Mr. Louis Grumet, Executive Director
New York State Society of CPAs
3 Park Avenue, 18th Floor
New York, NY 10016

Dear Mr. Grumet:

We are writing in response to your recent publisher’s column entitled “Leap of Faith” that was printed in the November 2006 edition of The CPA Journal. Your column suggests that credit for affecting a change from pass fail to numeric score reporting be given to the New York State Society of CPAs (State Society) CPA Exam Task Force report detailing its findings and recommendations based on a survey of approximately 600 examination candidates.

While the survey provided an interesting snapshot of information that supported State Board decisions regarding the computer-based CPA examination, the task force report was not a factor in the State Board’s deliberations because the survey did not represent a random sample of examination candidates and the survey’s response rate was too low to provide statistically valid information.

The State Education Department and the State Board for Public Accountancy have been actively involved in the transition to computer-based testing (CBT) and have continually monitored and sought resolution of key issues associated with the new exam since its inception in April 2004. The Department, with assistance from the State Board, has written several letters to both the American Institute of Certified Public Accountants (AICPA), the owner of the examination, and the National Association of State Boards of Accountancy (NASBA), the owner of the national candidate database through which candidate applications and scores are processed, expressing concerns about significant deficiencies with CBT. This continued involvement by State Board members and State Education Department staff provided the foundation of the State Board’s recent recommendation to amend the regulations to enable score reporting on a numeric basis.

At its April 2003 meeting, the State Board for Public Accountancy unanimously approved the reporting of scores on a pass/fail basis rather than on a numerical basis with the transition to computer-based testing in April 2004. The State Board decision was made after careful study and discussion of five score reporting issues: statistical validity of numeric scores, examination section re-grades, professional competency, enhanced diagnostic reporting under a computer-based examination, and more timely score reporting to candidates under a computer-based examination. The Regulations of the Commissioner of Education were amended to reflect the Board’s recommendation.

While drafting the amendments and during the comment period, the Department continually engaged the State Society in discussions about the proposed amendments, including providing a copy of draft amendments to the State Society as an “interested party.” We did not receive any negative comments about the proposed amendments prior to action by the Board of Regents.

However, after the first CBT examination window in July 2004, we learned that the diagnostic reporting model implemented under Computer-based testing (CBT) was less effective than that provided under the paper & pencil version of the examination and that scores were not being reported to candidates within two to three weeks of sitting, as was proposed before implementation.

Today, all parties, including the AICPA, acknowledge the shortcomings of the present diagnostic reporting model. While the AICPA has been unable to provide accelerated score reporting in the manner proposed prior to computerization, score reporting remains a priority of the AICPA’s Board of Examiners. It is expected that enhanced diagnostic reports will be implemented later this month with the release of scores for testing in the fourth quarter of 2006, albeit nearly two and one half years after the implementation of CBT.

Early draft versions of the revised diagnostic report were provided to state boards of accountancy for review and comment earlier this year. The New York State Board for Public Accountancy provided feedback to the Board of Examiners, including a request that greater specificity within content areas be provided to examination candidates on the revised diagnostic reports.

The final revised version of the candidate diagnostic report adopted by the Board of Examiners does not provide the level of specificity sought by the State Board. This lack of specificity was a significant factor in the State Board’s decision to recommend a return to numeric score reporting.

State Board members remain concerned about other examination-related matters including the timeliness of score reporting by the AICPA, ever increasing examination costs, and hardware and software issues encountered by candidates taking the examination. We continue to address our concerns through dialog with examination vendors and continued involvement in examination related committees and task forces.

The State Board for Public Accountancy will continue to monitor, evaluate and discuss these and other issues that impact the public interest and the integrity of the public accounting profession in New York. We appreciate the interest of the State Society in these issues of mutual concern.

Sincerely,

Robert L. Gray, CPA
Chair, NYS Board for Public Accountancy

Brooke Anderson-Tompkins
Chair, NYS Board for Public Accountancy Examination Committee