It has come to our attention that certain CPA firms may be running afoul of the NASBA’s CPE requirements for webinars. The purpose of this post is to summarize the temporary concessions provided by the NASBA because of COVID-19, as well as to remind firms of the CPE requirements for the Group Internet Based (GIB) delivery method (that’s what the NASBA calls webinars) so they ensure they are in compliance of the rules.

In March 2020, the National Registry of CPE Sponsors, part of the National Association of the State Boards of Accountancy (NASBA), provided flexibility to “Group Live only” approved sponsors, allowing for in-person events to be modified and offered online because of COVID-19. Additional flexibility was also granted to GIB delivery method sponsors. The timeframe for flexibility was originally granted through September 30, 2020 but was extended until December 31, 2020. However, the permitted departures from the CPE Standards were never intended to be long term but instead to assist in this emergency situation. And the NASBA made it perfectly clear that they would not extend the flexibility date beyond December 31, 2020:

Beginning January 1, 2021, we plan to revert back to our normal operating procedures for the National Registry of CPE Sponsors for applications and membership renewals and approved sponsors will be expected to comply with the requirements of the respective instructional delivery methods as detailed in the CPE Standards. If you plan to offer online training after December 31, 2020, then you will need to be approved for the Group Internet Based delivery method or have a pending application for that delivery method.”

Flexibility Provided by NASBA in 2020

For “Group Live only” sponsors, the flexibility related to the monitoring mechanism required for GIB-based programs is set out in Rule S16-04. This rule requires that GIB programs must employ some type of real time monitoring mechanism to verify that attendees are participating during the course. Evidently, firms were using platforms or tools that did not include reporting functionality of attendance or attendance checks such as polling or chat features. This requirement was suspended as long as firms took reasonable measures to monitor attendance, for example login / logout reports and screenshots of online participant lists taken periodically during the webinar.

For GIB sponsors, the flexibility provided by the NASBA is related to Rule S8-01. This rule requires that GIB-based programs must have a real time instructor while the program is being presented so that participants can ask questions. During the pandemic, firms were hosting live webinars and then just letting their professionals watch the reply without a real time instructor present. In such cases, the program becomes a self-study program (and that’s a whole other set of requirements). However, the NASBA said that as long as instructors respond to participant questions within 24-48 hours after watching the reply, then this requirement would be satisfied.

Any deviations from the Standards should be documented and such documentation should include the reasons for the deviation and the compensating controls used. If this documentation is available when such program or event is selected for compliance audit, then it would not be considered an audit failure.

Although the NASBA did not necessarily allow “Group Live only” sponsors to grant CPE under the GIB delivery method, they noted that most state boards of accountancy did permit flexibility during this time (New York and Maine being the exceptions). However, they required the certificate of completion to contain special language regarding the program delivery method such as Group Live presented online due to COVID-19.

Summary of Rules for the Group Internet Based Delivery Method

Additional flexibility was provided to Group Live only sponsors to continue to present Group Live programs in 2021 only if they (i) have a fully developed Group Internet Based course ready for the NASBA’s review and (ii) have submitted an Additional Delivery Method (ADM) application to the National Registry. Group Live only sponsors who do not meet the criteria above are not permitted to use this flexibility. 

Check out this site for the latest announcements from the NASBA.

So, minus the additional flexibility noted above, it’s back to following the rules for GIB programs! Do you know the rules? If not, no worries. We’ve summarized them below!

According to the Standards, a GIB program is:

Individual participation in synchronous learning with real time interaction of an instructor or subject matter expert and built-in processes for attendance and interactivity.”

Some things “stick out” in this definition:

• Synchronous learning – a group program in which participants engage simultaneously in learning activities. Watching a recorded webinar does not qualify!
• Real time interaction from an instructor – Participants need to be able to ask someone a question and get an immediate response. Again, watching a recorded webinar would not qualify.
• Built-in processes for attendance and interactivity – Examples include chat pods and polling questions.

Besides having a live instructor to answer questions, the biggest requirement specifically related to GIB programs is the real time monitoring mechanism to verify participants are participating in the course. This monitoring mechanism must be of sufficient frequency and lack predictability to ensure that participants have been engaged throughout the program. Also, this monitoring mechanism must employ at least three instances of interactivity completed by the participant per CPE credit. We use polling questions as the monitoring mechanism in our webinars

After the first full credit (Fun fact: Webinars must be at least 50-minutes long to qualify for CPE), additional monitoring mechanisms are required based on the additional credit amount of the program as follows:

Of course, GIB programs, like other delivery methods, also must have all the “normal stuff” required by the Standards such as:

• Learning objectives and appropriate learning activities for the prerequisite education, experience, and advance preparation listed on the program.
• Training materials that are developed by subject matter experts, which must be a CPA for audit or accounting CPE programs.
• Content is reviewed by a content reviewer not involved in the development.
• Inclusion of a post-course evaluation with the required questions as set out in the Standards.

Unlike self-study programs, GIB programs are not required to have:

• Knowledge check questions with appropriate feedback; or
• Post-course assessment questions.

If you’d like to dig into these rules a bit deeper, as well as learn how your firm can use webinars to train your people and grow your business, please join us for our free, CPE-eligible webinar this Thursday at 11:00am EST. Hope to see you there!

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Disclaimer  

This post is published to spread the love of GAAP and provided for informational purposes only. Although we are CPAs and have made every effort to ensure the factual accuracy of the post as of the date it was published, we are not responsible for your ultimate compliance with accounting or auditing standards and you agree not to hold us responsible for such. In addition, we take no responsibility for updating old posts, but may do so from time to time.