Michigan Office of Administrative Hearings and Rules  
Administrative Rules Division (ARD)  
MOAHR-Rules@michigan.gov  
REGULATORY IMPACT STATEMENT  
and COST-BENEFIT ANALYSIS (RIS)  
AGENCY INFORMATION:  
Department name:  
Licensing and Regulatory Affairs  
Bureau name:  
Bureau of Professional Licensing  
Name of person filling out RIS:  
Weston MacIntosh  
Phone number of person filling out RIS:  
517-241-9269  
Email of person filling out RIS:  
MacIntoshW1@michigan.gov  
RULE SET INFORMATION:  
ARD assigned rule set number:  
2024-54 LR  
Title of proposed rule set:  
Accountancy – General Rules  
COMPARISON OF RULE(S) TO FEDERAL/STATE/ASSOCIATION STANDARDS  
1. Compare the proposed rules to parallel federal rules or standards set by a state or national licensing agency  
or accreditation association, if any exist.  
There are no parallel federal rules or standards set by a state or national licensing agency or accreditation  
association.  
A. Are these rules required by state law or federal mandate?  
Under MCL 339.205, the department shall promulgate rules to implement articles 1 to 6 and rules which are  
necessary and appropriate to enable the department to fulfill its role under this act.  
Under MCL 339.308, a board shall promulgate rules as required in the article in which it is created as are  
necessary and appropriate to fulfill its role and a board may promulgate rules to set the minimal standards of  
acceptable practice for an occupation for which the board is created.  
Under MCL 339.729, each licensed firm and sole practitioner that performs audit, review, and compilations that  
are relied upon by third parties shall participate in a peer review program established by rule of the department  
and approved by the board.  
No federal mandate demands the rules.  
B. If these rules exceed a federal standard, please identify the federal standard or citation, describe why it  
is necessary that the proposed rules exceed the federal standard or law, and specify the costs and  
benefits arising out of the deviation.  
The rules do not exceed a federal standard or law.  
2. Compare the proposed rules to standards in similarly situated states, based on geographic location,  
topography, natural resources, commonalities, or economic similarities.  
MCL 24.245(3)  
RIS-Page 2  
The proposed rules are like accountancy standards in the other Great Lake states, as well as other states throughout  
the United States. According to the National Association of State Boards of Accountancy’s National Qualification  
Appraisal Service, all United States jurisdictions have requirements that are substantially equivalent to the licensure  
requirements of the Uniform Accountancy Act (https://nasba.org/licensure/substantialequivalency/). Although the  
state does not have to have rule requirements that are consistent with the Uniform Accountancy Act, but must instead  
be consistent with state law, which they are, it is useful to note for comparison’s sake that the rules follow state law  
and are also similar to the requirements of surrounding states.  
A. If the rules exceed standards in those states, please explain why and specify the costs and benefits  
arising out of the deviation.  
Statute demands promulgation of rules related to licensure. The rules do not exceed the licensing requirements  
of other states.  
3. Identify any laws, rules, and other legal requirements that may duplicate, overlap, or conflict with the  
proposed rules.  
There are no federal regulations for licensing of certified public accountants. There are no laws, rules, or other legal  
requirements that duplicate, overlap, or conflict with the proposed rules.  
A. Explain how the rules have been coordinated, to the extent practicable, with other federal, state, and  
local laws applicable to the same activity or subject matter. This section should include a discussion of  
the efforts undertaken by the agency to avoid or minimize duplication.  
Review of applicable statutory law avoided unnecessary duplication in the rules. There are no other federal or  
local laws applicable to this activity.  
PURPOSE AND OBJECTIVES OF THE RULE(S)  
4. Identify the behavior and frequency of behavior that the proposed rules are designed to alter.  
The specific topics that the proposed rules address, and the purpose of the proposed rules are set forth below:  
R 338.5102: This rule pertains to standards of professional practice adopted by reference. The proposed revised rule  
uses the most current standards published and supplies the cost for obtaining copies of the adopted standards.  
R 338.5115: This rule pertains to qualifying educational requirements, approved educational institutions, and adoption  
of accreditation standards. The proposed revised rule clarifies the coursework requirements for a concentration in  
accounting.  
R 338.5116: This rule pertains to educational requirements for a CPA certificate. The proposed revised rule clarifies  
the coursework requirements for a concentration in accounting.  
A. Estimate the change in the frequency of the targeted behavior expected from the proposed rules.  
Promulgation of rules related to licensure is necessary under statute. This supplies a regulatory framework for  
the practice of certified public accountants. The proposed changes supply greater clarity to licensees and aid in  
understanding the requirements of the rules.  
B. Describe the difference between current behavior/practice and desired behavior/practice.  
Statute regulates the practice of certified public accountants. This mandates licensure for provision of those  
services. Adding clarifications on points that may have been ambiguous under prior rules will make compliance  
easier for applicants and licensees.  
C. What is the desired outcome?  
Regulation is necessary for individuals who wish to practice as certified public accountants. By improving and  
clarifying the rules, applicants and licensees should find compliance easier. This should result in fewer  
questions, fewer regulatory problems, and greater safety and protection of the public.  
5. Identify the harm resulting from the behavior that the proposed rules are designed to alter and the likelihood  
that the harm will occur in the absence of the rule.  
Outdated rules create conflict and confusion for certified public accountants. The proposed rules update previously  
adopted rules. Changes made specifically address the following:  
R 338.5102 pertains to standards of professional practice adopted by reference. The rule revision ensures licensees  
MCL 24.245(3)  
RIS-Page 3  
follow the most up-to-date standards.  
R 338.5115 pertains to qualifying educational requirements, approved educational institutions, and adoption of  
accreditation standards. The rule revision ensures applicants follow the coursework requirements for a concentration  
in accounting.  
R 338.5116 pertains to educational requirements for a CPA certificate. The rule revision ensures applicants follow the  
coursework requirements for a concentration in accounting.  
A. What is the rationale for changing the rules instead of leaving them as currently written?  
The proposed rule set provides clarity to all rules on licensure.  
6. Describe how the proposed rules protect the health, safety, and welfare of Michigan citizens while promoting  
a regulatory environment in Michigan that is the least burdensome alternative for those required to comply.  
The proposed rules supply a regulatory mechanism for the practice of certified public accountants. To protect the  
health, safety, and welfare of Michigan’s citizens, it is important that members of the profession adhere to educational  
and professional standards. The rules ensure that applicants receive proper education and training prior to licensure  
and that licensees are competent to practice. There is no less burdensome way to ensure that applicants and  
licensees satisfy minimum requirements for practice.  
7. Describe any rules in the affected rule set that are obsolete or unnecessary and can be rescinded.  
No rescission of any rules is necessary.  
FISCAL IMPACT ON THE AGENCY  
Fiscal impact is an increase or decrease in expenditures from the current level of expenditures, i.e., hiring  
additional staff, higher contract costs, programming costs, changes in reimbursements rates, etc. over and  
above what is currently expended for that function. It does not include more intangible costs for benefits, such  
as opportunity costs, the value of time saved or lost, etc., unless those issues result in a measurable impact on  
expenditures.  
8. Please provide the fiscal impact on the agency (an estimate of the cost of rule imposition or potential savings  
for the agency promulgating the rule).  
There is no expected fiscal impact on the agency for promulgating the proposed rules.  
9. Describe whether or not an agency appropriation has been made or a funding source provided for any  
expenditures associated with the proposed rules.  
There has been no agency appropriation for the proposed rules because there are no expected agency expenditures  
associated with the proposed rules.  
10. Describe how the proposed rules are necessary and suitable to accomplish their purpose, in relationship to  
the burden(s) the rules place on individuals. Burdens may include fiscal or administrative burdens, or  
duplicative acts.  
The proposed rules supply a mechanism for the licensing and regulation of individuals in this state, as mandated by  
statute. Applicants and licensees will continue to have a cost related burden associated with licensing, renewal, or  
relicensure. The cost of licensure for a licensed certified public accountant is $300.00. The cost of relicensure for a  
licensed certified public accountant is $320.00. The cost of renewal of licensure for a licensed certified public  
accountant is $200.00.  
A. Despite the identified burden(s), identify how the requirements in the rules are still needed and  
reasonable compared to the burdens.  
The rules are necessary to supply a mechanism for licensing and regulation of the profession. The rules are  
not more restrictive than allowed by statute. Despite the cost related burden of licensing, the rules and  
regulations are necessary to supply a framework of standards for educational and licensure requirements.  
IMPACT ON OTHER STATE OR LOCAL GOVERNMENTAL UNITS  
MCL 24.245(3)  
RIS-Page 4  
11. Estimate any increase or decrease in revenues to other state or local governmental units (i.e., cities,  
counties, school districts) as a result of the rule. Estimate the cost increases or reductions for other state or  
local governmental units (i.e., cities, counties, school districts) as a result of the rule. Include the cost of  
equipment, supplies, labor, and increased administrative costs in both the initial imposition of the rule and  
any ongoing monitoring.  
There is no expected increase or decrease in revenues to other state or local government units, nor are there cost  
increases or reductions on other state or local government units expected because of the proposed rules.  
12. Discuss any program, service, duty, or responsibility imposed upon any city, county, town, village, or school  
district by the rules.  
The proposed rules do not impose any program, service, duty, or responsibility upon any city, county, town, village, or  
school district.  
A. Describe any actions that governmental units must take to be in compliance with the rules. This section  
should include items such as record keeping and reporting requirements or changing operational  
practices.  
No action is necessary for governmental units to follow the rule(s).  
13. Describe whether or not an appropriation to state or local governmental units has been made or a funding  
source provided for any additional expenditures associated with the proposed rules.  
State and local government units will incur no added expenditures because of implementing the proposed rules.  
Therefore, no appropriation or funding source is necessary.  
RURAL IMPACT  
14. In general, what impact will the rules have on rural areas?  
There is no expected disparate impact on rural areas because of the proposed rules.  
A. Describe the types of public or private interests in rural areas that will be affected by the rules.  
There is no expected disparate impact on public or private interests in rural areas because of the proposed  
rules.  
ENVIRONMENTAL IMPACT  
15. Do the proposed rules have any impact on the environment? If yes, please explain.  
No, the proposed rules will have no impact on the environment.  
SMALL BUSINESS IMPACT STATEMENT  
16. Describe whether and how the agency considered exempting small businesses from the proposed rules.  
The Michigan Occupational Code authorizes the board and the department to regulate individuals with certified public  
accountant licenses, not small businesses. Even if a licensee’s practice qualified as a small business, the department  
could not exempt the licensee’s small business because it would create disparity in the regulation of the profession.  
17. If small businesses are not exempt, describe (a) the manner in which the agency reduced the economic  
impact of the proposed rules on small businesses, including a detailed recitation of the efforts of the agency  
to comply with the mandate to reduce the disproportionate impact of the rules upon small businesses as  
described below (in accordance with MCL 24.240(1)(a-d)), or (b) the reasons such a reduction was not lawful  
or feasible.  
There is no expected economic impact on small businesses because of the proposed rules. The proposed rules  
affect individual licensees rather than small businesses.  
A. Identify and estimate the number of small businesses affected by the proposed rules and the probable  
effect on small businesses.  
The department does not collect or have access to information that would allow it to find and estimate the  
potentially affected number of small businesses. It is impossible to estimate the number of small businesses  
affected by the proposed rules. The only small businesses affected by these rules are practitioners practicing in  
MCL 24.245(3)  
RIS-Page 5  
small business settings. The department does not track or have access to this type of information since it is not  
a data repository. The probable impact on small business is small.  
B. Describe how the agency established differing compliance or reporting requirements or timetables for  
small businesses under the rules after projecting the required reporting, record-keeping, and other  
administrative costs.  
Because the proposed rules pertain to individuals and not small businesses, they do not have differing  
compliance or reporting requirements or timetables for small businesses. They are unnecessary for the  
proposed rules.  
C. Describe how the agency consolidated or simplified the compliance and reporting requirements for  
small businesses and identify the skills necessary to comply with the reporting requirements.  
The proposed rules do not impose any compliance requirements or reporting requirements for small  
businesses.  
D. Describe how the agency established performance standards to replace design or operation standards  
required by the proposed rules.  
The agency did not set up performance standards to replace design or operation standards.  
18. Identify any disproportionate impact the proposed rules may have on small businesses because of their size  
or geographic location.  
The proposed rules affect individual licensees rather than small businesses. Therefore, there is no expected  
disproportionate impact on small businesses based on size or geographic location because of the rules.  
19. Identify the nature of any report and the estimated cost of its preparation by small businesses required to  
comply with the proposed rules.  
The proposed rules do not require any reports. There are no reports that a small business would have to complete.  
20. Analyze the costs of compliance for all small businesses affected by the proposed rules, including costs of  
equipment, supplies, labor, and increased administrative costs.  
There is no expectation of an effect on small businesses because of the proposed rules, nor are there any added  
costs, because the proposed rules apply to individuals and not businesses.  
21. Identify the nature and estimated cost of any legal, consulting, or accounting services that small businesses  
would incur in complying with the proposed rules.  
The proposed rules, which apply to individuals and not businesses, should not create a need for any legal, consulting,  
or accounting services for small businesses to be able to follow the proposed rules.  
22. Estimate the ability of small businesses to absorb the costs without suffering economic harm and without  
adversely affecting competition in the marketplace.  
Since the rules affect individual licensees rather than small businesses, there is no expected cause of economic harm  
or for the rules to adversely affect competition in the marketplace.  
23. Estimate the cost, if any, to the agency of administering or enforcing a rule that exempts or sets lesser  
standards for compliance by small businesses.  
The proposed rules impose requirements on individual licensees rather than small businesses. Even if a licensee’s  
practice qualifies as a small business, the department could not exempt the licensee’s small business because it  
would create disparity in regulation of the profession. Therefore, exempting or setting lesser standards of  
competence for small businesses is not in the best interest of the public. It would likely cost the agency more to  
devote staff time to determining which licensees work for small businesses and then enforce different requirements for  
those individuals.  
24. Identify the impact on the public interest of exempting or setting lesser standards of compliance for small  
businesses.  
The department is not able to exempt licensees that own a small business. If the department exempted small  
businesses, it would create a disparity in the regulation of a profession and have a negative impact on public safety.  
25. Describe whether and how the agency has involved small businesses in the development of the proposed  
rules.  
The department worked with the Michigan Board of Accountancy in the development of the proposed rules. The board  
is composed of professional and public members. Some members of the board may work in a small business, but the  
members were not involved in the development of the rules as representatives of small businesses.  
A. If small businesses were involved in the development of the rules, please identify the business(es).  
MCL 24.245(3)  
RIS-Page 6  
No small businesses took part in the development of the rules.  
COST-BENEFIT ANALYSIS OF RULES (INDEPENDENT OF STATUTORY IMPACT)  
26. Estimate the actual statewide compliance costs of the rule amendments on businesses or groups.  
There are no estimated compliance costs with these rule amendments on businesses or groups.  
A. Identify the businesses or groups who will be directly affected by, bear the cost of, or directly benefit  
from the proposed rules.  
The proposed rules directly affect licensees. Licensees bear the cost of and directly benefit from the proposed  
rules.  
B. What additional costs will be imposed on businesses and other groups as a result of these proposed  
rules (i.e., new equipment, supplies, labor, accounting, or recordkeeping)? Please identify the types and  
number of businesses and groups. Be sure to quantify how each entity will be affected.  
There will be no expected added costs imposed upon licensees because of compliance with these proposed  
rules.  
27. Estimate the actual statewide compliance costs of the proposed rules on individuals (regulated individuals or  
the public). Include the costs of education, training, application fees, examination fees, license fees, new  
equipment, supplies, labor, accounting, or recordkeeping.  
Applicants and licensees will continue to have a cost related burden associated with licensing, renewal, or relicensure.  
The cost of licensure for a licensed certified public accountant is $300.00. The cost of relicensure for a licensed  
certified public accountant is $320.00. The cost of renewal of licensure for a licensed certified public accountant is  
$200.00.  
Currently there are approximately 13,458 licensed certified public accountants. If all 13,458 licensed certified public  
accountants continue to renew their licenses the estimated actual statewide compliance cost would be (13,458 X  
$200.00) = $2,691,600.00.  
A. How many and what category of individuals will be affected by the rules?  
There are approximately 13,458 licensed certified public accountants. The rules affect all individuals who seek  
licensure as certified public accountants.  
B. What qualitative and quantitative impact do the proposed changes in rules have on these individuals?  
The qualitative impact of the proposed rules on the citizens of Michigan will be that they will know a licensee  
who supplies services has achieved the level of education and training necessary to meet the minimum  
requirements for licensure. The quantitative impact of the proposed rules on the citizens of Michigan is that  
there will be no increase in the cost of services due to the rule amendments. The proposed rule amendments  
help to ensure the health, safety, and welfare of Michigan citizens without more costs.  
The qualitative impact on licensees and applicants by the proposed rules will be the knowledge that they and  
their peers have achieved the minimum requirements for licensure and can appropriately support the needs of  
the citizens of Michigan. The quantitative impact on licensees and applicants by the proposed rules is that they  
will have credentials that will meet the minimum requirements of licensure. These credentials will allow them to  
have access to job opportunities and compensation in line with their education and work experience.  
28. Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units as a  
result of the proposed rules.  
There are no expected reductions in costs to businesses, individuals, groups of individuals, or governmental units  
because of the proposed rules.  
29. Estimate the primary and direct benefits and any secondary or indirect benefits of the proposed rules. Please  
provide both quantitative and qualitative information, as well as any assumptions.  
The proposed rules use clear, concise language, and implement the statutory requirements for licensing. The clear,  
concise language allows the public, licensees, and schools to better understand the requirements for licensure.  
30. Explain how the proposed rules will impact business growth and job creation (or elimination) in Michigan.  
There is no expected significant impact on business growth, job growth, or job elimination because of the rules.  
MCL 24.245(3)  
RIS-Page 7  
31. Identify any individuals or businesses who will be disproportionately affected by the rules as a result of their  
industrial sector, segment of the public, business size, or geographic location.  
The department does not expect any disproportionate effect on any individuals or businesses by their industrial  
sector, segment of the public, business size, or geographical location.  
32. Identify the sources the agency relied upon in compiling the regulatory impact statement, including the  
methodology utilized in determining the existence and extent of the impact of the proposed rules and a cost-  
benefit analysis of the proposed rules.  
National Association of State Boards of Accountancy (NASBA)  
https://nasba.org/  
Illinois  
https://www.ilboe.org/  
Indiana  
https://www.in.gov/pla/professions/accountancy-home/  
Minnesota  
http://www.boa.state.mn.us/  
New York  
https://www.op.nysed.gov/certified-public-accountants  
Ohio  
https://acc.ohio.gov/  
Pennsylvania  
https://www.pa.gov/agencies/dos/department-and-offices/bpoa/boards-commissions/accountancy-board.html  
Wisconsin  
https://dsps.wi.gov/Pages/Professions/Accountant/Default.aspx  
A. How were estimates made, and what assumptions were made? Include internal and external sources,  
published reports, information provided by associations or organizations, etc., that demonstrate a need  
for the proposed rules.  
Since statute mandates the rules, no estimate was necessary.  
ALTERNATIVE TO REGULATION  
33. Identify any reasonable alternatives to the proposed rules that would achieve the same or similar goals.  
Since statute mandates the rules, there are no reasonable alternatives to the proposed rules.  
A. Please include any statutory amendments that may be necessary to achieve such alternatives.  
Since statute mandates the rules, there are no reasonable alternatives to the proposed rules.  
34. Discuss the feasibility of establishing a regulatory program similar to that proposed in the rules that would  
operate through private market-based mechanisms. Please include a discussion of private market-based  
systems utilized by other states.  
Since statute mandates the rules, private market-based systems cannot serve as an alternative. The licensing and  
regulation of certified public accountants are state functions, so a regulatory program independent of state  
intervention cannot be set up. One could consider certified public accountant professional associations as regulatory  
mechanisms that are independent of state intervention; however, these professional organizations would provide the  
public with significantly less protection because membership in these organizations is voluntary. This means an  
individual who meets the membership requirements, but does not join, would still be able to practice and there would  
be no way to ensure the individual’s competency or hold the individual accountable for harm done to clients.  
No other states in the Great Lakes region use a private, market-based system to regulate licensed certified public  
accountants.  
MCL 24.245(3)  
RIS-Page 8  
35. Discuss all significant alternatives the agency considered during rule development and why they were not  
incorporated into the rules. This section should include ideas considered both during internal discussions  
and discussions with stakeholders, affected parties, or advisory groups.  
Since statute mandates the rules, there are no reasonable alternatives to the proposed rules. There were no  
alternatives that the department considered to achieve the intended changes. They are necessary for the  
administration and enforcement of the licensing process.  
ADDITIONAL INFORMATION  
36. As required by MCL 24.245b(1)(c), please describe any instructions regarding the method of complying with  
the rules, if applicable.  
The rules include the instructions for compliance.  
MCL 24.245(3)  
;