Milestone Certified Public Accountants logo — boutique CPA firm Pleasanton CA

CALIFORNIA NON-PUBLIC AGENCIES


Tax and accounting for California NPA practices.

Built for California Non-Public Agencies certified by CDE to deliver special-education services — speech, OT, PT, ABA, counseling, mental health — to school districts. The district contract cycle, the AB 5 exposure, and the CDE annual review on one desk.

THE REALITY OF AN NPA

Six places generic CPAs miss.


NPAs look like clinical practices on the surface and run like education-services contractors underneath. Six places that hybrid breaks generic accounting.

District payment cycles + summer gap

Districts pay on 60-90 day cycles. Service hours stop in June and resume in August. Cash flow that looks healthy in April becomes a credit-line draw by July if it isn't modeled as deferred revenue with a summer carry plan.

Per-session, per-hour, per-student rates

NPA rate cards mix per-hour direct service, per-session IEP attendance, per-student annual caps, and travel-time stipends. Generic books lump it all as "revenue" — losing the per-contract margin visibility owners need.

AB 5 + the ABC test for clinicians

1099 SLP, OT, and BCBA contractors rarely survive AB 5's ABC test when the NPA is the entity delivering the contracted service. Most NPAs pre-2020 still carry historical exposure. EDD audits in this space are unforgiving.

CDE annual certification + financial review

CDE certification requires annual renewal with financial review, liability-insurance proof, and demonstrated solvency. Books that work for cash-basis tax often don't pass CDE scrutiny — you need GAAP-aware financials.

Fingerprinting, TB, training, supervision

Mandatory pre-service costs per clinician (LiveScan, TB clearance, mandated reporter training, BCBA supervision hours) are recurring and deductible — but only if categorized correctly and tracked per employee.

IDEA / IEP-driven service obligations

Districts contract NPAs to fulfill IDEA-mandated IEP services. Compensatory hours, ESY (extended school year), and make-up sessions create revenue patterns generic CPAs don't model — and miss billable hours owed.

WHAT WE DO

Three engagement tracks built for NPA practices.


Accounting, tax, and advisory — integrated for NPA owners delivering school-contract services.

01

Accounting & Bookkeeping

Monthly close that reflects how an NPA actually earns and spends — per district, per service line, per clinician.

  • Per-district contract margin reporting
  • Deferred revenue + summer cash modeling
  • Per-clinician productivity reporting
  • CDE-ready GAAP financials
  • Audit-ready closes by the 15th
02

Tax Strategy & Prep

Federal + CA returns plus year-round planning that uses the structure of an NPA practice.

  • Entity structure (PC vs LLC by service mix)
  • S-corp election + reasonable comp
  • §179 + bonus depreciation on equipment
  • Multi-district / multi-county planning
  • Quarterly estimated tax planning
03

Practice Advisory

Owner-level guidance for compliance, growth, and the transitions every NPA owner faces.

  • ABC-test compliance + back-payroll exposure
  • Adding clinicians (W-2 vs PC partner)
  • New service lines (ABA, counseling, MTSS)
  • Selling, merging, or rolling up the NPA
  • Retirement plans for owner + staff
A

CPA-led

You work with a CPA, not an associate.

B

Flat-fee

Scoped upfront and committed in writing.

C

24-hour

Response within one business day.

D

Year-Round

Quarterly planning — not just at deadlines.

Common Questions

Before we talk.


Should an NPA be a Professional Corporation, LLC, or S-corp?

It depends on the service mix and licensing structure of the owners. NPAs delivering services that require professional licenses (SLP, OT, PT, MFT, LCSW) where the entity itself is the practitioner often need a Professional Corporation in California. Service mixes that include BCBA, paraprofessional, or non-licensed services can use LLC. S-corp election is layered on top once compensation hits the breakeven.

How do we handle the summer cash flow gap?

We model district contracts as deferred revenue so income is recognized in the period the service is delivered. That gives you accurate monthly margin and lets you build a summer reserve from peak months. We also help structure a working-capital line so summer payroll isn't a stressor.

What does AB 5 mean for our 1099 clinicians?

For most NPAs the ABC test does not support 1099 status for SLPs, OTs, BCBAs, or other licensed clinicians delivering the contracted school service. The business-to-business exception is narrower than people think. We reclassify cleanly, model the cost impact, and coordinate with employment counsel on any historical exposure.

Can you help with the CDE annual financial review?

Yes. We prepare GAAP-aware financials and the supporting schedules CDE expects — solvency, insurance, payroll, related-party transactions. Most NPAs find their existing books need rebuilding the first time around; after that we maintain them at review standard year-round.

What about make-up sessions, comp ed, and ESY?

These are billable revenue under the contract — but only if tracked. We help build a workflow that captures owed sessions per IEP, separates ESY from regular school year, and turns make-up obligations into the revenue they actually represent.

How quickly can you onboard our NPA?

Typically 30-60 days from engagement letter. We pull your prior three years of returns and contracts, reconcile per-district AR, restate deferred revenue, and set the entity structure before the first full close.


An Invitation

Built around how your NPA practice actually runs.

A complimentary 30-minute review. We look at your NPA specifically — service lines, district contracts, staffing, certification — and tell you honestly what we'd do.

Call directly: 925-320-0309 · ronak@milestonecpas.com