What Is an Alternative Practice Structure?
An Alternative Practice Structure (APS) is an arrangement in which a CPA or CPA firm works with or is associated with a non-CPA business. The non-CPA business may provide services such as accounting, tax preparation, insurance, wealth management, financial planning, consulting, or other professional services.
Nebraska allows CPAs and CPA firms to work within an APS. However, professional CPA services must be provided through a properly licensed CPA firm or sole proprietorship—not directly through the non-CPA business.
Providing Services Through a Non-CPA Business
An individual CPA may not hold out, offer, or provide professional CPA services through a non-CPA business.
A CPA providing tax services through a non-CPA business may choose to register with the IRS in another capacity, such as an Enrolled Agent or paid tax return preparer. When working in that capacity, the individual must not represent that the services are being provided as a CPA or through a CPA firm.
Providing CPA Services Within an APS
A CPA who holds an active Nebraska permit and practices through a licensed sole proprietorship or CPA firm may provide professional CPA services while associated with an APS.
The CPA must clearly explain to clients that the professional CPA services are being provided through the licensed sole proprietorship or CPA firm—not through the non-CPA business.
The following guidelines apply:
- Engagement letters should clearly identify the licensed CPA firm or sole proprietorship providing the professional CPA services.
- Websites, advertisements, social media, and other marketing materials must clearly distinguish the CPA firm’s services from those provided by the non-CPA business.
- Letterhead, business cards, and similar materials may be shared with the non-CPA business if they clearly state that professional CPA services are provided through the licensed CPA firm or sole proprietorship.
- A disclaimer or asterisk may be used to clearly identify the licensed CPA firm providing the professional services.
- Communications with clients should not create the impression that the non-CPA business is licensed as a CPA firm.
Example Disclosure
The following is one example of a disclosure that may be used:
Professional CPA services are provided through [name of licensed CPA firm or sole proprietorship], a firm licensed by the Nebraska State Board of Public Accountancy.
The disclosure should be adjusted to accurately describe the business arrangement.
Experience Earned Within an APS
Experience earned while working within an Alternative Practice Structure may qualify toward Nebraska’s experience requirement if:
- The work involves accounting, attest, compilation, management advisory, financial advisory, tax, or consulting skills;
- The work is completed under the supervision of an actively licensed CPA; and
- The experience meets all other requirements established by Nebraska law and the Board.
Qualifying experience earned in public practice, private industry, government, or academia is evaluated under the same standards.
The amount of experience required depends on the applicant’s education pathway:
- Postbaccalaureate degree: At least 2,000 hours of qualifying experience completed over a period of at least one year.
- Bachelor’s degree plus 30 additional semester hours: At least 2,000 hours of qualifying experience completed over a period of at least one year.
- Bachelor’s degree: At least 4,000 hours of qualifying experience completed over a period of at least two years.
The supervising CPA must be familiar with the applicant’s work and able to verify that the experience meets Nebraska’s requirements.
If the applicant and supervising CPA work for different entities within the APS, the Board may request additional information to determine whether the supervision requirement has been met.
For complete information, visit the Board’s Experience Requirements page.
Important Reminders
CPAs working within an APS are responsible for ensuring that:
- Professional CPA services are provided only through a licensed CPA firm or sole proprietorship;
- Clients understand which business is providing each service;
- Advertising and other communications are not misleading;
- The CPA complies with the Nebraska Public Accountancy Act and the Board’s Rules of Professional Conduct; and
- Any required individual, firm, and office permits remain active and in good standing.
Because every business arrangement is different, CPAs are encouraged to contact the Board office before offering services through an APS if they are unsure whether the proposed structure meets Nebraska’s requirements.
Additional Information
Review the Board’s complete:
Alternative Practice Structure Guidelines – September 2022
Please note: The experience requirements shown in the September 2022 guidelines are no longer current. The experience requirements changed in July 2026. Please use the current requirements provided on this page and on the Board’s Experience Requirements page.