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Published 1 (2020-04-27)

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cAO U.S. GOVERNMENT ACCOUNTABILITY OFFICE
441 G St. N.W.
Washington, DC 20548


April 27, 2020

Mr. Michael Decker
Vice President, Examinations
American Institute of Certified Public Accountants
Princeton South Corporate Center
100 Princeton South, Suite 200
Ewing, NJ 08628

GAO's Response to the American Institute of Certified Public Accountants' December
2019 Exposure Draft and Invitation to Comment, Maintaining the Relevance of the
Uniform CPA Examination

Dear Mr. Decker:

This letter provides GAO's response to the American Institute of Certified Public Accountants'
(AICPA) exposure draft and invitation to comment, Maintaining the Relevance of the Uniform
CPA Examination. GAO promulgates generally accepted government auditing standards
(GAGAS), which provide professional standards for auditors of government entities in the United
States.1 GAGAS provides a framework for conducting high-quality audits of government awards
with competence, integrity, objectivity, and independence.

GAO generally agrees with the practice analysis's (PA) direction, including its focus on the
knowledge and skills required of newly licensed certified public accountants (nICPA). However,
we are concerned about the exposure draft's proposed changes to GAGAS exam content. In
our opinion, government auditing knowledge and skills are critical for nICPAs. We believe that
the Uniform CPA Examination (CPA Exam) should maintain the current content related to
GAGAS. In our view, auditors that have recently taken or passed the CPA Exam are regularly
staffed to governmental audit teams, and it is crucial for nICPAs to have an understanding of
and be able to apply GAGAS independence and ethics requirements when conducting these
audits. The public interest in government spending, the number of organizations required to
comply with government auditing standards, and the quality issues in this area demonstrate the
need for the AICPA to test potential CPAs in government auditing standards.

We also encourage the AICPA to consider maintaining content related to government
accounting standards. We believe that knowledge and skills in government accounting
standards are critical for nICPAs. For state and local governments, the AICPA could consider
focusing on fund accounting and how it differs from for-profit accounting. In addition, we strongly
believe that the AICPA should include content in the exam related to basic concepts of federal
accounting standards that the Federal Accounting Standards Advisory Board issues, which the
AICPA has recognized as the generally accepted accounting principles (GAAP) standard-setting
body for federal reporting entities since 1999. As noted above, nICPAs are often members of
governmental audit teams, and it is critically important they are familiar with fund accounting.
Similar to government auditing standards, government accounting standards have a far-


1GAO, Government Auditing Standards: 2018 Revision, GAO-1 8-568G (Washington, D.C.: July 2018).


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