BEFORE THE BOARD OF PUBLIC ACCOUNTANTS 

                          DEPARTMENT OF LABOR AND INDUSTRY 

                                            STATE OF MONTANA

 

In the matter of the amendment of ARM 24.201.101 board organization, 24.201.301 definitions, 24.201.505 firms – registration, and 24.201.532 nonroutine applications, and the repeal of 24.201.401 board meetings, 24.201.405 committees, 24.201.524 cheating, 24.201.1101 introduction, and 24.201.2101 renewals

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NOTICE OF AMENDMENT AND REPEAL

 

TO: All Concerned Persons

 

            1. On September 24, 2021, the Board of Public Accountants (board) published MAR Notice No. 24-201-54 regarding the public hearing on the proposed amendment and repeal of the above-stated rules, at page 1170 of the 2021 Montana Administrative Register, Issue No. 18.

 

            2. On October 15, 2021, a public hearing was held on the proposed amendment and repeal of the above-stated rules via the videoconference and telephonic platform. Comments were received by the October 22, 2021, deadline.

 

            3. The board has thoroughly considered the comments received. A summary of the comments and the board responses are as follows:

 

COMMENT 1: Several commenters suggested that the board should have more than one person reviewing applications which are submitted to the board for approval.  Their concern, at least partially, stems from removal of current procedures which have up to eight persons reviewing each application to a non-specified number under the proposed rule.

 

RESPONSE 1: The board appreciates the concern and understands that its proposed change is a large shift in historical processing of applications.  Over the past eight months staff has provided the board with sufficient evidence that they are capable of processing most applications that the board receives.  This change in turn will result in faster licensure for many applicants who are well-qualified and tested, and ultimately receive a license in addition to having spent multiple years attempting to gain the required qualifications. These also include applicants initially found deficient by the board but are licensed by staff upon receipt of supplemental materials.  The board believes that department staff, including an executive officer, counsel, and administrative support, can process applications without a significant loss of quality.  Their review is secondary to NASBA reviewing applications for licensure which the board has entrusted on several matters.  The board will continue to evaluate the efficacy of the change moving forward but believes the current proposed amendment is appropriate at this time.

 

COMMENT 2:  Several commenters suggested that the board look at its experience evaluation requirements under ARM 24.201.502 to clarify discrepancies in applications.

 

RESPONSE 2: The board will continue to evaluate its experience requirements moving forward to provide applicants the best footing in complying with the requirements while ensuring the board's mission of public safety.

 

            4. The board has amended ARM 24.201.101, 24.201.301, 24.201.505, and 24.201.532 as proposed.

 

            5. The board has repealed ARM 24.201.401, 24.201.405, 24.201.524, 24.201.1101, and 24.201.2101 as proposed.

 

 

	BOARD OF PUBLIC ACCOUNTANTS DAN VUCKOVICH, CPA PRESIDING OFFICER
/s/ DARCEE L. MOE Darcee L. Moe Rule Reviewer	/s/ LAURIE ESAU Laurie Esau, Commissioner DEPARTMENT OF LABOR AND INDUSTRY

 

 

            Certified to the Secretary of State November 30, 2021.