Relating to the certification and regulation of certain out-of-state certified public accountants.

Contracts

• Master Services Agreements (MSAs): Update agreements with external accounting and audit firms. Insert a warranty clause requiring the vendor to certify that all staff assigned to your Texas accounts meet the requirements of Texas Occupations Code § 901.462 (SB522).
• Employment Agreements: For remote/out-of-state employees, amend contracts to make continued employment contingent upon maintaining practice privileges under the new Texas tiers.

Hiring/Training

• Two-Tier Verification Workflow: HR and Credentialing teams must stop relying on general reciprocity. Implement a specific intake checklist for out-of-state hires:
• 1. Tier 1: 150 semester hours/Graduate Degree = Requires proof of 1 year work experience.
• 2. Tier 2: Bachelor’s/120 semester hours = Requires proof of 2 years work experience.
• Vendor Onboarding: Update vendor intake forms to require specific confirmation of SB522 compliance for professional services.

Reporting & Record-Keeping

• Grandfathering Evidence: For staff claiming exemption under the grandfather clause, you must retain proof that they held an active out-of-state license and exercised practice privileges in Texas on or before December 31, 2024. (e.g., timesheets, emails, or engagement letters dated 2024).
• Transcript Retention: Retain academic transcripts for non-grandfathered out-of-state staff to prove they meet the 150-hour or 120-hour distinction in the event of a Board audit.

Fees & Costs

• No New State Fees: There are no direct fee increases from the state.
• Administrative Costs: Budget for increased administrative hours regarding credential verification and potential legal review of professional liability insurance policies.