CPA firm, individual permit/registration deadlines extended to July 1

Written on Dec 10, 2020

OSCPA staff report 

The Accountancy Board of Ohio has affirmed that House Bill 404 – signed into law last month – extends the 2020 deadline for firms and individuals to July 1, 2021 because of the pandemic. 

The deferral applies to peer reviews needed by firms for firm registration renewals originally due Dec. 1 and for individual registration and permit renewals originally due Dec, 31, 2020. The ABO determined that individual CPAs utilizing the extension would be required to have 120 CPE credits by the date they renew (no later than July 1, 2021), and only credits received after renewal would be applied to the 2023 reporting period. 

CPAs who have already completed their 120 hours of needed CPE should still renew by the original Dec. 31 deadline to preserve a full three-year reporting period to get their next 120 hours. That will provide the greatest amount of time to meet your next three-year requirement and also minimize confusion should you be audited by the Accountancy Board. 

Here is the pertinent language in HB 404: 

(C)(1) Except as provided in division (E) of this section, if a person is required by law to take action to maintain the validity of a license on or after March 9, 2020, but not beyond April 1, 2021, notwithstanding the date by which action with respect to that license is required to be taken in accordance with that law, the person shall take that action not later than July 1, 2021. 

(2) Except as provided in division (E) of this section, a license otherwise expiring pursuant to law on or after March 9, 2020, but not beyond April 1, 2021, notwithstanding the date on which the license expires in accordance with that law, remains valid until July 1, 2021, unless revoked, suspended, or otherwise subject to discipline or limitation under the applicable law for reasons other than delaying taking action to maintain the validity of the license in accordance with division (C)(1) of this section. 

(D) Nothing in division (C) of this section limits the authority of a state agency, political subdivision, or official that issues a license to take disciplinary action under the applicable law against a person with respect to a license, provided that a state agency, political subdivision, or official shall not take disciplinary action against a person who delays in taking action to maintain the validity of the license in accordance with division (C)(1) of this section.

Q&As

Q: I am in Group 1. Does this mean I no longer have to renew my license by December 31, 2020? What about finishing my 120 hours of CPE by Dec. 31?

A: The Ohio Legislature and Gov. DeWine approved a law change, effective immediately, that extends the due date for all licensees who otherwise would have to renew their permit or registration by Dec. 31. The Accountancy Board agreed that you also have until no later than July 1 (up to 6 extra months) to complete your 120 hours of CPE.

Q: What about firm registrations that were due Dec. 1? I am having a hard time completing my peer review on time because of COVID issues.

A: Firm registrations are also bumped out to no later than July 1, 2021, meaning impacted firms will have extra time to complete their peer review. If you take advantage of this situation, you may find your next peer review will occur in two years, instead of three. If you have any questions about this, contact the OSCPA Peer Review team.

Q: Does this mean that all future renewals will be in July rather that December?

A: No. This is one-time extension affecting only Group 1 due to COVID challenges. For the next three-year cycle (2021-2023) those in Group 1 will have to renew by Dec. 31, 2023. For the current cycle, if you already have completed your 120 hours of CPE, the best thing to do is go ahead and renew by Dec. 31, 2020 to avoid any confusion going forward.

Q: What is the downside to pushing out my renewal date?

A: For those who plan to take advantage of the additional time to get your 120 hours before renewing, keep in mind that all hours you earn up to the date you renew will count toward the hours originally due Dec. 31, 2020. Example: if you file your individual permit renewal March 1, 2021, all hours you earned between Jan. 1, 2018 and March 1, 2021 will count toward the last cycle, even if it is over 120 hours. That means that you will have 33 months to earn the 120 hours that will be due the end of 2023 rather than the normal 36 months. If you renew your permit on July 1, 2021, you will only have 30 months to earn the 120 hours you must report in 2023.

Q: Does this change the requirement that I have to earn at least 20 hours each year?

A: No. You will still need to take at least 20 hours of CPE in each year, per ABO rules.