The experience requirement and what the verifying CPA attests to

In this lesson you will

Describe the types of work that count as experience under UAA Section 5(f)(3)
Compute whether part-time work meets the Model Rule 6-2(c) definition of one year
Identify who may supervise and who must verify experience
Recognize verification practices that a board can challenge

What the UAA requires

UAA Ninth Edition Section 5(f) sets the experience for an initial certificate. Applicants under the post-baccalaureate and bachelor's-plus-30 pathways show one year of experience; applicants under the bachelor's-only pathway show two years. In both cases the board defines experience by rule.

Section 5(f)(3) describes qualifying experience: providing any type of service or advice representing the skills needed at initial licensure, involving accounting, attest, compilation, management advisory, financial advisory, tax or consulting skills, all verified by a licensee meeting board-rule requirements. The experience is acceptable if gained through employment in government, industry, academia or public practice. The UAA comment adds that the experience may be supervised by a non-licensee but must be verified by a licensee.

What the Model Rules add

UAA Model Rule 6-2 (January 2024 Model Rules) fills in the detail for the one-year requirement:

6-2(a) Experience may consist of providing any type of services or advice using accounting, attest, compilation, management advisory, financial advisory, tax or consulting skills.
6-2(b) The applicant's experience is verified to the board by a licensee or an individual licensed in another state. The board looks at factors such as the complexity and diversity of the work.
6-2(c) One year of experience is full- or part-time employment that extends over no less than a year and no more than three years and includes no fewer than 2,000 hours of the services described above.

The January 2024 Model Rules predate the Ninth Edition's two-year pathway, so the hour definition for two years of experience comes from your board's rule. Do not double the 2,000 hours on your own.

Board follow-up

Model Rule 6-3 gives the board tools to test what the verifier signed:

A licensee who refuses an applicant's request to submit evidence of experience must, on board request, explain the refusal in writing or in person.
The board may require anyone who furnished evidence to substantiate it.
The applicant may be required to appear before the board to supplement or verify the evidence.
The board may inspect documentation of the claimed experience.

What the verifying CPA should do

The verifier is attesting to facts, so treat the form like any other signed representation:

Verify only work you supervised or can confirm from records: time reports, engagement files, job descriptions.
Check the dates and hours against the board's definition, including the time limit.
Describe duties in the board's terms (attest, tax, advisory) rather than job titles.
Keep a copy of what you relied on. Model Rule 6-3(b) lets the board ask you to substantiate it later.
Confirm your own license meets the board's verifier requirements.

The experience verification guide covers the forms in more detail. Signing a form you cannot support raises an integrity issue under the AICPA Code's Integrity and Objectivity Rule (ET 1.100.001), which bars knowingly misrepresenting facts.

Common problems

Counting hours outside the one-to-three-year span.
Experience supervised by a non-licensee with no licensee who can verify it.
Verification by a CPA whose license lapsed.
Vague duty descriptions that do not match the board's categories.

Worked example

Part-time hours under Model Rule 6-2(c)

Sam Patel works part-time at Cedar Point Advisors while finishing a master's degree (pathway A, one year of experience). His board follows Model Rule 6-2(c): at least 2,000 hours over a period of not less than one year and not more than three years.

Year 1: 25 hours a week x 50 weeks = 1,250 hours. Year 2: he goes full-time at 40 hours a week. Hours needed after year 1: 2,000 - 1,250 = 750. At 40 hours a week, 750 / 40 = 18.75 weeks, so 19 weeks.

Total span: 1 year + 19 weeks, which is more than one year and less than three. Total hours: 1,250 + (19 x 40 = 760) = 2,010, above 2,000.

Verification: his supervisor in year 1 is a controller who is not licensed; in year 2 he reports to a CPA. The UAA allows non-licensee supervision but requires a licensee to verify. The CPA reviews the year 1 time reports and job description, confirms the duties were accounting and tax work, and signs.

Conclusion: Sam meets the one-year definition at 2,010 hours over about 1 year and 19 weeks, with verification by a licensee who kept the records she relied on.

Self-check

Answer each question before you open the answer.

Under Model Rule 6-2(c), does 2,400 hours of work completed in eight months satisfy one year of experience?
Show answer
No. The rule requires employment that extends over at least one year and no more than three years, plus at least 2,000 hours; eight months is too short a span.
Can a non-CPA controller supervise a candidate’s experience under the UAA?
Show answer
Yes, under the UAA comment to Section 5(f), experience may be supervised by a non-licensee, but it must be verified by a licensee.
What can a board do if it doubts the experience a CPA verified?
Show answer
Under Model Rule 6-3 it may require the verifier to substantiate the information, require the applicant to appear, and inspect documentation of the experience.
Which types of employment does UAA Section 5(f)(3) accept?
Show answer
Government, industry, academia or public practice, as long as the work uses accounting, attest, compilation, advisory, tax or consulting skills and is verified by a licensee.

Sources

Back to the syllabus

Standards are paraphrased from the primary sources listed above; read the source before relying on a requirement. This lesson is training material, not professional advice. Report an error