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STATE OF MICHIGAN  
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS  
BUREAU OF PROFESSIONAL LICENSING  
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PUBLIC HEARING  
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MONDAY, APRIL 18, 2025  
AT ABOUT 9:00 A.M.  
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OTTAWA BUILDING  
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611 W. OTTAWA STREET, UL-4  
LANSING, MICHIGAN  
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RE: Accountancy -- General Rules  
(MOAHR #2024-54 LR)  
Task Force on Physicians Assistants - General Rules  
(MOAHR #2024-53 LR)  
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17 HEARING FACILITATOR:  
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WESTON MacINTOSH  
Bureau of Professional Licensing  
611 W. Ottawa Street  
Lansing, Michigan 48909  
23 REPORTED BY: Lori Anne Penn, CSR-1315  
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Penn Reporting, LLC - lori.penn@yahoo.com  
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I N D E X  
2 Opening Statement - Weston MacIntosh  
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4 COMMENTS:  
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Paul Balas -- Accountancy - General Rules  
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7 Closing Statement - Weston MacIntosh  
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Penn Reporting, LLC - lori.penn@yahoo.com  
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Lansing, Michigan  
Monday, April 18, 2025  
At 9:00 a.m.  
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(Public hearing commences pursuant to due notice.)  
MR. MacINTOSH: Good morning. My name is  
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Weston MacIntosh, and I'm a Departmental Specialist for  
the Bureau of Professional Licensing in the Department of  
Licensing and Regulatory Affairs, and I will be  
conducting the hearing today.  
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This is a public hearing on the proposed  
administrative rules titled "Accountancy - General Rules"  
and "Physicians Assistants - General Rules". We are  
conducting this hearing under the authority of the  
Administrative Procedures Act, Public Act 306 of 1969, on  
be behalf of the Department of Licensing and Regulatory  
Affairs, Bureau of Professional Licensing.  
We are calling this hearing to order at  
9:00 o'clock a.m. on April 18, 2025, in UL-4, at 611 West  
Ottawa Street, Lansing, Michigan. Publication of the  
notice of public hearing was in three newspapers of  
general circulation, including the Flint Journal on  
March 13, 2025, the Grand Rapids Press on March 13, 2025,  
the Escanaba Daily Press on March 29, 2025, as well as  
the Michigan Register, Issue #6, published on April 15,  
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2025.  
We are here today to receive your  
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comments on the proposed rules. If you wish to speak,  
please make sure you have signed in and said that you  
wish to speak. You may use the cards supplied for this  
purpose. I will organize the cards by rule set so that  
the comments for that profession are in a group together  
in the transcript. If you would like to testify and have  
not signed in, please do so now. For those of you who do  
not wish to sign in with a card, you may speak once we  
have exhausted the stack of cards that you give to me.  
If you have comments, please make sure  
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that they relate directly to the proposed rules. If you  
have questions about the rules, please include your  
questions as part of your testimony for the Department's  
review. If you have suggested changes to the proposed  
rules, please include the specific reasons why the  
changes would be in the public interest.  
For the record, when you testify, please  
give us your name by spelling your name and the  
organization, if any, that you may be speaking for today.  
This will help the Department prepare the hearing record  
that will go before the Boards. You can give written  
statements directly to me at the table. The Department  
will also accept written statements emailed or postmarked  
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until 5:00 o'clock p.m. today.  
The Department staff from the Bureau of  
Professional Licensing also includes Kerry Przybylo.  
So the first rule set that we'll take  
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comments for are the "Accountancy - General Rules". The  
first card I have for that profession is from Paul Balas.  
Go ahead.  
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MR. BALAS: Good morning. My name is  
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Paul Balas, B-a-l-a-s, and I've been a proud Michigan CPA  
for approximately 43 years. I currently serve on several  
nonprofit boards, including the executive committee and  
chairman of the audit committee for the YMCA of  
Metropolitan Detroit, treasurer of Troy People Concerned,  
a family crisis agency, and I'm an Executive in Residence  
in the business school at Michigan State University.  
While I serve in these different capacities, the comments  
today are personal comments and my own views.  
I'm here to express my strong opposition  
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to the proposed removal the 24-hour general business  
course requirement from the definition of "Accounting  
Concentration" in the Michigan "Accountancy - General  
Rules".  
Prior to my retirement from  
PriceWaterhouseCoopers, I was most recently responsible  
for global audit quality and global regulator  
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relationships for PriceWaterhouseCoopers firms. The  
first thing my team did when we identified audit quality  
matters was try and determine the root cause of the  
problem: How did it happen? How was the issue missed?  
What did the client or the auditor not get right? As we  
evaluated the conditions present when there was a  
negative event, one of the factors we considered was the  
competency and educational background of the partners and  
staff assigned to the engagement.  
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As I look at the current proposed change  
to the rules, which effectively reduces the required  
business education hours by 50%, I'm deeply concerned  
that we are lowering the standards to a level that will  
cause the next generation of Michigan CPAs to lack the  
necessary qualifications to properly understand and  
assess the complex business transactions that are  
currently being undertaken in the marketplace. We are  
sending the message that a broad-based business education  
is not important, while I believe a well-rounded business  
education is imperative for a certified public  
accountant. While technical accounting knowledge is  
important, the complexity of today's business environment  
demands a broader base of business knowledge to enable  
the CPA to understand the substance of activities and  
transactions that are subject to bookkeeping, auditing,  
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and tax treatments. Areas such as business law, ethics,  
and economics are foundational to the role of the CPA.  
The regulatory impact statement included  
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comments relating to comparisons to other states in the  
U.S. and the Great Lakes states. Currently only seven  
states or jurisdictions do not have a general education  
credit requirement, while the impact statement says that  
we are similar to all states around the U.S. In  
addition, the impact statement indicates that we are  
similar to Great Lakes states, while in truth all states  
near Michigan, including Indiana, Ohio, Wisconsin,  
Illinois, and Minnesota, have a general business  
requirement that is similar to the current requirement in  
the State of Michigan. In addition, Ohio just completed  
a full review of their CPA requirements which included  
alternative paths to licensure, but notably retained the  
general education credit requirements.  
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I believe we will be doing a disservice  
to students studying in the State of Michigan if their  
early post-graduation personal or professional lives  
resulted in a need to become licensed in a state that had  
a general business credit requirement. They may not  
qualify for licensure due to reciprocity rules. They may  
not meet the education requirements of that state. In my  
role at Michigan State University, I consult with  
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students that are looking ultimately to move to Chicago  
and New York on a regular basis, and both those states  
have significant requirements that are in excess of what  
this rule would provide for Michigan.  
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In addition, there are several areas  
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where the Accountancy rules and statutes may be changing  
in the near term. It is likely that the State of  
Michigan will be reconsidering overall education  
requirements with a focus on a the current requirement of  
150 credit hours.  
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In addition, the Michigan Department of  
Licensing and Regulation recently published a cutting red  
tape report which includes several items relating to  
Accountancy rules and statutes. Many of these appear to  
have merit, but should be subject to further discussion  
and consideration, including input from the Board of  
Accountancy and the public. I believe the proposed rule  
change should be deferred until any changes to the  
education requirements, as well as the items included in  
the cutting red tape report, can be considered in  
totality.  
The Accountancy Board's primary role is  
to protect the public interest. Lowering the education  
requirements for CPAs, in my view, would not benefit the  
public, nor serve to increase public trust in the  
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accounting profession. Thank you very much.  
MR. MacINTOSH: Thank you, Paul.  
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Is there anyone else who wishes to speak  
on the "Accountancy - General Rules"? (No response.)  
Hearing none. The second rule set that  
we'll take comments for are the "Physicians Assistants -  
General Rules". Is there anyone who wishes to speak on  
the "Physicians Assistants - General Rules"? (No  
response.)  
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Hearing none.  
If there are no other people who wish to  
speak at this time, we'll take a short recess.  
(Recess from 9:07 a.m. until 9:25 a.m.)  
MR. MacINTOSH: Okay. We're back on the  
record. One last time, is there anyone who wishes to  
speak on the "Accountancy - General Rules"? (No  
response.)  
Hearing none. Is there anyone who wishes  
to speak on the "Physicians Assistants - General Rules"?  
(No response.)  
Hearing none.  
If there are no further comments at this  
time, I hereby declare the hearing closed. The record  
will remain open until today at 5:00 o'clock p.m. for any  
other comments you may wish to share about the proposed  
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rules. Thank you for coming.  
(Public hearing concluded at 9:26 a.m.)  
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1 STATE OF MICHIGAN )  
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2 COUNTY OF MACOMB )  
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I, Lori Anne Penn, certify that this  
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transcript consisting of 11 pages is a complete, true,  
and correct record of the proceedings held in the  
captioned matters on Monday, April 18, 2025.  
I further certify that I am not  
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responsible for any copies of this transcript not made  
under my direction or control and bearing my original  
signature.  
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I also certify that I am not a relative  
or employee of or an attorney for a party; or a relative  
or employee of an attorney for a party; or financially  
interested in the action.  
April 23, 2025  
_________________ ____  
Date  
Lo
Noan  
My Commission Expires June 15, 2025  
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