NASBA has noticed an alarming increase in compliance audit failures and wants to reverse this trend. As such and as previously announced, NASBA is implementing a new compliance desk audit policy in connection with the 2020 compliance desk audit cycle to institute financial penalties for audit failures. If a sponsor fails an audit, a penalty fee will be assessed to equal 25 percent of the most recent renewal fee paid by the sponsor. The penalty fee must be paid within 30 days of receipt of the failed audit report. Sponsors will continue to be required to submit a corrective action plan within 30 days, detailing how the deficiencies will be remediated.

Consistent with NASBA’s current policy, the sponsor will be subject to a follow-up audit to ensure corrective actions have been operationalized, and that the continuing professional education (CPE) program and supporting materials comply with the Statement on Standards for CPE Programs (Standards). Failure of a follow-up audit will result in immediate removal from the National Registry.

Given the current circumstances and the unprecedented impact of COVID-19, NASBA has delayed the start of the 2020 compliance audit cycle until September 1, 2020.

The compliance audit sample is selected at random. If you have been selected for a compliance audit, the main contact of the organization will receive an email notification. You will be required to acknowledge the notification and submit your program list for the period under audit. After receipt of the program list, additional instructions and information will be provided.

The most common causes for failure include:

• Inadequate attendance monitoring policies coupled with insufficient attendance monitoring documentation
• Incomplete or inaccurate information on the issued certificates of completion

We encourage sponsors to review their most recent renewal and the policies, procedures and documentation regarding CPE programs to ensure adherence to the Standards.

NASBA’s true hope is that there is not one failed audit penalty. However, this trend of noncompliance with the Standards must be disrupted, and it is believed that a financial penalty is the most effective deterrent.

Should you have any questions regarding compliance audit policy or any matters of compliance with the Standards, please reach out to any member of the National Registry team at cpe@nasba.org.