gwscpa mobility legislation considerations

							Mobility Legislation Considerations for DC


           There is overwhelming support for mobility across the country. Practice mobility as a
            uniform approach has been endorsed by American Institute of Certified Public Accountants
            (AICPA) and the National Association of State Board of Accountancy (NASBA). To date,
            47 states have passed mobility, including all of our surrounding states.

           Our local members support mobility. Our members, many of whom are DC residents
            and many more of whom maintain their primary workplace in the District and thus
            contribute to the District through their work here, are overwhelmingly in favor of mobility.

           Being one of the only remaining jurisdictions without mobility puts DC CPAs at a
            competitive disadvantage. The GWSCPA believes that multiple, cumbersome processes
            and disparities in requirements across state lines creates an unnecessary burden for DC
            CPAs. We also are concerned that in three states so far, including our close neighbor
            Pennsylvania, there are provisions in place that retaliate against licensees in jurisdictions that
            have not adopted mobility (including DC), denying them practice privileges. There have been
            discussions to this effect in MD and VA and should this trend continue, this would
            unnecessarily punish DC CPAs and make it undesirable to be licensed here.

           This creates a disincentive for CPAs to do business in the District. Business realities,
            including an increase in interstate commerce and virtual technologies necessitate a uniform
            system that allows for fluid practice across state lines. A uniform process gives CPAs the
            flexibility to better serve these clients and without this available to CPAs seeking to do
            business in DC, it makes locating and conducting business here less attractive. Many firms
            and practitioners operating in the District now bring in revenue from taxes and day to day
            business operations-lunches, meetings, taxis, parking, etc. that could be lost if CPAs choose
            to avoid work in the District.

           We understand that concerns over a perceived potential revenue loss may arise
            related to this legislation. The DC Board of Accountancy has voiced a concern over
            potential lost revenue but has not demonstrated through sound data their anticipated loss.
            There is no way to know how CPAs will react to the new law. Some may give up a DC
            license. Some will not. That being said, the GWSCPA does not want to see the District
            suffer financially and is committed to working with the DC Board of Accountancy and other
            stakeholders to explore solutions that could mitigate any potential loss of revenue so that the

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    Board of Accountancy’s ability to operate is not negatively impacted by this legislation. To
    date, no state that has passed mobility, including some that like DC have a large number of
    out of state licensees, have reported significant revenue shortfalls. Though it is very early in
    many states to ascertain if anticipated shortfalls have come to fruition, some states have
    worked to make up potential revenue losses through increased fees on remaining licensees.
    The GWSCPA would be likely to support a modest increase in registration fees in DC that
    could mitigate projected revenue losses, should data to that effect be provided.

   Enacting Mobility is good for DC consumers. Implementation of a uniform provision
    allows DC consumers to receive timely services from the CPA best suited to the job,
    regardless of location and without delays necessitated by obtaining a reciprocal license.

   Mobility actually strengthens the ability of the DC Board of Accountancy to protect
    the public interest. Under the legislation, the Board will gain automatic jurisdiction over all
    CPAs practicing any part of an engagement in the District, whether or not they set foot onto
    District soil or obtain the reciprocal license that is currently required. Since there is a strong
    likelihood that CPAs are currently operating without the necessary reciprocal license now, as
    was found to be the case in other states, this provides the Board with enhanced consumer
    protection capability.

   In summary…

     Mobility is good for DC CPAs and the local business community.
     Mobility is good for DC consumers and protection of the public interest.
     There are ways to mitigate revenue concerns if we work together and base decisions on
      fact rather than speculation.
     Failing to pass mobility could have negative consequences for CPAs and business in the
      District.




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