Qualifications Committee Meeting January 18, 2017

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OREGON BOARD OF ACCOUNTANCY

Qualifications Committee Minutes of January 18, 2017

Committee Members Present Alan Steiger, CPA-Retired (Chair) Haley Fish, CPA Rachelle Quinn, CPA (Vice-Chair) Megan Kurz, CPA Michael Schmidt, CPA Rebecca Griffith, CPA Lynn Kingston, CPA (Board Liaison) Staff Present Kimberly Fast, Licensing Manager Julie Nadeau, Licensing Specialist

Excused Absence Bryce Wilberger, CPA Yvette Burling, CPA Casey Camors, CPA Guests Present Jenna Bailey, Applicant Erick Clow, Applicant Vivien Fedd, Applicant

1. CALL TO ORDER

The Qualifications Committee (QC) convened for a regularly scheduled meeting on January 18, 2017. Alan Steiger, CPA-Retired, Committee Chair, called the meeting to order at 9:00 am. Mr. Steiger announced that the meeting was being recorded and called the roll.

2. APPROVE MINUTES A. November 9, 2016

Ms. Kurz pointed out the misspelling of Rick Koseor’s last name on the list of guests present. COMMITTEE ACTION: APPROVAL Ms. Quinn moved to approve the November 9, 2016 minutes as amended. MOTION PASSED: 6 Ayes.

3. REPORT OF BOARD ACTION

Ms. Kingston reported that the Board approved all of the QC’s recommendations at their meeting of December 5, 2016. She also noted that Rebecca Griffith was officially appointed to the Committee.

4. PENDING APPLICATIONS A. Current Applications

1. Jenna Bailey

Ms. Bailey passed the Uniform CPA examination in October 2016. Experience was gained at the following employer:

KAI USA, Ltd 17 Months All Competencies

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Ms. Quinn introduced Ms. Bailey’s application. She reported that she and Ms. Bailey discussed her narrative and that substantial revisions were made, adding details regarding risk assessment, understanding and identification of internal controls, and understanding critical success factors. She added examples in foreign currency translation and working through a solution to address problems, review of accounts payable functions, segregation of duties and making sure there are mitigating controls in place to address any exposure items. Mr. Schmidt asked Ms. Bailey to elaborate on competency D, specifically regarding the software implementation and how she tested the software changeover to be sure different modules were posting correctly. Ms. Bailey said she created a new chart of accounts, ran tests through the different modules before training individuals in each department to be sure when invoices were posted that they would flow through to correct accounts, and then audited those accounts. She tested every module to be sure everything was flowing through to the general ledger correctly. Mr. Steiger asked about the first paragraph in competency D regarding the conversion from an AS400-based system to a Microsoft Dynamics GP system. Ms. Bailey reported that conversion happened during her employment with Mayflower Transit, where she worked for 9 years in a controller capacity. She explained that, outside of the one paragraph, all other details in her narrative related to her employment with KAI under her qualified supervisor. COMMITTEE RECOMMENDATION: APPROVAL Ms. Quinn moved to find that there is sufficient evidence to make a preliminary finding that Jenna Bailey has demonstrated the competencies necessary for initial licensing per OAR 801-010-0065. MOTION PASSED. 6 Ayes.

2. Erick Clow

Mr. Clow passed the Uniform CPA examination in November 2015. Experience was gained at the following employer:

Craft Brew Alliance, Inc. 22 Months All Competencies

Ms. Kurz introduced Mr. Clow’s application, noting that he works for a large craft brew distributor. Mr. Clow worked as a staff accountant and reported to the technical accounting manager for approximately 17 months before recently becoming a financial analyst. Ms. Kurz noted that Board staff verified the supervisor was continuously licensed between Arizona and Oregon since March 2007. Ms. Kurz said Mr. Clow did a nice job adding detail in his revised narrative based on their conversation, including expanded descriptions of the resolution and achievements of examples, as well as discussion about regulatory trends impacting the brewing industry. In competency D, Mr. Clow summarized the fixed asset system conversion, including testing that he had conducted after conversion, the benefits of the conversion process and steps he performed, as well as the benefits the new system provided to the organization. Competency E originally included examples of 10-K and 10-Q, which Ms. Kurz felt were more appropriate for competency C. In the revised narrative, Mr. Clow moved that example and provided a new example for competency E that Ms. Kurz said was still brief and left a gap between the two examples. Ms. Kurz was comfortable with rest of competencies and believes the work experience can be documented. Mr. Clow indicated that he was on vacation during the period of review leaving him rushed to make changes. He said he didn’t design the risk assessment work, but went through the actions of verification. He did use the fixed asset existence testing and that he had a hand in developing most of the risk assessment and verification. Mr. Steiger indicated that additional information would need to be provided in writing and could not be shared verbally during the meeting.

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Mr. Steiger said Mr. Clow’s examples in competency B that showed undesirable outcomes left him to question if the management team had all the information necessary to make a decision and whether or not there was a good analysis of the risk involved. Mr. Clow explained that decisions are based on the information provided, but that sometimes decisions go sideways. He added that quality work is provided. Ms. Kurz suggested that Mr. Clow spend time discussing fixed assets and include another example in competency E to leverage the example used in competency B to discuss participation in the risk assessment that occurred in decision making.

COMMITTEE RECOMMENDATION: DEFERRAL Ms. Kurz moved to defer the application for Erick Clow pending additional documentation of competency E. MOTION PASSED. 6 Ayes.

3. Cheuk Yan Kwan

Ms. Kwan passed the Uniform CPA examination in May 2016. Experience was gained at the following employer: WSP Parsons Brinckerhoff 31 Months All Competencies

Mr. Schmidt introduced Ms. Kwan’s application, noting that she is located in Asia which left them to communicate solely through email. He was able to confirm that her direct supervisor provided regular and meaningful direct oversight, meeting daily to work through issues. Mr. Schmidt was concerned with competencies B, D, E and G, indicating that the documentation and examples did not demonstrate competency. In Competency B, he didn’t see performance of verification through the systems, but instead it appeared that an offline excel tracker was used. He would also like to see additional documentation regarding a formal risk assessment and clear presentation of an analytical review with the applicable accounting rules. Ms. Quinn said she was also concerned with competencies C and F, noting that discussion regarding analysis of expense reports was light, suggesting that the example include FASB or real literature. Regarding competency F, she found the discussion about inactive vendors and employees confusing, noting that an additional example would be warranted. . Mr. Schmidt agreed to discuss further revisions with Ms. Kwan, but felt the applicant may have difficulty understanding what level of detail is required and how to demonstrate competency, especially by email. Mr. Steiger provided an analogy he uses when reviewing narratives, stating that he reviews the application as if he is interviewing the applicant for a position in his firm that requires a CPA license and in evaluating the candidate, he uses the seven competencies as set out in the job description. He stated that he would guide the applicant by saying “can you give me a little more information?” or “can you give me another example?” and those kinds of questions. Recognizing that the bar is set higher than that of applicants through public accounting, he said the Qualifications Committee serves as guardians of the gate for industry applicants. Ms. Quinn noted that the applicant is welcome to participate in the meetings and review the discussion from the meeting.

COMMITTEE RECOMMENDATION: DEFERRAL Mr. Schmidt moved to defer the application for Cheuk Yan Kwan pending additional documentation of competencies B through G. MOTION PASSED. 6 Ayes.

4. Vivien Fedd

Ms. Fedd passed the Uniform CPA examination in November 2015. Experience was gained at the following employer:

Northwest Evaluation Association 55 Months All Competencies

Mr. Wilberger was unable to attend the meeting but was able to provide a written recommendation of Ms. Fedd’s file which Mr. Steiger summarized. The four-page written review provided by Mr. Wilberger, included his recommendation for approval and referenced each competency and how the competency was achieved. Ms.

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Nadeau emailed the document provided by Mr. Wilberger to all of the members in attendance so they could personally review the comments. A copy of Mr. Wilberger’s full review is appended to these minutes. In Mr. Steiger’s summary, he stated that Mr. Wilberger indicated that the application materials demonstrate that the applicant was supervised at a level that indicates regular and meaningful interaction. For competencies A, C, D and G, Mr. Steiger reported that Mr. Wilberger felt the applicant satisfied the competency. Regarding competency B, Mr. Steiger said Mr. Wilberger indicated the applicant appears to work with fundamental measurement factors within the organization based on documentation of evidence and that Mr. Wilberger felt there was evidence the applicant satisfied the competency. For competency E, the applicant included discussion regarding what work was done after an area was determined to be at risk; however, Mr. Wilberger noted that examples could discuss the process of why A/P and A/R presented risk of misstatement. Mr. Steiger said Mr. Wilberger noted that using the examples provided, discussion with candidate and supplementing information from the first example provided for competency G to document experience, the candidate satisfied the competency. In discussing competency F, Mr. Steiger said Mr. Wilberger noted that by using examples from other sections, the candidate has satisfied the competency and he made reference to other comments provided by Mr. Wilberger. COMMITTEE RECOMMENDATION: APPROVAL Mr. Steiger, on behalf of Mr. Wilberger, moved to find that there is sufficient evidence to make a preliminary finding that Vivien Fedd has demonstrated the competencies necessary for initial licensing per OAR 801-010-0065. MOTION FAILED. 2 Ayes, 3 Nays (Schmidt, Fish, Steiger), 1 Abstain (Griffith).

Ms. Quinn supported the recommendation, noting that the application was well done and she appreciated the inclusion of multiple examples. Ms. Kurz agreed, noting that she liked how well competency E articulated how a risk assessment can be contemporaneous during the process of completing a reconciliation. Mr. Steiger addressed his issues with the applications, noting that there were a number of situations throughout where the language used was not direct, for example “involved with,” “contributor to,” and “worked on,” leaving question as to how much input the applicant had. Mr. Steiger also said there were a number of examples where journal entries were used to correct errors. Errors were found, but he didn’t see follow-up discussion on what control issues there were to cause the errors. He would like to see a solution as to how they will avoid journal entry errors in the future. Ms. Fish said the narrative was well written, but she struggled with competencies C, D and E. She said documentation for journal entries were used instead of a complete work paper with a purpose, analysis and conclusion, and that the control aspect was missing. Ms. Fish also said the example in competency D seemed much more manual rather than systematic. In competency E, Ms. Fish said the narrative lacked the control perspective, so she struggled from a risk perspective. Ms. Fedd said she would be happy to answer any questions and asked the Committee to be more specific with their concerns so she could address each issue. Mr. Steiger said the decisions made by the Committee must be based on information documented in writing, but he offered to answer her questions. Ms. Griffith abstained because the applicant’s employer was a client of her firm and she was involved in the work for that client, leaving her unsure if she worked directly with the applicant. Ms. Fast explained that abstention is only required if the Committee member feels that the knowledge they have from working with the applicant or employer would influence a decision regarding the applicant. Mr. Schmidt asked if the motion should include the request to update the indirect language. Ms. Kurz agreed conceptually that direct language demonstrates personal ownership of whether the experiences truly rest in the applicant’s portfolio; however, she thought it may be helpful to the applicants to include clarification in the application to avoid deferring applications because it was unclear to applicants as they prepared their narratives. Mr. Steiger referred back to his analogy of the interview situation and said if someone included that they “worked

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on” a project, he would ask a probing question to determine their role. Ms. Kurz said it is more difficult in this situation because this isn’t a live interview process and it takes several months to turn the narrative around. Ms. Kurz noted it becomes the responsibility of the reviewer to keep that in mind and that the applicant should be provided guidance during the application process so they can make an effort to get it right on the first draft. Ms. Quinn asked Ms. Fish to review her concerns again to be sure it is clear to Ms. Fedd what the concerns are with the competencies. Ms. Fish said for competency C she specifically struggled with the conflict of the work paper being the backup for a journal entry, and she couldn’t tell whether or not everything the applicant walked through in her example was actually documented within the work papers of purpose and analysis therein as opposed to just being reports that backed up a journal entry. For competency D, Ms. Fish said the examples seemed very manual versus systematic in nature and the procedures Ms. Fedd was doing related to vouching. Regarding competency E, Ms. Fish stated the example seemed substandard in nature and lacked the discussion of control. Ms. Fedd asked which language was indirect because she had a hard time finding an example of passive language in her application. Mr. Steiger pointed out that example #1 in competency C starts with “I worked on the task.” Ms. Fedd explained that saying she worked on the task meant she performed the task. Mr. Steiger asked for the context and if she was working alone or within a group. Ms. Fedd said she was referencing her own work. Mr. Steiger said his impression from the wording “I worked on” led him to believe she was part of a team and asked how she would communicate better. Ms. Fedd said that, while she is part of the accounting team, when she used the phrase “I worked” she was referring to the work she performed individually and asked for a suggestion of better verbiage. Mr. Steiger suggested that she use “I did” instead of “I worked,” using a different verb in the sentence. Ms. Fedd asked for clarification regarding competency D being manual rather than systematic. While Ms. Fish searched for an example, Mr. Steiger provided general feedback regarding competencies C, D and E, in that Ms. Fedd worked to find an error, but he didn’t see the conversation as to why the error occurred and how it would be prevented from happening again. Ms. Kurz suggested that, in the last paragraph of example #1 for competency D, the control that was missing was that the initial general ledger classification was not reviewed for prepaid versus expensable items and it was posted to an expense account. However, in competency E there could be a discussion of controls put in place to bring it full circle. Ms. Fish noted that she also struggled with the fact that the risk assessment is always coming from an error noted or investigating an error rather than trying to mitigate and looking at the system prior to identification of an error. Mr. Steiger said in the real world when an applicant comes into an organization where policies and procedures are already in place, he’s not as hung up as keeping a problem from happening again. Ms. Kurz said this narrative does a nice job of demonstrating where, in industry, the luxury of taking a blank sheet of paper for a brand new process to conduct a risk assessment isn’t always available. In this case, identifying via reconciliation contemporaneously, the risk presents itself and finding where it went wrong. Ms. Fedd asked if the minutes would be available so she can review the feedback. Ms. Nadeau said she would email Ms. Fedd and Mr. Wilberger the portion of the minutes related to the review of her application. COMMITTEE RECOMMENDATION: DEFERRAL Ms. Fish moved to defer the application of Vivien Fedd pending clarifying or additional information related to competencies C, D and E. MOTION PASSED. 5 Ayes, 1 Abstain (Griffith).

5. Timothy Murphy

Mr. Murphy passed the Uniform CPA examination in May 2016. Experience was gained at the following employer:

Dr. Martens AirWair USA LLC 54 Months All Competencies

Ms. Camors was unable to attend the meeting and provided a written recommendation for the application of Mr. Murphy. Mr. Steiger read Ms. Camors review and recommendation for the record. Ms. Camors noted that the

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supervisor licensee became qualified to provide supervision in August 2014, which allowed for more than two years qualified supervision. Mr. Murphy and his supervisor have ongoing, daily interaction. His job functions are mostly tax related, which allows him to participate in many areas including revenue, cost of goods sold, sales systems and e-commerce, and fixed assets. Mr. Steiger noted that Ms. Camors originally suggested narrative revisions for competencies B, D, E, F and G as she didn’t feel these areas encompassed all required competency elements. While the updated narrative is still somewhat brief, Ms. Camors felt it fulfilled the required competencies. COMMITTEE RECOMMENDATION: APPROVAL Mr. Steiger, on behalf of Ms. Camors, moved to find that there is sufficient evidence to make a preliminary finding that Timothy Murphy has demonstrated the competencies necessary for initial licensing per OAR 801-010-0065.

Ms. Quinn said she struggled with competency C because it was brief and was limited to the federal and state estimated tax. In competency F, she identified the areas of experience outlined in the competency heading and said she didn’t see any of those experiences listed in the narrative. Ms. Kurz agreed and added that she had difficulty with competency B stating the applicant explained the objective, however, she didn’t see evidence where Mr. Murphy tied back or corroborated whether or not the objective was met. Mr. Steiger struggled with competency G because there was only one example included in the discussion and he felt competency D was weak for the same reason. Ms. Fish said she struggled with all of the competencies. In competency A, she indicated that doing the right thing due to a lack of control structure isn’t really the same as integrity, noting that she was looking for the perspective of an industry as a whole. COMMITTEE RECOMMENDATION: AMENDED MOTION - DEFERRAL Ms. Quinn moved to amend the motion to defer the application for Timothy Murphy pending additional information on all competencies. MOTION PASSED. 6 Ayes.

5. NEW BUSINESS

A. Committee recruitment

Mr. Steiger asked Ms. Kingston to discuss the current vacancies with the Board to see if they have any recommendations for recruitment. Ms. Kingston agreed.

B. Committee elections 2017

Mr. Steiger noted that Ms. Quinn is currently the Vice-Chair of the Committee. Ms. Quinn said she is happy to have Mr. Steiger remain as Chair. Mr. Steiger asked if the Committee would like to see Ms. Quinn assume the role of Chair while Mr. Steiger is still on the Committee. Ms. Fast agreed that it would be beneficial to have someone else assume the role to gain experience before Mr. Steiger leaves the Committee at the end of the year so they would have experience. The Committee opted to defer the election of officers until their April 5 in-person meeting.

6. ADJOURN

The meeting was adjourned at 10:20 am.

Summary Review Notes – Vivien Fedd

Qualifications for Certification - The Basics:

Passed CPA Exam: 11/2015 Passed Ethics Exam: Yes

Experience: includes 46.5 months of qualifying experience, indicated as applicable to all competencies.

Supervisor Licensee: The supervisor licensee in the application is Yana Kolesnikov. Ms. Kolesnikov is the Senior Director of Finance at Northwest Evaluation Association, the company that the candidate is employed with, and at which the experience was obtained related to the application. The reporting relationship between the candidate and the supervisor licensee is a direct reporting relationship. The reporting relationship was further supported by the organization chart provided in the application materials.

Direct Supervision 801-010-065 (2)(d) –“Direct supervision” as used in this rule means that there is a regular and meaningful interaction between the supervisor licensee and the person being supervised in terms of planning, coordinating, guiding, inspecting, controlling, and evaluating activities, and having authority to influence the decision to discharge the employee being supervised.

The application materials indicate that the applicant was supervised by supervisor licensee and that the relationship was regular or meaningful in terms of planning, coordinating, guiding, or controlling the work performed by the applicant.

Conclusion: Based upon these details, it appears that a supervisor licensee had directly supervised the candidate at a level that indicates regular, meaningful interaction in terms of planning, coordinating, guiding, inspecting, controlling and evaluating activities for the duration of the qualifying experience.

Experience portfolio – core competency evaluation: 801-010-065 (2)(e) The experience required under ORS 673.040 must consist solely of experience within activities generally performed by certified public accountants and public accountants licensed in Oregon, including (but not limited to) financial statement audits, financial statement reviews, financial statement compilations, attestation engagements, financial forecasts and projections, pro forma financial information, compliance attestations, management advisory services, tax advisory services, tax return preparation, personal financial planning or reporting on an entity's internal controls.

A. Understanding the Code of Professional Conduct 801-010-005 (3)(a) – Understanding of the Code of Professional Conduct promulgated and adopted by the Board.

• Passed ethics exam • Exercises professional skepticism and due professional care when performing work • Taken and passed the AICPA ethics course

Comments: based upon the documentation of experience provided, the candidate has satisfied this competency.

B. Ability to Assess the Achievement of an Entity’s Objectives 801-010-005 (3)(b) – Ability to assess the achievement of a client’s objectives by demonstrating knowledge of various business organizations, understanding of the objectives and goals of business entities, ability to develop and analyze performance measures and critical success factors, and understanding of the economic and regulatory trends that affect the environment of a business entity. 801-010-005 (4)(c)(i) – Industry, government or other experience related to subsection (3)(b) of this rule, assessing the achievement of an entity’s objectives, will include obtaining an understanding of the industry in which the entity operates, including the employer’s competition (or other similar service providers in the case of government) and key competitiveness factors that affect the industry.

• Monitoring key performance indicators • Contribute to and deliver data for performance measurement tracking • Compare expenses to budget • Create and monitor staffing plans and growth

Comments: Candidate appears to work with the fundamental measurement factors within the organization and how the industry and regulation affect the organization. Based upon the documentation of experience provided, the candidate has satisfied this competency. C. Evidence in Preparing Working Papers That Contain Sufficient, Relevant Data to Support Analysis and Conclusions

801-010-005 (3)(d) – Experience in preparing working papers that include sufficient relevant data to support the analysis and conclusions required by the applicant’s work.

• Preparation of prepaid control account reconciliation • Review of spreadsheets looking for mathematical errors • Identification of voucher line items • Review service dates • Evaluate appropriateness based on underlying documentation. Correct errors as needed.

Comments: based upon the documentation of experience provided, the candidate has satisfied this competency.

D. Understanding Transaction Streams and Information Systems 801-010-005 (3)(d) – Understanding transaction streams and information systems, including the ability to understand how individuals transactions aggregate at the organization level, to infer how transactions impact the organization as a whole, and to evaluate the integrity and reliability of various client information systems, including relevant computer aspects. 801-010-005 (4)(c)(ii) – Industry, government or other experience related to subsection (3)(d) of this rule, understanding transaction streams and information systems, will include assessing the adequacy of an entity’s internal controls.

• Observation of transactional flows through procurement module • Identify errors and reclassify based on prepaid status

• Identify missing internal control in existing workflow. Recommend new control process for workflow and then implement

• Involved in implementing new revenue recognition software • Provide revenue reconciliations for a year post implementation to ensure proper revenue

recognition

Comments: based upon the documentation of experience provided, the candidate has satisfied this competency.

E. Risk Assessment and Verification Skills: 801-010-005 (3)(e) – Skills in risk assessment and verification demonstrated by a sufficient understanding of accounting and other information systems to (a) assess the risk of misstatement in an information system; (b) obtain sufficient relevant data based on the risk of misstatement and the nature of the engagement to determine the appropriateness of underlying data in terms of its completeness, existence and occurrence, valuation and allocation , rights and obligations, presentation and disclosures.

• Year end evaluation of misstated financial data related to accounts payable • Year end evaluation of existence, completeness and valuation related to accounts receivable • Year end evaluation of completeness and valuation related to fixed assets

Comments: A lot of discussion regarding what work was done after an area was determined to be a risk. Seems to support 801-010-005(3)(e)(b). I would like to see these types of examples discuss more of the process to determine that A/P or A/R present a risk of misstatement and why.

Upon discussion with the candidate, she performs various risk assessments related to the financial systems and changes that are being considered. The process she follows to evaluate the risk of change is to first identify areas of risk and then flow a transaction through the system to identify areas of concern and see how the change will affect the overall process and potential risk of misstatements. Once area of concerns are identified, the candidate then evaluates process flow and provides management with recommendations on process controls which can be used to mitigate risk.

1st example under G provided some additional support related to risk assessment and evaluation of internal controls related to the procurement system.

Using provided examples, discussion with candidate and supplementing information from 1st example from G to document experience, the candidate has satisfied this competency.

F. Decision Making, Problem Solving, and Critical Thinking in the Context of Analysis 801-010-005 (3)(f) – Skills in decision making, problem solving, critical analytical thinking including the ability to evaluate and interpret sufficient relevant data in a variety of engagements and settings. For example, the candidate must evaluate a client’s cash flow, profitability, liquidity, solvency, operating cycle, achievement of management’s plans, accomplishment of service efforts and systems reliability.

• Cash flows from operations analysis

• Evaluating operating cash flow against normal operations • Analysis of operational trends contributing to reduced net profit • Identify negative trends and provide policy change recommendations to management to mitigate

Comments: The examples feel very theoretical in nature as though they were written for an assignment. There is discussion of analysis related to cash flow trends. Additionally the candidates uses terms that are inconsistent (indirect method and cash from customer/cash paid to suppliers).

Upon discussion with the candidate, the cash flow is on the indirect method and the analysis is performed on a monthly basis. Part of her role is to analyze the trending of operational cash flow and then discuss with management the changes and how changes will affect the operations.

There was some confusion by the candidate as to how to document technical research. Her understanding was that she should reference various ACS section. She provides an example of technical research as the 2nd example under G. I used it to provided additional support related to decision making, problem solving, and critical thinking as used in researching technical areas for taxes.

1st example under D also discussed, in brief, identifying missing controls and implementing work flow changes to mitigate errors.

Using provided examples, discussion with candidate and examples from other sections to document experience, the candidate has satisfied this competency

G. Quality of Communication, Expressing Scope of Work, Findings and Conclusions 801-010-005 (3)(g) – Ability to express scope of work, findings and conclusions including the ability to determine the appropriateness of reports on financial statements, system reliability, or reports expressing scope of work, finding and conclusions.

• Evaluation of gaps in procurement system and how it affect the overall financial workflow • Provided management with written report and presentation with pro/con of potential decisions • Walked management through the applicable options • Examples of deficiencies and how they affected the financial work flow • Evaluation of internal controls related to procurement. Identified and recommended various

changes to the internal controls over the procurement process. • Technical research related to lobbying expenses and the tax implications. Presentation of research

to management with recommendation of how to proceed.

Comments: based upon the documentation of experience provided, the candidate has satisfied this competency.

Final Summary and Conclusion: I move to find that there is sufficient evidence to make a preliminary finding that Vivian Fedd has demonstrated the competencies necessary for initial licensing per OAR 801-010-0065.