Rulemaking Calendar

The Board of Accountancy is committed to protecting Oregon consumers by ensuring qualified licensees practice public accountancy in accordance with established professional standards and promulgated rules. We embrace diverse backgrounds and experiences, ensuring that accounting inequities are addresssed while also ensuring to engage with the public in a variety of ways. There are many ways you can get involved in the decision-making process in regards to accounting such as by appearing at one of the numerous Board or Committee meetings displayed below. The BOA holds open comment periods on our rules and proposals as well holding frequent meetings open for the community to attend. All meetings provide the oppurtunity for public comment as a part of the agenda while other meetings are dedicated soley to gathering public comment.

NOTE: The Board and LRC are discussing potential policy responses to the emerging issue of private equity ownership of CPA firms. That work initially will focus on what legislative language tweaks may be appropriate to propose (and when), before any rulemaking can take place on any passed legislation. At this time, the BOA's focus is on monitoring the recommendations developed at the national level (AICPA and NASBA).

FOR QUESTIONS REGARDING BOARD RULEMAKING ACTIVITIES, PLEASE CONTACT:

Martin Pittioni
Executive Director
State of Oregon Board of Accountancy
Cell: 503-569-7686
martin.pittioni@boa.oregon.gov

PAST PUBLIC COMMENTS

Comments:

Michelle Heckel, Casseil, Inc.

I believe the eligibility requirements should be changed to include graduates no longer attending university out in the workforce. It is my belief that many students do not realize the importance of the CPA until being on the job. The need for assistance is much greater out of college. I would not have been able to afford the exams, travel, and time off work required to take my tests had it not been for an extremely understanding and generous employer. Not all employers are that generous, there is a great need for scholarships/grants for CPA exam expenses for candidates that are no longer at their institutions.

Scott Wright, Kernutt Stokes

Is it the Board’s intent that scholarship awards, to be issued under the Oregon Board of Accountancy Pipeline Scholarship Grant Program, (Program), would be available to incoming freshmen at an eligible institution? Or, rather is the intent to limit such awards to
1) “established” students at eligible institutions, and
2) those who are already taking accounting and business courses?

I ask in that proposed OAR 801-060-0030 provides the definition for an eligible student, i.e., a person that can receive a scholarship under the Program. Specifically -

A) Proposed OAR 801-060-0030 (1) requires that a scholarship recipient be currently enrolled in an eligible institution. Would this prevent the issuing of a “tentative”” scholarship to a high school senior, (or person taking time between high school and their higher education), who has the intent to enroll in an eligible institution and planning to enter an accounting program? Based on timing of the scholarship application and then award, institution admittance, and completion of the actual enrollment process, there could be a “gap”. Would OAR 801-060-0030, as proposed, allow for a Program scholarship award, subject to the requisite enrollment, with the scholarship withdrawn if required eligibility requirements, including enrollment, are not timely met? If such a gap is an issue, the wording of the proposed OAR could be at odds with a Board intent of getting students into accounting early in their educational journey.

B) Proposed OAR 801-060-0030 (4) requires “good standing” for eligibility, with good standing defined as maintaining a GPA of at least 2.5 in all accounting and business courses. As worded, does this limit Program scholarship awards to those students that have already taken at least one accounting and business classes at an eligible institution? Freshmen students may not take their first accounting or business classes until perhaps several semesters/quarters into their educational journey. Are they, therefore, ineligible for a Program scholarship award until they take such classes? This could even make certain sophomores ineligible for a Program scholarship award, at least until they were to take such specified classes. Again, the proposed OAR wording may be at odds with a Board intent of getting students into accounting early in their educational journey,

The proposed OARs provide the legal framework for any contract that the Oregon Board of Accountancy, (as a Grantor), enters into with a Grantee. (With the Grantee being the entity that awards Program scholarships.) As such, I would think that the OAR should be fully, and clearly, reflective of the Board’s intent. If a grant contact allows for incoming freshmen to be eligible recipients, while the underlying legal framework, as per the proposed OAR, is not written/interpreted as allowing such freshmen eligibility, might such a grant contract be invalid ? (I guess for legal minds to determine.)

If the Board’s intent is to delay Program scholarship awards until later in a student’s accounting education process, i.e., to just upperclassmen, then there may not be issues.

Elizabeth Almer, Portland State University

That said I would like to request that the Board not adopt OAR 801-060-0080 Grantee Reporting Requirements as exposed. Instead I am respectfully asking to consider that the Board make the following changes to that portion of the exposed section of the rules through whatever legal mechanism the Board has available to it. My proposed rule changes are outlined in strikethroughs for deleted text, and underlined italics for proposed added text. Thank you so much for considering this request, which in my personal view will help the Board better achieve its program goals and allow for the best possible grant agreement to be developed and executed.

OAR 801-060-0080 Grantee Reporting Requirements:
(1) Grantees receiving a scholarship grant program grant must collect data and other information specified by the Board of Accountancy related to the scholarship grant program and report that information to the board annually or as otherwise specified in the grant agreement.¶
(2) The grantee Grantees must collect and report to the board scholarship recipient information, including
where reasonably possible and to the extent allowable by law, the following aggregated, program-wide information, categorized by college or university, regarding the Scholarship Program, applicants, and awardees. Aggregated information should be reported only for colleges or universities where there are at least three or more applicants or scholarship awardees whose information is being aggregated. The information below must be reported unless it is not feasible to provide the information and Recipient receives written approval from the board
(a) Total number of applicants to the scholarship program.
(b) Total number of scholarships awarded during the year and total number renewed;
(c) Methods used to determine financial need;
(d) Total scholarship funds awarded and the average award amount across all students;
(e) Average GPA of awardees in all accounting and business courses, and range of GPAs (lowest–highest);
(f) Aggregate count of awardees by academic level (e.g., freshman, sophomore, junior, senior, graduate);
(g) For renewal applications, total number of awardees in good standing and, if applicable, total not in good standing;
(h) Total number of awardees with enrollment or completion changes (e.g., revised completion dates, changes in status, leaves of absence);
(i) Aggregate demographic responses (reported in totals only) to voluntary questions per BOA guidance, including age, gender, veteran status and disability (defined as “an individual who is eligible to receive or is receiving federal Social Security benefits due to disability or blindness”).
(j) Summary of any barriers to administering the Oregon Board of Accountancy Pipeline Scholarship Program and how these were addressed;
(k) Aggregate follow-up information, to the extent reasonably possible, from students after participation in the scholarship program, including degrees or certifications obtained by awardees (total counts) and number of awardees who became licensed in Oregon as professional accountants.¶
(a) The eligible institution attended by the student;¶
(b) The enrollment status and amount of scholarship grant program funds disbursed to each eligible student;¶
(c) The basis used to determine financial need such as Pell Grant or Oregon Opportunity Grant status;¶
(d) Each scholarship recipient's grade point average in all accounting and business courses;¶
(e) Each scholarship recipient's academic level and total credits earned;¶
(f) Whether the scholarship recipient is in good standing;¶
(g) Whether the scholarship recipient receives any other need-based or other financial aid; and¶
(h) Any other information specified by the board.¶
(3) In addition to the reporting required under section (2) of this rule, grantees must collect and provide demographic information specified by the board for the pool of applicants for scholarship grant program funds and for all scholarship recipients. To the extent allowed by law, the demographic information collected and reported must include the following information on applicants and recipients:¶
(a) Age;¶
(b) Veteran status;¶
(c) Disability status;¶
(d) Gender;¶
(e) Race and ethnicity;¶
(f) Whether the applicant or recipient is a first generation college attendee;¶
(g) The applicant's or recipient's first language spoken; and¶
(h) Any other information specified by the board.

Lynette Ochoa, Musser Olsen PC

I quite liked the NASBA platform, and the ability to have all documentation uploaded to one site. If selected for audit, the process is much more streamlined than sending all of the documentation to the office.

Comments:

No Public Comments received

Comments:

John MacDonald - Retired CPA

Rule 801-010-0119

Comment: Under the prior rules, a retired CPA could use their accounting skills as a volunteer (801-010-0120(6)(b)(C)). Under the new rules (801-010-0119(3)(a)) all a retired CPA can do is provide volunteer tax services. What does this rule change do to a retired CPA who provides volunteer services as the treasurer of a 501(c)(3) organization? A treasurer is generally expected to provide more than just bookkeeping services, some level of accounting analysis is required, which would seem to be prohibited under the new rule.

Harry Bose - The RBH Group

Rule: 801-010-0120

Comment: I recall that the Board was making an effort to help CPA firms find qualified staff, given the lack of accounting graduates in the pipeline. The changes made with respect to retirees are going to help significantly, but I was hoping that there would be more opportunity to hire folks with lapsed or inactive licensees who are returning the workforce after taking time off to, for example, raise children. Could there be a grace period between the hire date of a lapsed licensee and the date by which the lapsed licensee meets the conditions to reactive their license?

I am reading the changes for inactive licensees at OAR 801-010-0120 and need some help understanding. The way I read the changes, an inactive licensee working for a CPA firm could not prepare income tax returns, even if under the supervision of a CPA, and even if in a non-client facing role?

As a peer reviewer, I see CPA firms hiring folks who do not have an accounting degree, although many of those hired have a four-year degree of some kind. The firms assign them to audit and tax preparation engagements. These staff members are not on a CPA track and may never obtain CPA certification. It seems incongruous that a CPA firm can hire an English major or Math major, or apparently anyone as long as they have not been licensed previously, to staff audit engagements when firms cannot hire a more qualified individual whose license is lapsed or inactive – is that in fact the state of affairs we face as a profession in Oregon?

Another question for I have: How much is determined by the statutes when you are drafting these rules? For example, would the statute allow you to establish through rulemaking a grace period for a former CPA re-entering the workforce to reactivate their license or, in this respect, are your hands tied by the statute?

Appreciate your time. I only hear good things about you. We are fortunate to have you as the executive director.

Daniel Ellis

Comment: (20) “Substantially equivalent” means a license an individual holds from another state, and the other state requires the individual, as a condition of licensure as a certified public accountant, to achieve a passing grade on the Uniform Certified Public Accountant Examination and:
(a)(A) Complete at least 150 semester hours of college education, obtain a baccalaureate or higher degree conferred by a college or university and possess at least one year of experience verified by a license holder in providing any type of service involving the use of accounting, attestation, compilation, management advisory, financial advisory, tax or related consulting skills, obtained through public practice or government, industry or academic work;
(B) Obtain a baccalaureate degree and possess at least two years or more of experience verified by a license holder in providing any type of service involving the use of accounting, attestation, compilation, management advisory, financial advisory, tax or related consulting skills, obtained through public practice or government, industry or academic work; (
C) Obtain a master’s degree and possess at least one year or more of experience verified by a license holder in providing any type of service involving the use of accounting, attestation, compilation, management advisory, financial advisory, tax or related consulting skills, obtained through public practice or government, industry or academic work; or
(D) Meet requirements otherwise prescribed by the board; or (b) If the other state does not require an individual to have the qualifications specified in paragraph (a)(A), (B), (C) or (D) of this subsection as a condition of licensure as a certified public accountant, the individual nonetheless has the qualifications specified in paragraph (a)(A), (B), (C) or (D) of this subsection. SECTION 2. ORS 673.050 is amended to read: 673.050. [(1) Except as provided in subsection (2) of this section, a candidate for admission t

Ali Beaudoin - CPA Applicant

Comment: I am writing regarding a future application for CPA licensure in the State of Oregon. I would like to inquire whether there is a process to request a review or reconsideration of the current requirement of 24 semester hours of upper-division accounting coursework, specifically whether there is any flexibility to allow accounting credits regardless of course level.
As an Oregon resident, I have been exploring licensure pathways in other states due to this requirement, and I am interested in understanding whether Oregon offers any alternative review, waiver, or policy consideration options.I have an BA in Economics and MBA with a focus on Finance and Accounting; but still lack upper accounting credits.
Thank you for your time and consideration. I appreciate the Board’s commitment to maintaining high professional standards and would welcome the opportunity to provide additional documentation or clarification if helpful.

Kim Martin - CPA Appliant

Rule: 801-010-0065

Comment: 801-010-0065(6)(c) and (d) both incorrectly refer to "application for a restored permit" when they should refer to "application for initial licensure" or similar, to match the section they are in.

Stan Martin - Inactive CPA

Rule: 801-005-0010

Comment: The proposed OAR 801-005-0010 (58)(b) should now reference OAR 801-010-0119, which is the newly proposed OAR specifying details about Retired Licensee Status.

Stan Martin - Inactive CPA

Rule: 801-010-0120

Comment: The title of the rule should be “Inactive Licensee Status”

I understand the difficulty in trying to identify differences in what a Retired Status CPA and an Inactive Status CPA may or may not do, but the language in the currently proposed OARs seems to give more latitude for a Retired Status CPA to work in a CPA firm than an Inactive Status CPA. That is counterintuitive since the Inactive Status CPA must meet certain CPE requirements, including ethics, where the Retired Status CPA has no CPE requirements whatsoever. One would think that the Inactive Status CPA should be able to do any accounting/financial-related work that a Retired Status CPA is allowed to do—plus a few things! That is not evident to me based on the examples of allowed work in either the current OAR 801-010-0120 or the proposed OAR 801-010-0119 and OAR 801-010-0120.

I apologize for not offering specific language suggestions in this comment to provide more clarity, but I have neither the time nor the bandwidth to do so!

Sherri McPherson - OSCPA President

Rule: 801-010-0080

Comment:

Dear BOA Board Members, Executive Director Martin Pittioni, and Staff,

On behalf of the Oregon Society of CPAs (OSCPA), thank you for the opportunity to provide both written and verbal comment for the Oregon Board of Accountancy rulemaking hearing scheduled for Thursday, January 29, 2026, at 9:00 am.
Our comments below are from feedback received related to the proposed rules:
Principal Place of Business (PPB): The ORS definition of PPB currently reads as "the location of the principal office where a person practices public accounting or as otherwise further defined by the board by rule." It does not consider designating the PPB based on a CPA's own designation and the proposed OAR definition does not reference allowing a CPA to specify their PPB. Shared is that best practices would allow the Board to rely on the CPA's designation of the PPB by further defining the PPB via rule. Permission is granted in the statutory language "or as otherwise further defined by the board by rule." This permission provides the Board with the opportunity to adopt a definition more closely aligned with current professional practice.
• We recommend the rules be amended to read as follows: "Principal Place of Business means the location of the principal office where a person practices public accounting, as designated by the person."
• If the Board is unable to adopt this amendment, we ask the Board to consider the CPA's designation of the PBB unless information comes to light to call that into question.
Defining "Professional" to Include Consulting Services: We encourage the Board to consider removing consulting services from the definition of "professional." As consulting generally arises within the context of licensing experience requirements such as under the UAA rather than as a type of professional service performed by CPAs. Clarifying this distinction would provide clarification and reduce confusion.
Mobility Regulations: The current OAR addresses this via limited provisions in OAR 801-010-0080 per the following:
• Subsection (1) permits licensed CPAs in good standing in another jurisdiction, with a principal place of business outside Oregon and substantial equivalency of licensure, to practice in Oregon.
• Subsection (4) authorizes reliance on NQAS information for verifying substantial equivalency.
The proposed draft removes subsection (1) but retains subsection (4) (renumbered as subsection (2)), with slight modifications. We understand the omission of subsection (1) eliminates explicit OAR language on mobility except for references regarding NQAS. Based on the comprehensive nature of the Oregon mobility statute, we recommend the Board retain subsection (1) of 801-010-0080 to maintain clarity around mobility provisions.
Employee Stock Ownership Plan: A question has been advanced of whether the related ORS intended to provide that an owner could "be" a stock ownership plan, versus that they could "have" a stock ownership plan. Are the OARs correcting that point?
Thank you kindly for the opportunity to provide comments.

We commend the Oregon Board of Accountancy for its efforts in both the legislative and rulemaking process.
Kind regards,

Sherri L.D. McPherson, IOM, CAE, President/CEO Oregon Society of Certified Public Accountants