Dr. HERBERT. That is right. Mr. FRASER. To that extent, you would be ahead of other Gov ernment agencies' work in any event. No matter how the Boar might look at their work, under this section there would still be 11⁄2-to-1 ratio. Dr. HERBERT. That is right. In other words, GAO experienc would be comparable to the public accounting experience on a 1-forbasis. The other Government agencies as I said before, many o them do excellent jobs and we recognize that-would be on a 11⁄2-tobasis. Mr. FRASER. Is there any reason to believe the Board of Account tancy tends to fail to take a fairly reasonable view of these matters Dr. HERBERT. Yes. It is also interpretation. I will give you specific illustration. The law in Ohio specifically recognized Gov ernment experience. They recognize GAO experience without an question. The board changed when I was out there last year. Th board said, "We are a new board. We can interpret this law the wat we feel it should be interpreted." They cut out GAO experience We had to go back and completely build the case all over again fo GAO in Ohio. Mr. FRASER. That is Ohio. I was thinking of the District Columbia where they are much more familiar with what the GA is. I am sure they did not know as much about GAO in Ohio. Dr. HERBERT. That was the problem. Mr. FRASER. I was thinking of your experience with the Board o Accountancy. Dr. HERBERT. We have had none. In other words, our experienc does not count at all in the District of Columbia. Mr. FRASER. Under the present law? Dr. HERBERT. That is right. Mr. FRASER. So, whatever is in the bill is a liberalization. Mr. FRASER. Now the question is, "How much liberalization?" The Congress, when creating the General Accounting Office in 192 and designating its responsibilities, assured its independence and freedom of action by making it a part of the legislative branch and requiring it to report and be responsible to the Congress. Also, the Comptroller General and the General Accounting Office, under the responsibilities assigned by the Congress, are the principal adviser of the Congress on accounting and auditing matters. To adequately discharge these tremendously important responsibilities requires staff of highly competent professional accountants and auditors who are capable of dealing with an almost limitless range of accounting and problems. This high degree of professional competence is particularly required in Washington where our day-to-day contact: with Members of the Congress and committee staff members usually occur. The demonstrated professional quality of the accounting and audit ing work of the General Accounting Office staff is the basis for the acceptance of that work by the Congress, its committees, and its Members. We believe that recognition of that work both by the Congress and by jurisdictional regulatory agencies is essential to maintaining the quality and high level of performance required to discharge the accounting and auditing responsibilities of our Office. At the present time, the laws of 37 States allow our professional staff members to obtain their CPA certificates either through experience, education, or a combination of education and experience. A number of the States which require experience recognize the professional nature of our work and have decided that General Accounting Office experience meets eligiblity standards required for the CPA certificate. Many of our professional staff have obtained their CPA certificates on the basis of General Accounting Office experience. Three hundred and ninety-one members of our staff are holders of the CPA certificate, and 61 others who have passed the required examination will receive their certificates upon completion of their experience requirement. We believe that all of the various jurisdictions should recognize the experience of our staff members as qualifying for the CPA certificate. However, the present law of the District of Columbia does not. We feel strongly that recognition of our experience is especially important in the District of Columbia in which our headquarters office is located and to which a little more than one-third of our professional staff is assigned. To make the current bill more specific as to recognizing experience of General Accounting Office accountants and auditors for the CPA certificate of the District of Columbia, we recommend that substantially the following language be added to H.R. 7624 on page 8, line 16; page 9, line 18; page 10, line 18; and page 11, line 17: *** or in the full-time employment as an accountant or auditor of the U.S. General Accounting Office. Subsection 7(c) also refers to experience in auditing the books and accounts of other persons in three or more distinct lines of commercial business in accordance with generally accepted auditing standards. To remove any doubt that the term "commercial business" includes governmental activities, we recommend that the term "commercial or governmental activities" be substituted therefor or that the committee report on the bill specifically state that the term "commercial business" is intended to include governmental activities. It is a well-established principle that ultimate responsibility should be placed in the head of an organization with a clear and direct line of responsibility, command, and supervision down through the heads of at the suborganizational units to every employee. We endorse this principle and believe that the authority to regulate the practice of te certified public accountants in the District of Columbia should be vested in the Commissioners of the District of Columbia by authority te granted by Congress specifically to them. It seems to us, however, s that to restrict the Commissioners' authority to act only "upon unanimous recommendation of the Board of Accountancy" as proand vided in subsection 7(c) of the bill is entirely inconsistent with this is principle. We therefore feel very strongly that either the phrase cts upon unanimous recommendation of the Board of Accountancy" ally should be deleted in its entirety, or at least that the word "unanimous" be deleted. fit Subsections 7 (a) and (b) specify not less than 30 semester hours in the accounting theory and practice, auditing, and commercial law as its required accounting education. We understand that many of the the well-recognized universities do not require that many semester hours to of accounting and related subjects for a major in accounting. Accordto ingly, this provision would mean that many college or university graduates with majors in accounting would have to take addition: courses in order to qualify as a certified public accountant in th District of Columbia. For this reason, only 24 semester hours accounting subjects is required for employment of profession: accountants in the Federal service. In fact, the trend today in th universities and colleges for an undergraduate degree with a maj in accounting is to require less semester hours of accounting and mo hours of academic courses. The committee on relations with univers ties of the American Institute of Certified Public Accountants sugge only a major in accounting as the minimum educational requiremen for the CPA certificate. The form of regulatory public accountan bill developed by the committee on State legislation, American Inst tute of Certified Public Accountants, as a guide to State societi planning such legislation, merely requires "a baccalaureate degr conferred by a college or university recognized by the Board, with major in accounting, or what the Board determines to be substantial the equivalent of the foregoing; or with a nonaccounting majo supplemented by what the Board determines to be substantially th equivalent of an accounting major, including related courses in oth areas of business administration." Subject to the foregoing comments, we favor H.R. 7624 and recor mend its enactment. Mr. ABERNETHY. Thank you very much, Doctor. Mr. SICKLES. Just one short question. I know we have the U.S. General Accounting Office. Are the comparable State accounting offices where you might have the san kind of individuals doing the same kinds of things? Dr. HERBERT. There would be none in the District of Columbi There are in other States. For example, I am from Louisiana, a I was the supervisor of public funds, which is basically the same ide Mr. SICKLES. It is part of the legislature rather than part of t executive? Dr. HERBERT. No. California has that. This was a part of t executive. They put it in the auditor's office, an elected official, get it out of the Governor's office. Mr. SICKLES. If anyone were to seek to take the examination the District of Columbia, he might want to include experience n confined just to the District of Columbia. He might have come fro California or Louisiana. Dr. HERBERT. I believe section 7(c) would take care of the situation. It would be 12 to 1 on that basis. Mr. SICKLES. Thank you. Mr. FRASER. Could I reiterate the chairman's suggestion? We shall now hear from the Corporation Counsel's Office, M Moyer. At this point I would like to insert in the record a letter to Chairma McMillan from the Commissioners under date of October 8, 1965, an call attention to the fact that the Commissioners ask that action the legislation be suspended until a time when it could get a recon mended bill before the committee. I think that is a correct interpr tation of the letter. Also their letter to the Speaker of the Hous under date of January 17, 1966, to which the Commissioners attach and recommend the enactment of substitute legislation. Is that right? Mr. MOYER. That is correct, Mr. Chairman. Mr. ABERNETHY. I am not trying to testify for you, but as I understand it, the Commissioners desire to have general legislation enabling them to regulate and require the registration and the administration of all professions within the District under one act. Mr. MOYER. That is correct. (The letters referred to follow :) GOVERNMENT OF THE DISTRICT OF COLUMBIA, Hon. JOHN L. MCMILLAN, Chairman, Committee on the District of Columbia, U.S. House of Representatives, Washington, D.C. EXECUTIVE OFFICES, Washington, October 8, 1965. DEAR MR. MCMILLAN: The Commissioners of the District of Columbia have for report H.R. 7624, 89th Congress, a bill to provide for regulation of the professional practice of certified public accountants in the District of Columbia, including the examination, licensure, registration of certified public accountants, and for other purposes. The Commissioners are informed that the primary purposes of the bill are (1) to establish residence requirements for the taking of the examination for certified public accountant in the District of Columbia; (2) to raise the education and experience requirements for eligibility to take such examination; (3) to provide for the recognition of accounting experience gained in self-employment or with the Government; (4) to provide for the certification of a certified public accountant in the District of Columbia by endorsement of his certificate from another jurisdiction; (5) to provide for the biennial registration of practicing certified public accountants; and (6) to provide for the licensing in the District of Columbia of partnerships of certified public accountants where the partners who reside in the District of Columbia are certified in this jurisdiction and the other partners are certified in some State. Although the Commissioners are in accord with these primary purposes of the bill, they question the desirability of enacting a statute of this nature to accomplish these purposes. The presently existing act regulating the practice of certified public accountants in the District of Columbia, which would be replaced by the bill, is one of a series of acts passed and amended by the Congress from time to time regulating a number of occupations and professions in the District of Columbia. Each of the professions of physician, registered nurse, practical nurse, dentist, optometrist, pharmacist, podiatrist, physical therapist, veterinarian, engineer, and architect is also regulated under a separate statute as are the occupations of barber, boxer, cosmetologist, plumber, and steam engineer. All of these statutes to some degree establish qualifications for licensing to practice the in occupation or profession, provide various grounds and procedures for suspension or revocation of a license, and establish fees to be charged for various services rendered by the District of Columbia in connection with licensing. The Commissioners believe that, rather than to amend or to replace from time to time the statutes which relate to the licensing of these occupations and professions, a much more desirable approach to the problem would be to supplement such statutes with a general act authorizing the Commissioners, by regulation, to change, from time to time, the qualifications for licensing certain specified professions and occupations in the District of Columbia; to prescribe the grounds for the suspension or revocation of licenses to practice the several professions or to engage in the various occupations; and to establish administrative procedures under which licenses are granted, denied, suspended, or revoked. This would give the Commissioners authority to deal with these matters and to change the requiremments from time to time as the public interest might indicate are needed, making all it unnecessary to seek frequent changes in the legislation enacted by Congress. In addition, such a statute could authorize the Commissioners to fix, and change from time to time, the fees determined by them to be necessary to administer the licensing and regulation of the various professions and occupations. The promulpre gation by the Commissioners of regulations or changes relating to qualifications, to Use CERTIFIED PUBLIC ACCOUNTANTS to fees, and to grounds for suspension or revocation would be subject to the hold of a public hearing to afford the members of the profession or occupation and general public an opportunity to express their views on the desirability of s regulation or amendment. In no case would a Commssioners' regulation lo qualifications required by an act of Congress in order to be licensed in a profess or occupation. Legislation to accomplish the foregoing is presently pending in the Bureau of of the Budget. Should this proposed legislation be enacted, it will be poss for the Commissioners to revise and modernize not only the act providing for certification of public accountants, but also the acts of Congress relating to licensing, registration, or certification of some 20 other professions, occupatio trades, and callings. In view of this possibility, the Commissioners recomm that further action on the bill be held in abeyance pending the submission by Commissioners, to the Congress of legislation of broader application. Sincerely yours, WALTER N. TOBRINER President, Board of Commissioners, District of Columbia GOVERNMENT OF THE DISTRICT OF COLUMBIA, The Honorable the SPEAKER, EXECUTIVE OFFICES, Washington, Janaury 17, 1964 MY DEAR MR. SPEAKER: The Commissioners of the District of Columbia h the honor to submit a draft bill to revise and modernize procedures relating the licensing by the District of Columbia of persons engaged in certain occupatio professions, business, trades, and callings, and for other purposes. Physicians, dentists, dental hygienists, nurses, practical nurses, phys therapists, optometrists, pharmacists, podiatrists, veterinarians, certified pu accountants, architects, barbers, persons participating in boxing contests, metologists, plumbers and gas fitters, steam engineers, professional engine real estate and business chance brokers and salesmen, undertakers, and electr and refrigeration and air-conditioning contractors are licensed, registered, certified, as the case may be, under the authority of 20 acts of Congress. earliest of these acts was enacted in 1887. Fourteen of the acts were enacted before 1939, while six were enacted since 19 The most recent was enacted in 19 The Commissioners believe that it may readily be appreciated that there is c siderable need to modernize many if not all of these acts, which were enac more than 10 years ago; i.e., 18 of the 20 acts. From time to time, action is initiated by persons interested in a particu profession, occupation, business, trade, or calling to revise the act of Cong relating to such profession, occupation, business, trade, or calling. These visions may range from a complete rewriting of an act (such as has been propo by the certified public accountants, the pharmacists, the optometrists, the metologists, the barbers, and the real estate brokers and salesmen) down to si a simple matter as changing the age requirement for registered nurses from to 19 years, or permitting the acceptance of the results of national board exami tions in connection with the licensing of dentists and dental hygienists. 1 number of acts involved, and the need for revising them to meet changing nee inevitably results in the submission to each Congress of requests for such chang The principal problems confronting the Commissioners and persons affected these acts of Congress are the lack of uniformity in the methods and procedu prescribed by such acts, and certain obsolescent or madequate standards and quirements established by them. In the 74-year-span between the earliest of t acts and the most recent, the many Congresses have prescribed a variety standards, requirements, and procedures which, by reason of their lack of u formity, create difficulties in the administration and application of such ac Particularly affected by this lack of uniformity are those attorneys who may retained by persons contesting the proposed denial, suspension, or revocation a license, certificate, or registration, since an attorney so retained, rather th being able to rely on a standard, uniform procedure, must make sure that wha ever action he takes conforms with the particular requirements of the applica statute. Further, he must also familiarize himself with the regulations adopt under the authority of such statute, and these in turn, because of the requir |