy?
- What are the Board’s rules with regard to return of client records?
- How do I change my name and/or mailing address?
- How do I request a license verification /certificate of good standing?
- How do I request that my CPA exam grades be reported to another state?
CPA EXAMINATION REQUIRMENTS AS OF JANUARY 1, 2007
The Massachusetts Board of Public Accountancy (BoPA), at the request of many interested parties held discussions regarding amending its education rules to sit for the CPA exam. After much input from the CPA industry, the Board came to the conclusion that allowing candidates to sit for the exam at the point they earn a bachelor's degree and 120 semester hours, rather than the current 150 semester hours, is one step towards alleviating the shortage of CPAs in the Commonwealth.
BoPA members voted on September 28, 2006, to adopt amendments to 252 CMR, allowing candidates to sit for the CPA exam at 120 hours but to retain the current license requirement of 150 semester hours. On November 3, 2006, the rule was accepted by the Secretary of the Commonwealth and the rule changes become effective on January 1, 2007. If you have questions, e-mail the Secretary of the Board, Leo H, Bonarrigo, CPA, through this web site. Unfortunately, he is in only one or two days a week, so be patient for responses.
The following are frequently asked questions on these various subjects:
The Board amended its rules to adopt conditional credit rules that are now far less stringent in the successful completion of the exam than under the former paper CPAS exam. 252 CMR 2.06 set forth that when a candidate passes the first part of the exam, he/she has a rolling 18 months (or six attempts to sit for the remaining three parts) to complete and pass all parts of the exam. The Computer Based Test (CBT) allows candidates to sit for one part of the exam at a time in any exam window, and pass that part to start the rolling 18 month period. This conditional credit rule is far easier than under the paper CPA exam, and as such, no discretion is allowed the Board by this new rule to grant additional sittings under conditional credit when the candidate passes three parts and has only one exam window remaining to complete the last un-passed part. If a candidate leave the past part to an exam window and becomes medically unable to sit or it restricted on appearance by a death or other personal tragedy, no provision is available to extend the rolling 18 month period. The candidate will lose a previously passed part and if the candidate cannot sit subsequently for other exam windows, will lose other passed parts unless the candidate plans to sit and prepares to pass all remaining parts within the next rolling 18 month period. The planning issue of securing exam participation is key and all candidates are advised to sit for more than one exam part in any one exam window, especially after passing the first part and beginning the rolling 18 month period.
The Board’s statute was amended as of July 1, 2010 to allow practice privileges to CPAs from Substantially Equivalent (SE) states. This mobility legislation allows a CPA with a license issued by another state, which the NASBA (National Association of State Boards of Accountancy) National Qualification Appraisal Service has verified to be in substantial equivalence with the Certified Public Accountant licensure requirements of the AICPA/NASBA Uniform Accountancy Act, to practice public accountancy in Massachusetts all the same practice privileges to Massachusetts CPAs entering that state. As of July 1, 2011, the Board’s statute does not impose any time limit on practice via mobility in Massachusetts.
M.G.L. c. 112 section 87B (h) (1) makes it clear that the practice privileges afforded to out-of state licensees practicing in Massachusetts are limited to those licensees whose licensing state affords all of the same practice privileges to Massachusetts licensees practicing in that state, including but not limited to the ability to practice in that state without obtaining a license, permit, and/or registration or the imposition of any fee.
Last year, the Board had issued an Advisory Ruling to the effect that any practice of public accountancy in Massachusetts by an out-of-state licensee whose licensing state does not allow Massachusetts individual licensees to practice public accountancy, and provide CPA services of any type including financial statement audits, prospective financial information, PCAOB audit engagements, etc., in that state without having to obtain a license, permit, and/or registration (or imposition of any fee) in that state would constitute unlicensed practice in Massachusetts for which sanctions may be imposed. (See M.G.L. c. 112 §87D½ and M.G.L c. 112, §65A)
The Board wishes to clarify its Mobility Advisory Ruling and the rules that apply if an out-of–state licensee, not licensed in Massachusetts, wishes to perform audit or other attest services in Massachusetts pursuant to the mobility statute change.
- If the out-of-state CPA is associated (as a partner/owner or employee) with a firm that has an office in Massachusetts (and therefore has a firm license in Massachusetts), there are no additional licensure requirements for the out-of-state CPA.
- If the out-of-state CPA firm does not have an office in Massachusetts, but the firm is already licensed in Massachusetts, there are no additional licensure requirements for the out-of-state CPA associated with a firm upon entering Massachusetts on a temporary basis.
- If the out-of-state CPA is licensed in a state which permits an out-of-state CPA (specifically a Massachusetts CPA) to perform attest or any other public accounting service via mobility, even if the out-of-state (Massachusetts) licensee is not registered or licensed in the state, then the out-of-state CPA or CPA firm may perform attest or or any other public accounting service via mobility in Massachusetts pursuant to the mobility statute and his/her firm is not required to obtain a CPA license in Massachusetts.
- If the out-of-state CPA is licensed in a state which permits an out-of-state individual CPA (specifically a Massachusetts CPA) to perform attest or any other public accounting service via mobility, but requires the attest to be provided by or through a CPA firm licensed in their state, then the out-of-state individual CPA may perform to perform attest or any other restricted public accounting service via mobility in Massachusetts, but only if their CPA firm is licensed in Massachusetts.
The Board hopes this clarification satisfies the many questions about out-of-state CPA individual’s or firm’s temporary practice as allowed through our mobility statute change, but if not, any questions about this mobility legislation should be forwarded to the attention of Leo H. Bonarrigo by e-mail at the Board's web site www.mass.gov/dpl/boards/pa.
Yes. After January 1, 2007, candidates may qualify to sit for the exam when they have completed 120 of the required 150 semester hours (or 180 of the 225 quarter hours) of college education at a nationally or regionally accredited institution, where the successful completion of 120 semester hours (180 quarter hours) results in obtaining a bachelor's degree.
One must have completed 21 semester hours of accounting courses that include coverage in financial accounting, audit, taxation, and management accounting and 9 semester hours of business courses, including coverage in the areas of business law, finance and information systems.
The requirements to sit for the exam do not, but to become licensed, the requirements to become certified vary based on the highest degree you obtain, and you should read the new rule 252 CMR 2.07(2) carefully. In either case, all coursework must be completed at a nationally or regionally accredited college or university and Associate degree/community college courses will be accepted only if transferred into a four-year bachelor's degree program. Elementary or introductory accounting courses will now qualify to fulfill your accounting course requirements for exam and licensure.
NO. You must have completed all of the requirements for your bachelor's degree before you sit. You may, however, apply for the exam during your final semester. Please note that the application review process for a first-time exam candidate will take 6-8 weeks and that testing is only available in the first two months of each calendar quarter. Once your exam application is approved, you will receive a Notice to Schedule (NTS) that gives you six months to schedule and complete all exam sections for which you applied. If you have not taken all exam sections and your NTS expires, your fees will be forfeited.
Yes. You have three years from the time you receive notice of passing all four parts of the exam to meet the educational requirements for CPA certification/licensure. If you don't, you will need to retake all parts of the exam. This requirement is inflexible and candidates should plan accordingly and continue their education even when sitting for remaining parts of the exam. When every candidate applies after January 1, 2007, the testing administrator will complete an Academic Evaluation for Certification form. For candidates who satisfy the licensing requirement (252 CMR 2.07(2) (a)) when applying to sit for the first time, no further correspondence on the education issue will be necessary throughout the exam process. For all others, an academic report will be issued detailing the semester hour and course deficiencies to become certified once the entire exam is completed. This report will be updated through the entire exam experience.
When the final part is successfully completed, the passing grade notice will be sent our registered mail, and the date of delivery will begin the three year period to complete the 150 semester hour requirement for certification. The Academic Evaluation for Certification form will be required in the licensure application process, and a fee of $100 will be charged by the testing service for monitoring education during the exam process (and beyond) and verifying 252 CMR 2.07(2) (a) compliance prior to the candidate applying for a MA license.
All candidates who sit for the exam in any other state without completing the requirements of 252 CMR 2.07(2) (a) must complete the full education requirement within three years from the date they receive their final passing grade. If they do not, they must comply with the new reciprocity requirement of 252 CMR 2.08 in order to become licensed in Massachusetts.
Yes. Beginning January 1, 2007, you will be able to sit for the exam before you actually receive your official transcript as long as you are able to provide the certified transcript within 90 days of your exam date. Failure to provide a transcript(s) that certifies the award of the bachelor's degree and completion of all required accounting and business courses will result in the loss of any exam credit in the exam window completed. Also, you will not be allowed to sit as a MA exam candidate in future CPA exams until such official transcript is received by the testing administrator.
Since a candidate now needs 30 semester hours of undergraduate accounting courses or 18 semester hours of graduate courses for licensure, each undergraduate hour now equals 3/5 of a graduate hour (or conversely, each graduate hour equals 5/3 of an undergraduate hour).
An example: A candidate with 15 undergraduate hours and 9 graduate hours would have an equivalent of 30 undergraduate hours. (15 undergraduate hours + (5/3 x 12 = 15). If a candidate sits for the exam with the required 21 undergraduate accounting semester hours, he/she would only need complete 2 graduate accounting courses rather than 3 undergraduate accounting courses to comply with 252 CMR 2.07(2)(a) for licensure.
For business courses, since a candidate remains to need 24 semester hours of undergraduate accounting courses or 18 semester hours of graduate courses for licensure, each undergraduate hour equals 3/4 of a graduate hour (or conversely, each graduate hour equals 4/3 of an undergraduate hour).
An example: A candidate with 9 undergraduate business hours and 12 graduate business hours would have an equivalent of 24 undergraduate hours. (9 undergraduate hours + 4/3 x 12 graduate = 15, and the total is now 24). If a candidate sits for the exam with the required 9 undergraduate business semester hours, he/she would only need complete 4 graduate accounting courses rather than 5 undergraduate accounting courses to comply with 252 CMR 2.07(2)(a) for licensure. All should be advised that if one were earn a graduate degree in business (MBA, MST, MSAIS, or MSF), no specific business course coverage is necessary and only 18 graduate semester hours in business are required.
No. The only degree required for certification is a bachelor's degree, with 150 semester hours of education contained in this degree or supplemented after earning the bachelor's degree. However, the skills and knowledge usually developed in a graduate program (e.g., Masters in Tax, MBA, or Law degree) may be useful in helping CPAs meet client demands. For this reason, the BoPA strongly encourages a graduate education. In addition, the experience requirement is relaxed when one earns the graduate degree (explained in 252 CMR 2.07(2) (b) as follows:
- If you obtain a graduate degree in accounting from an AACSB accredited accounting program, or one that has been approved by the Massachusetts Board of Public Accountancy as substantially equivalent to an AACSB program, you will not need to meet any specific course requirements of 252 CMR 2.07(2) (a), either accounting or business course subjects.
- If you earn a graduate degree in accounting from a school that does not fall within the above AACSB category, or if you earn a graduate degree in business administration or law, you will need 18 semester hours (27 quarter hours) of accounting at the graduate level or 30 semester hours (45 quarter hours) at the undergraduate level, or an equivalent combination thereof (undergraduate courses are weighed as 3/5 of graduate courses per this new rule as mentioned above). These courses must include coverage in financial accounting, audit, taxation, and management accounting. In addition, the degree must include or be supplemented by 24 semester hours (36 quarter hours) of business courses (other than accounting courses) at the undergraduate level or 18 semester hours at the graduate level, or an equivalent combination thereof (undergraduate business courses are weighed as 3/4 of graduate courses per this new rule as mentioned).
- If your highest degree is a bachelor's degree in business, your degree must include or be supplemented by 30 semester hours in accounting with coverage in financial accounting, audit, taxation, and management accounting. In addition, the degree must include, or be supplemented by, 24 semester hours in business courses other than accounting courses. These business courses shall include coverage in business law, information systems, finance, and coverage in at least one of the areas of economics, business organizations, professional ethics, and/or business communication.
- If your degree is not in business, your 30 semester hours in accounting must include at least three semester hours in each of the subject areas of financial accounting, audit, taxation, and management accounting; and your 24 semester hours in business must include at least three semester hours in each of the areas of business law, business information systems, professional ethics and finance. Business courses, other than accounting, in business management of organizations, economics, and/or business communications may be included for the business course requirements.
In all 4 cases herein, the 30 semester hours of undergraduate or 18 semester hours of graduate accounting or business courses do not have to be included in the undergraduate or graduate degrees.
As in the past, all candidates with education outside of the U.S. must have their degree and course requirements evaluated by our only sanctioned evaluation service, the Center for Educational Documentation (CED). You can visit their web site at www.cedevaluations.com for their instructions. In the past, CED would evaluate the degrees and transcripts of all non-U.S. colleges and universities to determine their equivalency to a four-year bachelor's in the U.S. Since the exam evaluations now are that a candidate has a 4 year bachelor's degree and 120 semester hours to include the specific accounting and business course coverage, and since many candidates have both foreign and U.S. degrees and courses, CED will now evaluate all requirements and generally verify only exam qualifications for all candidates, who use either their foreign degree or any of the 21 required accounting or 9 business courses within this foreign degree.
The candidate with initial foreign education, along with additional U.S. education (taken here to comply with the 150 semester hour rule), who wishes to qualify for the certificate, would then contact the CPA exam service to obtain the Academic Evaluation for Certification form, as mentioned in the What's New Section above.
Any candidate who sat for the CPA exam prior to November 2002 as a Massachusetts candidate will be grandfathered with respect to education in their qualifications to become certified at the completion of the examination. Without the new education provisions of 252 CMR 2.07(3)(a), the candidate with only a bachelor's degree will need to have satisfied the experience requirements of three years in public accounting with 1000 hours in report experience or the government experience provisions of the old rule 252 CMR 2.07(6). If you fall in these categories, call the Board for a copy of these old rules.
If the candidate has a master's degree but not the specific course requirements of 2.07(3) (a), he/she will still need two years experience and the 1000 report hours as previously mentioned. Per the prior experience requirements under section 2.07(3) (a), the only equivalent to CPA experience is government audit experience as set forth in section 2.07(6) (a). However, any candidate can obtain the additional education per the new rule, 252 CMR 2.07(2) (a), and qualify to reduce or eliminate the experience requirement and be granted the new non-reporting license. The is an additional option for private accounting experience per section 2.07(5) (a) if one meets the 150 semester hour education rule, but has no graduate degree but three years experience under the supervision of a CPA in a comptroller assistant, internal auditor position or some other similar position.
The CPA Exam, which is now a Computer Based Examination (CBT) is administered during four examination windows a year, and is available through our testing administrator. To receive an application and/or any other exam related information, please call the exam service at 1-800-272-3926 or 1-615-880-4200, or visit their website at www.nasba.org.
Exam applications are obtainable by contacting the CPA Exam Service at 1-800-CPA-EXAM, ext. 4257 - or 1-615-880-4200, or by visiting their website at www.nasba.org.
- Will on-line university courses be accepted in the new educational requirement?
The on-line courses must be accepted through a degree-granting program at an accredited college or university. Generally, as is the case for any course to be accepted in meeting the educational requirement, this means that the candidate should be able to present a transcript from an accredited college or university showing that the course was accepted within a degree-granting program.
Do not call the Board administrative office for any exam related operational information (i.e. grade release information, change of address, etc.).
THE NEW EDUCATION RULE, 252 CMR 2.07(2) (a), AND RELATED NEW EXPERIENCE REQUIREMENTS, 252 CMR 2.07(2) (b) TO BECOME LICENSED
As of 11/03/06, candidates pursuing CPA certification in Massachusetts are required to have 150 credit hours of college level education (252 CMR 2.07(2) if they sat for the Computer Based Test on their first exam attempt. The 150-hour requirement was a result of the growing demand for CPAs to provide clients with a wide range of professional services. CPAs are required to make increasingly complex and technical judgments, creating the need for professionals with diverse skills and a broad educational background. The additional education requirement is designed to meet this need. The education requirement remains basically unchanged from the old rule 252 CMR 2.01(4) and the Board has copies of this old education rule as well as the old experience rule 252 CMR 2.07(3).
The experience rule has not changed based upon the changes of this new education rule. Experience is set forth in 252 CMR 2.07(2) (b) and is essentially the same as it was detailed under the old rule 252 CMR 2.07(3). Both the new and old rules will be maintained on our web site for the immediate future. The new rules are those shown effective as of November 3, 2006. Both experience rules depend on your level of education. With 150 credits, you need one year of public accounting experience for a full reporting license and the CPA experience must include 1000 hours of report (attest) experience as defined in these sections. With a graduate degree in accounting, business, or law, no experience is required for certification/licensure, but the candidate can only apply for the non reporting license.
If the candidate has no CPA experience or no report (attest) experience in his/her public accounting experience, the privileges of their license will be restricted to all accounting services, except issuing reports on financial statements. This restriction is designated as a non reporting license, but only the Board and the non reporting licensee will be aware of this restriction unless a member of the public were to inquire. The actual license itself has no restriction on it and we rely on the licensee to provide this information to clients or other members of the public if they are presented in their practice of public accounting with a potential report engagement. Ata that point, the non reporting licensee should review 252 CMR 3.01(5) and make a decision to upgrade the license to be able to perform report services.
You will qualify for to upgrade to a full license privileges after you comply with the provisions of 252 CMR 3.02(5), which remains unchanged in the new rules as of November 3, 2006. Non reporting candidates should review this rule carefully, and it would only be relevant if the non reporting licensee wished to accept a report engagement after becoming licensed. Many licensees practice public accountancy and do not issue reports on financial statements.
If you wish to upgrade to a full license, the purpose of the rule is to have you take the 80 hours of report CPE within six months of accepting the report engagement to gain the knowledge of reporting soon before taking a report engagement. Then, you can sign up for the peer review of this report with a report acceptance body (such as the MA Society of CPAs) and they will give you a list of peer reviewers to comply with the provisions of the rule within nine months of issuing the report. They will also schedule subsequent peer reviews as required by 252 CMR 2.15.
Every individual who sat for the paper CPA Exam prior to November 2002 and completed the exam without qualifying under the 150 semester hour education rule under the old rule 252 CMR 2.01(4) must qualify for the full reporting license experience requirements at that time.
The first opportunity at that time was that each candidate had to have had three full years of public accounting experience with 1000 hours in the report function and at least 700 in audit or review experience and 300 of the remaining amount (if not all 1000 in audit or review experience) in full disclosure compilations. The only other opportunity was that the candidate had at least six years of government audit experience and any candidate who wishes to qualify for either provision of the old rule should contact the Board for a copy of the old rule experience provisions. This grandfather provision is contained in the new rule 252 CMR 2.07(3).
The Board’s statute was amended as of July 1, 2010 to allow practice privileges to CPAs from Substantially Equivalent (SE) states. This mobility legislation allows CPAs with licenses issued by a state, which the NASBA (National Association of State Boards of Accountancy) National Qualification Appraisal Service has verified to be in substantial equivalence with the Certified Public Accountant licensure requirements of the AICPA/NASBA Uniform Accountancy, assuming these SE states allow all the same practice privileges to Massachusetts CPAs entering those states.
M.G.L. c. 112 section 87B (h) (1) makes it clear that the practice privileges afforded to out-of state licensees practicing in Massachusetts are limited to those licensees whose licensing state affords all of the same practice privileges to Massachusetts licensees practicing in that state, including but not limited to the ability to practice in that state without obtaining a license, permit, and/or registration. Therefore, the Board has issued an Advisory Ruling to inform all out-of state-licensees of the Board’s intent to strictly enforce the statutory mandate of M.G.L. c. 112 section 87B (h)(1 ). As such, any practice of public accountancy in Massachusetts by an out-of-state licensee whose licensing state does not allow Massachusetts individual licensees (and/or firms) to practice public accountancy, and provide CPA services including financial statement audits, prospective financial information, PCAOB audit engagements, etc., in that state without having to obtain a license, permit, and/or registration in that state shall constitute unlicensed practice in Massachusetts for which sanctions may be imposed. (See M.G.L. c. 112 §87D½ and M.G.L c. 112, §65A)
In these instances, CPAs or CPA firms from these states must obtain a MA CPA license to perform these services in our state until such time that our rules, 252 CMR can provide for temporary permit provisions for such services. We expect these rules to be in place by December 31, 2010.
The Board is not aware of all state Board’s Statutes and Regulations, but in the New England area (including New York state),only Rhode Island appears to allow “no notice, no fee” for all CPA services, and thus, only Rhode Island CPAs can enter our state with full mobility privileges. All other CPAs must inquire with their state Board of Accountancy for verification of full mobility privileges for MA CPAs in their state before coming to MA and providing CPA services to include financial statement audits, prospective financial information, PCAOB audit engagements, etc. Without such reciprocal privileges, CPA individuals (or firms ) from these other states need a MA CPA license to enter MA and provide these services, and applications are available at our web site.
Also, for the first year of this new law, no individual CPA or CPA firm can enter the state and practice for more than 90 days between 07/01/2010 and 06/30/2011 without obtaining a temporary permit, which also will be set forth in the 252 CMR rule changes to be in place by December 31, 2010.
Any questions about this mobility legislation should be forwarded to the attention of Leo H. Bonarrigo by e-mail at the Board's web site www.mass.gov/dpl/boards/pa.
Reciprocity, or the recognition of your MA license in another state, is ultimately the decision of the licensing board in your new state. However, since almost all states have adopted the 150-hour education requirement, it is likely that if you meet the certification requirements for MA you will be able to obtain a license in another state. For more information, visit: www.nasba.org and the requirements of each individual state.
Renewal and Continuing Education Questions
In order to renew an expired license, a written request to the Board Office is required. Included in this written request, expired licensees must ask the Board Staff to prepare a re-instatement package. Please also include a current address and license number for verification.
If a license is renewed on time, the required number of hours of Continuing Professional Education (CPE) to renew that license to practice is 80 hours. This requirement is due in connection with the renewal of your license. Any person with a late renewal should refer to the rules and regulations (252 CMR) regarding CPE, as the requirements to renew are different based on the number of years expired.
All CPE sponsorship, and/or CPE qualification questions, should be answered in the rules and regulations (252 CMR). Please be aware that the Board of Public Accountancy does accept any CPE course or seminar approved by either the A.I.C.P.A., or N.A.S.B.A.. However, the Board Office itself, does not pre-approve, or verify, any course or seminar as qualifying for CPE. (See CPE rules in Rules and Regulations section.)
Firm Licensure Questions
Applications for firm registration are available at the Board's web site www.mass.gov/dpl/boards/pa under applications & forms.
Based on a recent change to M.G.L. c. 112, sections 87A to 87E, licensed CPA firms (partnerships, corporations, LLCs and LLPs) may organize or add partners, shareholders or members up to 49 percent ownership with individuals who do not possess a CPA license. This informational notice provides the guidance to all who wish to either form a new entity with non-CPA owners or add a non-CPA owner to a currently licensed CPA firm as above.
The Board recognizes that mobility privileges now allowed as of July 1, 2010 for an out-of-state CPA or CPA firm may permit the out-of-state CPA or CPA firm to choose not to maintain a current license to practice in Massachusetts. However, the Board cautions each current MA licensee from any other state to contact their Board of Accountancy and confirm that their state Board has granted full unrestricted practice privileges to MA CPAs or CPA firms before allowing their MA CPA license to lapse. Prior to Mobility law changes, in order for an out-of-state CPA or CPA firm to practice public accountancy in MA, one out-of-state CPA partner or owner of the firm and the CPA firm must have registered and become licensed by our Board to enter our state and offer to provide CPA services here.
Now, this restriction remains in effect only if the out-of-state CPA moves his/her residence to Massachusetts or the out-of-state CPA or CPA firm opens an office location in our state. This is the requirement for all individual CPAs, who practice as sole proprietors and reside here, or the CPA firm enters our state to open an office here as a Partnership, Professional Corporation, Business Corporation, LLP or LLC and are licensed as a CPA firm from any other state. If your CPA firm is a Professional Corporation, Business Corporation, LLP or LLC, it must register with our Secretary of State and then become licensed with our Board. Please be aware that our Board also restricts the firm names so read our rule 252 CMR 3.05 (5), as we do not allow fictitious names, or the use of “and Company” or “and Associates” without restriction per this rule.
But remember that if the state Board where you or your firm is licensed restricts MA CPAs in their practice in your state, your CPA practice will be similarly restricted here. Contact your state Board for any such practice restrictions if you are licensed in a state other than those listed as follows: Alabama, Delaware, Idaho, Indiana, Iowa, North Carolina (maybe notice but no permit or fee), North Dakota, Ohio, Pennsylvania, Rhode Island, Tennessee, Utah and Virginia.
Yes, but one should be aware that any complaint made against an unlicensed practice where a CPA owner of this practice promotes the unlicensed entity with the use of his/her CPA designation, will be investigated by the Board and the individual CPA will be held to the same rules and standards of practice in the unlicensed entity as in a CPA practice. If a CPA provided any of the services directly to a client through the unlicensed entity or supervised or was otherwise involved in the services, or benefited directly from the sale of these services, the Board will hold the CPA responsible for the services as subject of the complaint if it can be assimilated as a violation of our statute or rules.
The Board requires its licensees to return all original records received in any professional engagement and the conclusion of the engagement. The Board also requires that the CPA give a copy of the completed work product (tax return or report on financial statements) and if requested, a copy of the CPAs work papers to the extent that the work papers explain or detail the material in the work product and are not otherwise available to the clients. This would include any business financial statements adjusted by the CPA in the engagement including trial balances and all adjusting entries or other schedules like depreciation or loan accounts. This return of records requirement must be satisfied regardless of any fee issues in the engagement and 252 CMR does not allow the CPA to withhold information for non-payment of fees. The Board recommends that CPAs provide engagement letters for all engagements and specifically detail all services to be provided and all fees to be paid as scheduled on an interim basis. If the engagement is ended before completion and there must be written notice by the CPA of its conclusion with reason and, without a completed work product, no work papers need be returned. The key factor is proper communication during an engagement and interim billing to ensure or help prevent or lessen any outstanding balances at its conclusion. The Board cannot force a licensee to complete any work product engagement so the bargaining point would be payment to complete the work or the return only of all original documents with an explanation of why the engagement cannot be completed. The Board expects clients to respect the work as properly explained during production and completed as scheduled and paid upon completion. However, if the CPA completes the work product, he/she is responsible for it and to provide work paper support for its contents without regard to outstanding fees and to return these materials within 30 days form receipt of a written request.
Name changes can only be done by submitting the completed Name Change Form available at the Board's web site at www.mass.gov/dpl/boards/pa. Mailing address changes can be done online provided that you have in your possession your most current CPA wallet license card. If not, you must download and complete the address change form at this web site and either fax it to 617- 727-0139 or mail it to the address provided on the form.
To request a license verification/certificate of good standing, please submit a written request with the following; your full name, CPA license number (if known), address where the verification is to be mailed and a check, or money order, in the amount of $15.00 payable to Comm. Of Massachusetts. The address to mail your request to is, Board of Public Accountancy, 1000 Washington Street, Suite 710, Boston, MA 02118. If the verification is for a state board and they have provided you with their own form, you may enclose it with your request. Please allow 1 to 2 weeks for your request to be processed. If you are submitting a combined request for license verification and grade transfer (only for Massachusetts exam candidates that sat prior to January 1982) the total fee is $15.00.
Massachusetts exam candidates that sat the CPA exam from 1982 to the present: Massachusetts has authorized the CPA Examination Services (CPAES) to transfer grades. Anyone requesting this service will find an Authorization for Transfer of Uniform CPA Examination Grades located at the Board's web site www.mass.gov/dpl/boards/pa. Click Applications and Forms and then click CPA Exam Grade Transfer. Please follow the instructions provided on the form. Should you have any questions regarding the grade transfer, you must contact CPAES at 1-800-CPA-EXAM and ask for the Massachusetts Coordinator. Please allow 1 to 2 weeks for your request to be processed.Massachusetts exam candidates that sat the CPA exam prior to 1982 (paper & pencil): please submit a written request with the following; your full name, CPA license number (if applicable), address where the verification is to be mailed and a check, or money order, in the amount of $15.00 payable to Comm. of Massachusetts. The address to mail your request to is, Board of Public Accountancy, 1000 Washington Street, Suite 710, Boston, MA 02118. If the other state board has provided you with their own form, you may enclose it with your request. Please allow 1 to 2 weeks for your request to be processed. If you are submitting a combined request for license verification and grade transfer, the total fee is $15.00.
Individuals that did not take the examination as a Massachusetts candidate, please contact the state board you sat in for the transferring or reporting of examination grades.