The document summarizes a study evaluating merging the Washington State Board of Accountancy (WBOA) into the State Department of Licensing (DOL). The study found that accountability would be damaged by a merger, as independent boards resolve complaints at a higher rate than consolidated boards. It also found no significant cost savings or differences in efficacy would result from a merger. The conclusion was that WBOA should remain independent to maintain its accountability to the public.

1. BOARDS UNDER SCRUTINY PRESENTED BY DON AUBREY AND LAURIE TISH WASHINGTON STATE BOARD OF ACCOUNTANCY JUNE 2011

2. MERGER REPORT In response to legislative request, the Washington Board of Accountancy (WBOA) commissioned a study to evaluate the efficacy, economy and accountability of merging the WBOA into the State Department of Licensing (DOL) Study was performed by Zwillinger Greek Zwillinger & Knecht, PC and Field Lawdahl, PLLC Study completed in December 2010

3. SCOPE AND METHODOLOGY Focus of review Understanding the current structure of WBOA and DOL Understanding the proposed structure of the new entity if merger took place Comparing the actual costs of operating WBOA independently vs as an integrated program of DOL Assessing the effectiveness of the regulation of the profession under the current and proposed structures Considering the impact that integration may have on accountability to the public and to the profession

4. REPORT RESULTS - ACCOUNTABILITY Accountability would be damaged, “potentially by a significant amount” Boards that operate independently investigate and resolve complaints at almost twice the rate of consolidated agency boards (data is from 22 boards of accountancy) Compared to another consolidated Washington Board (Professional Engineers/Land Surveyors), WBOA investigates and resolves complaints at almost twice the rate

5. REPORT RESULTS - ACCOUNTABILITY Accountability would be damaged, “potentially by a significant amount” A merger would remove WBOA’s direct reporting relationship with the Governor’s office This change would decrease WBOA’s visibility and accessibility to the State’s top level of government Could reduce effectiveness in carrying out mission Negative impact on accountability

6. REPORT RESULTS - ECONOMY There would be no significant changes noted in WBOA’s economy as a result of a merger with DOL A proforma expenditure budget was developed Budget would decrease by less than 6% However, initial costs of merging operations and data platforms would more than negate this Operation benchmarks were reviewed All indications are that WBOA is running its operations as efficiently as similar regulatory and disciplinary boards currently under DOL authority

7. REPORT RESULTS - EFFICACY There would be no significant differences noted in WBOA’s efficacy as a result of a merger Analysis focused on: Current regulatory processes, including rulemaking, license applications/renewals, and determinations of disciplinary matters Current handling of public records requests

8. REPORT RESULTS - CONCLUSION WBOA should not merge into DOL “Given that the stated reason for the creation and existence of WBOA is to promote the dependability of financial information and to protect the public interest, a reduction in the accountability of WBOA to the public and the profession would be a failure of WBOA’s statutory purpose.”