A Note to Group Internet Based Approved - COVID-19 Impact
Given the unprecedented nature of the COVID-19 pandemic and the government-imposed business closures and social distancing, CPAs are now performing their responsibilities to clients in a virtual manner. These professionals continue to seek out relevant, quality education on a variety of technical and non-technical topics. Event facilities and travel restrictions have forced conferences to be cancelled and postponed, causing an increasing demand for virtual learning events.
With the need for CPE sponsors to provide more virtual events in a quick timeframe, Group Internet Based approved sponsors have requested allowances with regard to certain matters in the Statement on Standards for Continuing Professional Education (CPE) Programs (Standards).
We request that sponsors do their best to adhere to the Standards. However, we understand that unanticipated circumstances may arise that make strict adherence to those Standards an impracticality. NASBA is providing flexibility to our Group Internet Based approved sponsors for certain matters as follows:
Matter 1 - Current Standard
S8-01. Real time instructor during program presentation. Group Internet based programs must have a real time instructor while the program is being presented. Program participants must be able to interact with the real time instructor while the course is in progress (including the opportunity to ask questions and receive answers during the presentation.) Once a group Internet based program is recorded for future presentation, it will continue to be considered a group Internet based program only when a real time subject matter expert facilitates the recorded presentation. CPE credit for a recorded group Internet based program facilitated by a real time subject matter expert will be equal to the CPE credit awarded to the original presentation.
S8-02. No real time instructor during recorded program presentation. A group Internet based program that is recorded for future presentation that does not include a real time subject matter facilitator is no longer a group Internet based program and will only be classified as a self-study program if it meets all self-study delivery method requirements, with the exception of the basis for CPE credit. CPE credit for a recorded group Internet based program not facilitated by a real time subject matter expert will be equal to the CPE credit awarded to the original presentation, or it may be determined by either of the two self-study credit determination methodologies described in Standard No. 17: pilot testing or the prescribed word count formula, at the sponsor’s discretion.
As a result of the current environment, some subject matter experts are unable to commit to being available on the date/time of their presentation and to additional re-broadcasts of the recorded presentation. The subject matter experts are interested in pre-recording their presentation and answering questions submitted by attendees within a 24-to 48-hour period.
NASBA is willing to grant flexibility to allow for pre-recorded programs to continue to be considered a Group Internet Based program as long as questions are answered within 24 to 48 hours by an individual demonstrating expertise through practical experience and/or education.
Matter 2 – Current Standard
S16-03. Monitoring mechanism for group Internet based programs. In addition to meeting all other applicable group program standards and requirements, group Internet based programs must employ some type of real time monitoring mechanism to verify that participants are participating during the course. The monitoring mechanism must be of sufficient frequency and lack predictability to ensure that participants have been engaged throughout the program. The monitoring mechanism must employ at least three instances of interactivity completed by the participant per CPE credit.
With the need to convert many in-person events to virtual meetings quickly, the CPE sponsor may need to use platforms or tools to conduct the training virtually that do not include reporting functionality of attendance or attendance checks such as polling or chat/”raise your hand” features.
NASBA is willing to grant flexibility around the requirement to maintain documentation of individual participation for 3 attendance monitoring mechanisms per one CPE credit. The sponsor must take reasonable measures regarding attendance monitoring for these events, understanding that attendance monitoring documentation may vary depending on the size of the event. Such attendance monitoring documentation may include participant log-in and log-out times for the event or screen shots of the onscreen participant lists periodically taken throughout the event.
All 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 will not be considered an audit failure.
This flexibility will be available for courses conducted until September 30, 2020. Depending on how the COVID-19 situation unfolds in the coming months, this timeline may be extended.
Should you have specific questions, please reach out to the National Registry team at firstname.lastname@example.org.