By: Anthony F. Gioffre,
JD, CGFM, CPA, a member of AGA's International Development Committee
Roles of professional accounting associations in
supporting economic development and reform
Professional accounting associations
perform vital roles in support of economic development and reform.
These associations serve the following purposes, among many others:
1. Identification of properly
qualified professionals. Professional associations adopt and
enforce rigorous criteria for accountants to qualify for, and
maintain, membership.
2. Communication of technical
developments among members. Professional associations promote
the dissemination of knowledge through training, conferences and
publications.
3. Advocacy. The positions of
associations, and the opinions of their leading members, can
play an important role in forming public opinion and public
policy.
In many countries outside the world’s
most advanced economies, professional accounting associations tend
not to be financially or intellectually self-sustainable. It is no
surprise that these associations do not entirely fulfill their
public service purposes. An important reason for these shortcomings
is that the qualification of the associations’ members is performed
in a way that is not consistent, rigorous, standardized and
otherwise compliant with international requirements.
The importance of
examination-based assessment of competencies
In come countries, such as the U.S.,
we often take for granted the ability to rely on credentials such as
the CPA and CGFM designations as evidence of at least a minimum
level of technical competence. The CPA exam has existed for so long,
and so many hundreds of thousands of accountants have endured it,
that CPAs and non-CPAs alike rarely imagine a world without it—nor
one without the supporting mini-industry of CPA review courses and
materials.
The qualification process requires
some entity to determine whether candidates have met all the
requirements to be designated as professional accountants.
Qualification bodies must assess whether candidates demonstrate the
necessary competencies, as a result of appropriate education and
experience. Assessment of competence may take many forms, but most
commonly is performed by means of a written examination. The
development and administration of such an examination is a
monumental task. From a purely technical perspective, consider the
scope of subject matter in which a professional accountant must be
educated in order to comply with International Federation of
Accountants’ (IFAC) criteria for professional qualification:
1.
Accounting, finance and related knowledge;
2.
Organizational and business knowledge; and,
3.
Information technology knowledge and competencies.i
These
subjects, seemingly simple enough on the surface, are of course
highly complex and cover a vast array of continually evolving
topics. Fortunately, there is now a general acceptance of what
content a professional accounting qualification examination must
encompass. In the area of accounting, finance and related knowledge,
for example, the subjects to be covered include the following:
1.
Financial accounting and reporting;
2.
Management accounting and control;
3.
Taxation;
4.
Business and commercial law;
5.
Audit and assurance;
6.
Finance and financial management;
7.
Professional values and ethics.ii
This
content is described in the International Education Standards (IES's)
promulgated by the IFAC. The United Nations Conference on Trade and
Development (UNCTAD), through its International Standards of
Accounting Reform (ISAR) and Model Accounting Curriculum, further
breaks down these subjects. The UNCTAD-ISAR Model Accounting
Curriculum, which itself is but an overview (though less summarized
than the IES’s), requires 59 pages of text. Clearly, the subject
matter in which professional accountants are expected to demonstrate
competence is both broad and deep.
Moreover, aside from the complexity of the technical subject matter
of professional accountancy, there are many equally challenging
aspects of professional qualification exams. These include
administration, marketing, dissemination, grading and maintenance.
Therefore, it is not surprising that associations with limited
resources are unable to conduct qualification programs in accordance
with all international standards. Why are qualification exams worth
all the fuss?
Ineffective or corrupt certification examinations: winners and
losers
Many individuals, groups and entire
economies suffer greatly from the lack of a proper accounting
examination. However, this sad situation tends to provide great
benefits to a few individuals and groups. The main link between
these beneficiaries and the “examination vacuum” is the need to
qualify accountants as a prerequisite to licensure: even in many of
those countries lacking an objective professional accounting exam,
accountants must be licensed in order for them to practice before
the public.
The absence of an appropriate
examination offers the opportunity for rent-seeking individuals to
develop a proprietary, opaque examination that satisfies IFAC
criteria in form, but not in substance. In many cases, such
examinations are used to generate revenue through corrupt practices.
The corruption may take one or more of various forms: direct payment
to an examination or licensing official; informally requiring
examination candidates to attend above-market-cost training at which
an official is paid dearly to lecture; making qualification or
licensure conditional on providing future favors, such as expressing
an unqualified opinion on the financial statements of an
exchange-listed firm (with which an official has insider dealings);
and so forth. Some associations are so brazen as to forgo altogether
the assessment component of the qualification process. However,
those that employ corrupt practices tend to assess candidates in an
opaque and highly subjective way. One accessible means of injecting
subjectivity into the qualification process is to assign heavy
weight to a component of the examination in which the candidate
answers questions orally rather than in writing.
It is not surprising that
beneficiaries of such cozy arrangements fiercely oppose any attempts
to disrupt them. Yet, unless some force takes the initiative to
disrupt these arrangements, associations of such “qualified
professional” accountants simply fail to serve the public interest.
If corrupted qualification bodies are unwilling to reform their
statutory examinations, then leaders of the accounting community
must take it upon themselves to promote reform.
Costs and benefits of sound, standardized certification examinations
One possible reform would be
for individual associations to take it upon themselves to perform
the examination and qualification function. As suggested above, the
scope of this task would probably be too great for any individual
association to do on its own. Imagine, for example, each state
society of CPAs in the U.S. trying to duplicate the work of the
National Association of State Boards of Accountancy (NASBA), which
administers the CPA exam. The resources required would probably
overwhelm just about any single state society of CPAs.
Moreover, even if all state societies
were to have unlimited resources to qualify candidates, there would
be strong reasons not to develop state- or association-specific
examination systems. If CPAs in various states were qualified in
accordance with examinations of varying depth and breadth of subject
matter coverage, users of professional accounting services would
have to take extra steps in order to distinguish between better- and
lesser-qualified accountants. Worse, third-party users of financial
information would not have consistent levels of assurance that an
entity’s financial statements were subjected to appropriate audit
tests.
A model for associations to
consider
International
standards for an international-minded market
Neither IFAC nor UNCTAD has any
formal authority over the licensure of CPAs; nor can either of them
mandate how state societies qualify CPA candidates. However, for
accounting associations looking to achieve compliance with
international norms, IFAC plays an invaluable role. If accounting is
the language of business, then IES’s provide standardized
requirements for assessing candidates’ fluency in that language. Of
course, one’s fluency in accounting may be expressed in many
“natural” languagesiii
other than English. Notwithstanding the growing dominance of the
English language, it is inarguably not the only natural language in
which business is conducted. In several regions of the world, there
is a common natural language in which business is conducted: for
example, Spanish in much of Latin America. If a professional
association were to establish an English language examination in a
region where the language commonly spoken by professional accounting
candidates is other than English, then relatively few candidates who
meet professional qualification criteria would be certified as such.
In many countries, professional
certification faces even bigger problems than the
prevalence of many natural languages. Among them is the prevalence
of country-specific accounting and auditing standards. The U.S., of
course, also has its own accounting standards and auditing
standards. But the country-specific nature of standards represents a
relatively small problem in the U.S., due to the tremendous size and
international dominance of the American economy. To glimpse the
difficulties that country-specific standards impose on associations
in other countries, imagine a situation in which each state in the
U.S. had its own state-specific standards of accounting and
auditing. Even a centralized exam administration body such as NASBA
could hardly afford to develop, administer and maintain separate
qualification examinations for each jurisdiction.
For qualification bodies to serve
their public purposes effectively, it helps to have standards that
are, well, standardized. Moreover, the immediate users of
qualification programs—such as employers of qualified professional
accountants—should have a reasonable understanding of what body of
knowledge is covered by the examination on which the qualification
is based. In an increasingly international economy, there is
decreasing justification for having to understand differences
between various country-specific sets of accounting standards and
auditing standards.
The standards covered by
qualification examinations, therefore, should be internationally
recognized. In most countries, that means the accounting standards
should be International Accounting Standards (IAS; now referred to
as International Financial Reporting Standards, or IFRS); and the
auditing standards should be International Standards of Auditing
(ISA).
From the practical perspective of
examination development, the use of international standards provides
the benefit of allowing the examining body to capitalize on the
broadest possible base of knowledge and literature. Otherwise,
examination developers must make extensive use of subjective
judgment in developing questions that address the country-specific
aspects of standards, and also in determining the correct answers to
those questions.
From the similarly practical
perspective of examination marketing and dissemination, it makes
sense to target an economically viable market of aspiring
professionals. There is a global and relatively large market of
accountants aspiring to be qualified in accordance with
international standards; in contrast, there tends to be a relatively
small market of accountants aspiring to be qualified in accordance
with the standards of any particular country.
For associations in most countries to
have a realistic hope of achieving a true professional qualification
that provides adequate coverage of these topics and complies with
other international criteria, they need to pool their political,
intellectual and monetary capital in order to implement a common
qualification examination. Any such examination must assess
capabilities and competencies in a uniform body of standards,
auditing standards, etc. Aside from the question of international
versus national standards, this is essentially what CPA societies in
the U.S. have done. All 54 licensing jurisdictions in the U.S. have
established the CPA designation, administered by NASBA, as a
requirement for licensure. And the CPA examination is required to be
qualified as a CPA.
How to address
the prevalence of country-specific standards?
Regardless of the above
considerations in support of international standards, the
unfortunate fact remains that relatively few countries have
abandoned country-specific standards. As long as local GAAP or local
GAAS does not fully comply with international standards, there will
be at least a statutory need to qualify accountants in accordance
with local standards.
Fortunately, even in countries where
local standards differ from international standards, associations
can still use the model outlined above. My personal opinion is that
an exam-based qualification program can work just fine even if it
ignores country-specific standards altogether. As discussed below,
some associations in transition economies have had significant
success with this approach.
To the degree that associations must
assess candidates’ knowledge of country-specific standards, an
initial step for them to perform is to isolate differences between
the country specific standards and the internationally recognized
standards. This task can be a laborious and contentious one. Once
the differences are isolated, however, associations have the
information needed to assess candidates’ knowledge of applicable
standards. They should do so by developing an additional examination
module that tests only those specific topics where local standards
differ from international ones. As difficult as it is to identify
and test those areas where local standards differ from international
ones, it is generally far less difficult to do so than to test all
the required subject matter outright.
Even in cases where the underlying
principles of local standards deviate greatly from international
ones, I believe that professional accounting bodies should ignore
local standards, as they are ultimately doomed to become obsolete.
Better simply to defer the statutory examination process to
state-sponsored licensing bodies or their closely controlled
associations.
In developing and transition
economies with weak associations of professional accountants, the
associations’ problems extend far beyond the technical matters of
national versus international standards. An even bigger hurdle is to
identify the potential population of professional accountants, and
to foster the demand for their services. How to do so?
Developing the
supply of professional accountants
For reasons described above,
professional accounting associations should use rigorous
examinations as the assessment tool of choice in the qualification
process. There are many reasons why it will be difficult for many
associations to take this step. For one, many candidates for
association membership will be unwilling or unable to undertake the
personal commitment needed to pass a rigorous examination—especially
one that encompasses all the subject matter required of a
professional accountant. For the many associations that had marketed
themselves to all accountants, it will be difficult to believe that
they will benefit from targeting only a small subset of that
population. One question for associations to consider is: just how
small is the population of accountants who are willing to undertake
a series of professional accounting examinations?
In some countries, particularly those
still making a transition from central planning to a market economy,
many senior managers of enterprises are not aware of just how sorely
they need the services of skilled accountants. Associations should
use their public relations skills to educate business managers in
the benefits of employing qualified association members.
In addition to fostering demand for
qualified accountants, associations should of course concentrate
their efforts on developing their supply. Unfortunately,
associations are likely to find that viable candidates for a
professional accounting qualification are few and far between.
Moreover, the near-term supply and demand are more likely to be for
accounting technicians.
The
concept of accounting technicians
Accounting technicians are “staff
engaged in technical accounting work who are directed by, and
support professional accountants.... The basic distinction between
professional and technical accounting staff roles is between
strategy and policy making on the one hand and implementation and
support on the other....”
iv In
most entities, especially medium to large ones, it is likely that
the number of “doers” will significantly exceed the number of
overseers. It is also important to note that a significant number of
doers must possess competencies far beyond the merely clerical, even
if those competencies are not of the full depth and breadth expected
of professional accountants. IFAC refers to these key individuals as
“technical accounting staff”v.
As organizations conduct their recruiting efforts and oversee the
training and development of their staff, it is very valuable for
these organizations to know which candidates for employment, as well
as actual employees, have been assessed as competent to perform as
accounting technicians.
IFAC is very careful to emphasize,
“The term ‘technical accounting staff’ does not include trainees who
are in the process of qualifying as professional accountants.” There
are various political and historical reasons—which need not
preoccupy this discussion—why IFAC does so. The fact of the matter,
however, is that if an assessment regimen that is appropriate to
qualify accounting technicians, it forms a strong foundation for
prospective professional accountants to obtain further education and
experience in order to achieve professional qualification. The
accounting technician subjects in which IFAC places the greatest
emphasis are: financial accounting (including financial statement
preparation); management accounting and control (including cost
accounting, internal controls and project evaluation); business law;
and taxation.
Which subjects to
assess by examination?
As with the qualification of
professional accountants, it is critically important that a
technically proficient and rigorously controlled examination be the
central component of the qualification of accounting technicians.
But should all subjects be assessed by examination, or may some the
assessed by other means? As a purely practical matter, the vast
scope of subject matter required of accountants means that it would
be almost impossible to assess competence in all subjects by means
of examination. My experiences suggest that it is most effective to
employ examinations to assess competence in the area of “accounting,
finance and related knowledge.” Probably this is not a very
controversial observation. As discussed above, assessing even this
one broad area is an exceedingly complex and demanding task. With
respect to “organizational and business knowledge” and “information
technology knowledge and competences,” associations should consider
other assessment techniques if they lack the resources to assess
these areas by means of examination. For example, assessment of competence
may be devolved to a local training provider, or even to the
candidate’s employer.
Using these subjects as a foundation,
an examination-focused qualification system might look something
like the following:
|
International Education
Standard Subject Areas |
Assessment method |
|
Accounting, finance and
related knowledge: |
|
|
|
Examination |
|
|
Examination |
|
|
Examination |
|
|
|
|
Examination |
|
|
Examination |
|
|
Incorporated to above exams |
|
Organizational and business
knowledge |
Devolved |
|
Information technology
knowledge and competences |
Devolved |
There are many potential variations
on this model, and there are few hard and fast international
requirements regarding which competencies must be assessed by means
of examination and which may be assessed by other means.
Train, train,
train
In countries where there is no
rigorous, comprehensive, examination-based qualification, there is
unlikely to be a dependable and adequate supply of effective and
affordable training programs to help candidates pass such exams. In
these environments, it would be ideal for associations to dedicate
extensive resources toward an intensive training-of-trainers
program. Associations would then deploy these trainers to conduct widespread and subsidized training of practitioners.
The associations would, in parallel, coordinate closely with leading
universities to improve accounting curricula as needed.
In reality, few associations will
have the resources to fulfill this ideal. Associations will need to
utilize their limited resources to support members’ access to
training. At a minimum, associations should identify a body of
self-study textbooks, and other materials if available, that cover
all the required subject matter.
An illustrative
application of this model: the Certified International Professional
Accountant examination
In countries of the Commonwealth of
Independent States, leaders of many fledgling professional
accounting associations faced these very problems, among many
others. In seeking a solution, they capitalized on the fact that
Russian is widely spoken throughout this vast region spanning 11
time zones. The qualification examinations administered by most
professional associations in this part of the world were generally
of poor quality or consistency. In many other cases, government
and/or private officials corrupted the examination component of the
qualification and licensure process.
As a result, not just employers but
even many accountants had trouble distinguishing between
qualification and licensure. The concept of professional
qualification per se generated little interest in much of the
marketplace, so even those few associations that administered
reasonably rigorous examinations, found it difficult to achieve
widespread market recognition for the resulting qualification or the
members who held it. The myriad existing certifications, in turn,
held little prestige.
Only designations offered by
associations such as the AICPA and ACCA held much influence in the
marketplace. But because these examinations are administered only in
English—and, in the case of the CPA, administered only within U.S.
territory—only a tiny corps of highly elite accountants were able
even to sit for these associations’ qualification exams. The vast
majority of potentially qualified professionals had no opportunity
to demonstrate their qualification for professional certification.
To compound matters, only a small number of large, profitable
organizations could afford to hire accountants who were both
professionally qualified and fluent in English. Therefore, most
enterprises lacked access to sound financial management skills.
Fortunately, a progressive
association in tiny Kyrgyzstan was administering a rigorous
Russian-language certification examination. Given the economic
development needs of the region, this examination focused on the
essential principles of financial accounting needed by technical
accountants. A key aspect of this examination’s success was that
sponsor associations made concerted efforts to provide affordable
and widespread training in all aspects of the subject matter
covered. The corresponding designation eventually became known as
the Certified Accounting Practitioner, or CAPvi.
This exam was gradually gaining a certain reputation for rigor and
integrity.
In Kazakhstan, a progressive
association of auditors, led by a respected and tenacious president
and several colleagues, had been engaged for years in a fierce
battle against the entrenched government interests that benefited
from a corrupt qualification process. This association decided to
embark on the even more ambitious initiative of implementing a
rigorous, comprehensive, independent professional certification
examination. This designation eventually became known as the
Certified International Professional Accountant, or CIPA.
Fundamental to both associations’
efforts was a total commitment to examination integrity, as well as
a willingness to engage advice and assistance from international
donors. Ironically, one indication of these examinations’ success
was that the corresponding certification became so valuable that
some unscrupulous accountants attempted to forge qualification
certificates or offer unprecedented bribes in hopes of
obtaining an authentic certificate.
Several associations in the
neighboring countries of Uzbekistan and Tajikistan took note of
these successful examinations, and agreed that they should join to
establish common qualification criteria. They established an
international council to document these criteria and oversee member
associations’ compliance with them. Through this entity, named the
International Council of Certified Accountants and Auditors (ICCAA),
the member associations established the CAP and CIPA examinations as
representing the common minimum examination component of their
qualification criteria. They also mandated compliance with
international requirements for education and experience. Charter
members of ICCAA consisted of seven associations from countries
of the Commonwealth of Independent States (CIS).
When ICCAA was formed, it was already
apparent to all that the administrative infrastructure required to
develop, maintain, administer and grade such an examination program
was too great to be done informally. The members of ICCAA therefore
also established a center for the development, administration,
grading and maintenance of the examinations. Within each country,
they supplemented this center by providing resources to support
these examination functions. Together, this network of examination
resources is known as the CIPA Examination Network, or CIPAEN.
ICCAA member associations agreed on
the following framework for examining the competencies of
technicians (“CAPs”) and professionals (“CIPAs):