NASBA’s National Registry team continues to notice an alarming trend of compliance desk audit failures with Registry sponsors. NASBA is urging sponsors to take care in their responsibilities per the Sponsor Agreement, which is acknowledged with each renewal application, to adhere and comply with the Statement on Standards for Continuing Professional Education (CPE) Programs (2019) (Standards) and NASBA requirements. Failure to do so may result in removal from the National Registry. 

Generally, audit failures result from a significant deficiency from the Standards, which could impact the Certified Public Accountant (CPA) and the CPA’s ability to use the CPE credits issued. The most common causes for audit failures are inadequate attendance monitoring policies coupled with insufficient attendance monitoring documentation and incomplete or inaccurate information on the issued certificates of completion. 

Focus: Attendance Monitoring and Documentation 

Paragraph S16-02 of the Standards states that CPE program sponsors must maintain a process to monitor individual attendance at group programs to assign the correct number of CPE credits. 

Why the emphasis on attendance monitoring and documentation? CPAs must report CPE credits to their Boards of Accountancy to maintain and renew their licenses. Typically, state boards only review the certificate of completion, so it’s vital that attendance procedures support the assignment of CPE credits as reflected on the issued certificate. 

For the Group Live delivery method, common attendance monitoring deficiencies include: 

• The supporting documentation does not match the attendance monitoring procedures as described by the sponsor in their administrative policies. 

• The supporting attendance documentation is incomplete. There are no indications of check in and check out times nor indications of how late arrivals, early departures and extended breaks are handled. 

• The sponsor allows the CPA to self-report CPE credits. 

• The written attendance policy lacks sufficient detail to understand how attendance is monitored. 

Standard No. 16 requires Group Internet Based programs to employ some type of real time monitoring mechanism to verify that participants are engaged during the program. The monitoring mechanism must include at least three instances of interactivity completed by the participant randomly throughout the program per CPE credit. For a program that is longer than one CPE credit, additional monitoring mechanisms are required. Examples of monitoring mechanisms include polling questions, passcodes or use of the chat/raise hand functions.  

Sufficient documentation of attendance monitoring for Group Internet Based programs would contain each individual attendee’s responses, or lack thereof, to each of the employed monitoring mechanisms. While most platforms used for conducting Group Internet Based programs generate a report that indicates start and end time for each individual participant, that report alone is not sufficient to address the requirements of Standard No. 16. 

The key is to have attendance monitoring procedures and documentation that are adequate and sufficient such that, if contacted four months after the date of the program, a sponsor could re-issue the certificate with confidence as to the individual’s attendance and the correct amount of CPE credit earned for the program. 

Should you have questions regarding the adequacy of attendance monitoring and documentation for Group Live and Group Internet Based programs, feel free to contact the National Registry team at cpe@nasba.org.