I would like to thank the Majority Leader, the Chair of the Higher Education Committee (and the Honorable members of the Assembly) for giving me this opportunity of appearing before them this afternoon.

My name is Thomas A. Sullivan. I am a second generation Certified Public Accountant and member of the New York State Society of CPAs. My father, William H Sullivan, was certified in 1937 and practiced as a public accountant in a Big Eight firm until 1947 and then in his own firm until his death in 1970.

I worked in public accounting for 19 years. I started out with a second tier national firm, for four years and then spent the next 15 years working for a small regional New York City firm.

My public accounting experience has covered very large and complex audits leading to consolidating financial statements to the more routine payroll and write-up work for very small clients.

Since 1980 1 have been in private accounting working for the National Football League. I have held the positions of Controller, Treasurer and now Vice President of Internal Audit.

The National Football League is a professional sports league with 32 teams. The teams are located coast-to-coast in the major cities and areas of the country with the league headquarters located in New York City. The league currently employs more than a dozen CPAs at its headquarters companies in the accounting, treasury and finance areas.

I appear before you today to testify in support of Assembly bill number A. 8600.

I agree with the bill's provision that anyone using the CPA designation whether in public practice or in industry should be held to the highest standards.

Being a second generation CPA the CPA designation has a special meaning to me. Because of that you may think I may want the status quo to continue. But that is not so. My father always stressed the professionalism of being a CPA and was interested in anything that enhanced professionalism. He also stressed "keeping current" as he called it long before the term Continuing Professional Education (CPE) was invented.

He also was a great believer in education. He earned a college degree at night during the depression before it was a necessary CPA requirement. And was an accounting professor at St. John's University when it was in Brooklyn and St. Peter's College in Jersey City.

And I believe that the standard should be a standard of excellence. The AICPA prides itself on its IS09000 Certification because if you can attain excellence than the work you perform will be of the highest standard.

I also support non-technical courses for CPE. I believe the current CPE program is flawed because it doesn't serve either the practicing CPA or the CPA in industry. If you are a practicing CPA over a two or three-year period you have taken most of the technically relevant course.

When I first started in public accounting, the books of most small companies were posted byhand. That job has virtually disappeared and replaced by spreadsheet and general ledger programs. But the knowledge of how to use these computer programs is not considered CPE. Knowing how to use computers and how to operate relevant programs should be measures of a standard of excellence.

The problem I have as a CPA in industry with CPE is that the current CPE courses are just not designed for us. Currently I am as expert in spreadsheet and database computer programs as most accountants yet we have not received a single CPE credit for that knowledge.

These programs give me powerful analytical skills. I use these skills to model complex projections for clients who need the information to make critical business decisions. As an example, one of my current royalty audits requires me to review six million subscriber accounts.

This audit would have been impossible only five years ago without access to main frame computers and a full Information Technology staff. And it would have taken four to six weeks.

Currently I do this job with a staff of three none of who is an IT professionals. This job is accomplished with lap top computers and spreadsheet and database programs in a week and one-half. My employer and my client both benefit from my expertise.

This knowledge makes me a better and more efficient auditor and allows me to spend my time thinking and analyzing rather than doing. I believe I have attained a standard of excellence in this particular area but no CPE.

In trying to stay current on my CPE I try to find relevant courses but few exist. After almost forty years in the accounting profession I am hard pressed to find CPE courses that cover new ground.

I have to go back to the annual auditing conference to get the bulk of my CPE credits even though the conference is directed to practicing CPAs and does not help me in any of my electronic audits.

My father could do the actual auditing work I do because the basic auditing concepts haven't changed since he was certified. What have changed are the techniques. My father worked in a paper world. I work in an electronic world. CPE credits do not relate to my world.

One of my current projects is to make our internal audit environment paperless. I make extensive use of E-mail, the Internet, database programs and electronic audit work paper programs. All of this makes my department more efficient and gives my employer and my clients better and more timely information with less audit staff and support staff but none of these innovations qualifies for CPE.

By chance the November 1999 issue of THE CPA JOURNAL arrived last Friday. November being technology month the entire issue is devoted to technology. The issue is called "The Power of Technology, The CPA in the Connected Century". Some of the articles listed on the cover are; Software to Build Your Write-up Practice; and Productivity Solution for CPA's on the Go.

I have attached a copy of the cover and the table of contents to my notes. The cover shows three individuals using technology. Two with laptops and the third using a cell phone.

I would like to quickly read the brief explanations of some of the articles from the index. The Internet into the Next Millennium - "What impact will technology have on the CPA into the next millennium? Plenty, as the Internet and related technologies transform the relationship between client and CPA, and redefine the flow of information. The benefits: moving up the value chain while improving client service and the efficiency of the entire financial system."

"E-commerce and the transfer of back office fimctions to the Internet will, through adoption by clients and successfid businesses, come to dominate the CPA's world."

"The CPA is moving up the value chain, leaving clerical services and routine questions in the client's hands."

Building Your Write-up Practice - "By choosing the right write-up software program, practitioners can give clients everything they're really looking for from consumer programs while strengthening the relationship and remaining available for those problems only a professional can solve."

"The CPA practitioner can utilize write-up software programs to establish a direct, time-saving connection to the client's records. The CPA can keep constant tabs on the client's situation. The CPA can then reposition and emphasize greater value-added services over the write-up work the client performs for itself under the supervision of the CPA."

New Productivity Solutions for CPAs on the Go - "CPAs that spend a lot of time on the road know that every moment spent in transit is lost productivity - time that could be spent getting work done. Mobile tools have become both affordable and powerful as computer technology has advance in leaps and bounds."

Trying to establish and teach CPE courses about such a fast moving environment is almost impossible. In my opinion it would be in the best interests of the profession to stress excellence and leave it to the 'individual to decide how they want to invest their time and where they want to take their career or practice.

I also support the provision of the bill related to the experience requirement. At the same time I would like to address an alternate method of how to make the profession available to as many qualified people as possible.

There is a very narrow window for students to decide that they want to be CPAs. This usually happens early in their college career because of the extensive course work. I believe that an alternate route should be available such as is available in teaching.

I took the conventional route. A BS in accounting with the required courses for the CPA exam. Upon graduation I work for a CPA firm for the then required three years and eventually passed the CPA exam. I basically made my choice upon entering college. That was easy for me because of my father's guidance.

But what about otherwise qualified individuals who don't or can't take the conventional route and then at a later date want to be certified. It is almost impossible for them to backtrack to meet the experience requirements. If I as a CPA could verify their experience because of their work for me this would give them another option.

One of the anomalies of the current law is that if I were a practicing CPA I could give a staff person credit towards their experience requirement for the CPA exam. However because I am in private industry I can not give a staff person credit for exactly the same work without elaborate paperwork.

As a case in point a former staff person of mine has passed all four parts of the CPA exam. All he needs is verification of his experience. If I were in public practice it would require one or two pieces of paper. My estimation of the time he spent at various tasks based on percentages would be sufficient to validate his experience.

However because I am in private industry every hour must be itemized and the work described in detail. If someone were trying to get the experience requirement for a year this would require the details for almost 1,000 hours of work.

Each hour must then be reviewed by education department personnel and can be rejected even though signed off by a licensed CPA. We are about to file literally dozens and dozens of pieces of paper in support of his experience requirement. And again all of his extensive knowledge with computer programs is not allowable, and is not included.

Why are CPAs in industry treated as second class citizens in this situation? I take great pride in the CPA designation and would not jeopardize it by allowing an unqualified person to be able to use it.

Allowing this type of work experience to be considered would give the candidates an alternate route and hopefully attract more individuals to the profession.

Thank you for your time this afternoon.

I would be pleased to answer any questions you may have.