Impact of COVID-19
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.
We are currently reaching out to state boards of accountancy (boards) to gather information and guidance regarding the CPE requirements and the acceptance of CPE events that are changing due to COVID-19.
If you have an event planned in the very near future and you have a concentration of CPA attendees in a particular state, we recommend that you reach out directly to that board for guidance. You may find the contact information for each of the state boards of accountancy at the following link: https://nasba.org/stateboards/
We are accumulating responses from the boards and will post that information below as we receive it.
We understand the challenges you face as you navigate these difficult times and appreciate your patience as we try to assist you and the CPAs you serve.
Information is being gathered and will be posted here and updated regularly.
Issued June 22, 2020
The National Registry of CPE Sponsor has been providing flexibility to “Group Live only” approved sponsors, allowing for in-person events to be modified and offered online as a result of COVID-19. The timeframe for flexibility was granted from March 13, 2020 until September 30, 2020.
Given the current circumstances with government-imposed social distancing requirements and indications of continued concern to hold in-person events through the remainder of the calendar year, we are extending the flexibility to “Group Live only” sponsors until December 31, 2020.
We strongly encourage our sponsors that are only approved for the Group Live delivery method to apply for either the Group Internet Based or QAS Self Study delivery methods to be prepared for remote training in the instance that COVID-19 or some other circumstance becomes a disruptor in the future.
We have experienced a significant influx of applications for the Group Internet Based and QAS Self Study delivery methods. We are working diligently to review all applications. Please remember that the more the documents and program materials submitted with the application adhere to the Statement on Standards for CPE Programs (Standards), the more quickly we can complete the application review process.
In addition to providing flexibility to our “Group Live only” approved sponsors, we have provided some allowances with regard to certain matters in the Standards for Group Internet Based approved sponsors. We will also extend this flexibility through December 31, 2020.
We again emphasize that sponsors should do their best to adhere to the Standards. However, we understand that unanticipated circumstances may arise that make strict adherence impractical. All deviations from the Standards must be documented and such documentation should include the reasons for the deviation and the compensating measures taken.
For more detailed information, please see the respective sections below.
Group Live Providers
The National Registry team has been receiving a constant stream of emails and calls from CPE providers that are approved on the National Registry as Group Live providers, but because of the recent travel and public gathering restrictions as a result of COVID-19 need to cancel in-person events and provide them online instead. Because the CPE provider is not approved on the National Registry for the Group Internet Based delivery method, we are not in a position to allow those sponsors to issue certificates of completion for the group internet based delivery method without completing the application and review process.
The following table identifies the jurisdictions that have responded to provide guidance as to whether their CPE rules provide for flexibility in the instructional delivery method of a program due to these special circumstances. If you have specific questions, please reach out to the state board of accountancy directly.
Many boards have recommended that the certificate of completion for the affected program contain special language regarding the program delivery method such as "group live presented online due to COVID-19."
We also strongly recommend that CPE program sponsors take reasonable and appropriate measures regarding attendance monitoring for these modified events.
The recommended timeframe that this flexibility will be available is for programs conducted from March 13, 2020 through September 30, 2020. Depending on how the COVID-19 situation unfolds in the coming months, this timeframe may be extended.
NOTE: Updated 06/22/2020 11:00 am CDT - The flexibility to "Group Live only" sponsors has been extended until December 31, 2020.
Table Updated: 04/29/2020 9:30 am CDT
|State||Rules Allow for Flexibility||Prohibits Flexibility|
Group Internet Based Providers
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.
NOTE: Updated 06/22/2020 11:00 am CDT - This flexibility has been extended until December 31, 2020.
CPE Reporting Periods
Please check back frequently for future updates.
We have received numerous inquiries from Boards of Accountancy, CPE providers and licensees about upcoming CPE reporting deadlines. After careful consideration of the impact that COVID-19 has had on everyone and after consultation with the AICPA, we recommend to Boards of Accountancy that have CPE reporting years ending on or before October 31, 2020, to consider offering a grace period for those licensees to meet their CPE requirements until October 31, 2020. Boards may also have to consider adjustments to any attestations that are required as part of license renewal process. It may also be beneficial to place a notification of waivers on Board websites.
Under the above scenario, if a CPA’s reporting period ended on March 31, 2020, the licensee would have until October 31, 2020, to complete the CPE requirements for that reporting period. Similarly, if a CPA’s reporting period ended on June 30, 2020, the licensee would have until October 31, 2020, to complete the required CPE.
The use of a grace period would allow licensees adequate time to adjust their continuing education learning methods due to recent cancellation of conferences and live CPE events across the country, and to meet the growing demands of their clients during this difficult time. It would also allow Boards of Accountancy the time to assess the impact COVID-19 has had on their operations and to prioritize important board activities.
This is NASBA’s recommendation; however, each Board of Accountancy has the final authority on the CPE requirements and requirements for licensure renewal.
The following table identifies the jurisdictions that have provided additional guidance related to upcoming CPE reporting periods. For specific details, please refer to the respective Board of Accountancy website. You may find the contact information for each of the state boards of accountancy at the following link: https://nasba.org/stateboards/
Table Updated: 06/12/2020 8:00 am CDT
|State||Reporting Period Type||Current Period End||CPE Change?||Summary||
Notes Regarding COVID-19 CPE Changes
|Alabama||Annual||09/30/2020||No||Removed the Cap on Self Study Hours||The Alabama BOA reminds licensees that effective October 1, 2019, that the CPE rules were changed to remove the cap on self-study hours, allowing all 40 hours of CPE to be completed by self-study hours.|
|Arizona||Biennial Fixed||Birth Month||Yes||Grace Period through 10/31/2020||The 16-hour requirement for Live/Interactive Webinar will still be enforced. All impacted CPAs have been notified of the Executive Order and their ability to request an extension as a part of their renewal. If a CPA requests a CPE extension for good cause related to COVID they will be given an extension through October 31.|
|California||Biennial Fixed||Birth Month||Yes||Grace Period through 11/4/2020||On May 4, 2020, pursuant to the Governor’s Executive Order N-40-20, the Director of the California Department of Consumer Affairs (DCA) extended the deadline to complete required continuing education (CE) for licensees of the CBA (and various other DCA boards) whose license expired in March, April, or May 2020. These licensees who have yet to complete their required CE and submit their CE worksheet to the CBA have until November 4, 2020 to do so.|
|Connecticut||Annual||06/30/2020||Yes||Grace Period through 12/31/2020||The Connecticut State Board of Accountancy has extended the deadline for CPE to December 31, 2020.|
|Delaware||Biennial Fixed||06/30/2021||No||No Changes||The CE Extension notification is only relevant to professions that are renewing while we are under a state of emergency during the COVID crisis. Because CPA’s renew next year, we are not addressing the extension to them at this time. Our hopes are that the state of emergency will be lifted well before then and would not apply to our CPA’s. However, in the event that it carries over, we will let the board and licensees know in advance so that they can prepare.|
|Florida||Biennial Fixed||06/30/2020||Yes||Grace Period through 12/31/2020 Without Requiring Additional Credits||For the reestablishment period ending June 30, 2020, current active licensees who complete continuing professional education (CPE) hours by December 31, 2020 are not required to complete the additional CPE hours referenced in this subsection. CPE hours approved for this extension shall apply solely to the reestablishment period ending June 30, 2020.|
|Iowa||Triennial Rolling||06/30/2020||Yes||Self Study Limitation is Removed through 5/27/2020||The limit of online self-study has been lifted for the period of time as allowed by the Governor. Now through (updated) May 27, 2020, 100% of continuing education acquired may be online self-study. This provision may be extended for a longer period of time.|
|Kansas||Biennial Fixed||06/30/2020||No||No Changes||The Board has received a few, not many, inquiries regarding extensions for continuing education requirements for those permits expiring on June 30, 2020, due to cancellations of in-person seminars because of the COVID19 Virus. We assure you that we recognize and understand that these are trying times for everyone and that this is a fluid situation. To that end, we are, at this time, advising permit holders who renew this year that there will be no extension of time to obtain continuing education.|
|Maryland||Biennial Fixed||Expiration Date||Yes||Grace Period through 10/31/2020||Licensees with expiration dates of 3/13/2020 – 10/30/2020 may carry back any credits earned following the end of these periods through 10/31/2020 back to the previous reporting period.|
|Massachusetts||Biennial Fixed||06/30/2020||Yes||Grace Period through 9/30/2020||
Because of the current declared state of emergency in Massachusetts, all licensees whose individual or firm licenses expire on June 30, 2020 are allowed through September 30, 2020 to renew online without being assessed a late fee.
|Michigan||Biennial Fixed||06/30/2021||Yes||Removing Self Study Limitation for Year Ending 6/30/2020||
Given the current national emergency related to COVID-19 and also the state of emergency as declared by Governor Whitmer on March 10, 2020, including her most recent Executive Order 2020-21 (COVID-19) issued yesterday for Michiganders to "Stay Home, Stay Safe" to prevent the spread of the Coronavirus (COVID-19), the Michigan Department of Licensing and Regulatory Affairs (LARA) has recognized that the traditional in-person delivery of CPE is not possible and in conflict with the CDC recommendations and other authoritative orders.
From now through the end of the education cycle on June 30, 2020, the State of Michigan will recognize CPE that is taken through all electronic means, including webinars, self-study, e-learning, etc. relative to fulfillment of CPA license renewal requirements for accounting and auditing (A&A), ethics (including Michigan-specific ethics) and general education hours.
|Minnesota||Triennial Rolling||06/30/2020||Yes||Allowing 3 Months (July - September 2020) of Carry Back Without Late Fee||
Board Extends CPE Earning Period for CPE Year FY20 Until September 30
||The Board voted to extend the deadline on the current CPE period from June 30, 2020 until October 31, 2020. This blanket extension will provide our licensees with 16 months to obtain the required 40 hours of CPE. Accordingly, the online CPE reporting due date will be extended from August 1, 2020 until December 1, 2020. Additionally, carryover hours into the subsequent 8-month CPE period (scheduled to end on June 30, 2021), has been increased from 20 hours to a 40 hour maximum.|
|Nebraska||Biennial Fixed||12/31/2020||No||No Changes||https://nbpa.nebraska.gov/sites/nbpa.nebraska.gov/files/doc/pressreleasalicrenewals320_0.pdf|
|New Hampshire||Triennial Fixed||06/30/2020||Yes||CPE Requirements Waived for Period Ending 6/30/2020||Governor Sununu issued Exhibit H to Executive Order #29, 5/19/20. Section I (first one) applies to all Boards under the OPLC, including the Board of Accountancy. This changes the Board’s previous executive order re: CEU requirements. All CEU requirements are waived for those renewing March 13, 2020 – December 31, 2020. No waiver request needed.|
|North Dakota||Triennial Rolling||06/30/2020||Yes||Grace Period through 9/30||The North Dakota State Board of Accountancy has a reporting deadline of 6/30. They have approved a blanket extension for all licensees until 9/30.|
|Oregon||Biennial Fixed||06/30/2020||No||No Changes.||CPE Concerns: We understand that some if not most CPE live courses have been cancelled. At this time we encourage licensees to seek online courses to ensure you obtain the required hours for renewal. As of March 16, 2020 the Board is not granting exceptions to the annual requirement. Failure to meet CPE requirements will result in a CPE penalty.(16-hours for active licensees and 8-hours for inactive licensees). The Board will periodically reassess and post on our website any changes.|
|Pennsylvania||Biennial Fixed||12/31/2021||Yes||Removed Self-Study Limit||The governor granted a suspension of restrictions that limited the ability of licensees to take classes online or participate in distance-learning opportunities for the current biennial renewal period to permit all licensees to complete their continuing education online during the COVID-19 pandemic. This suspension applies to the CPE reporting period from January 1, 2020 through December 31, 2021.|
|South Carolina||Annual||12/31/2020||No||No Changes||In regards to CPE reporting, it is still early in the reporting period, so this is not something that we have enough information to address at this point. The Board will continue to monitor the COVID19 situation as it unfolds and will take appropriate action on this issue, if necessary.|
|Tennessee||Biennial Fixed||12/31/2020||No||No Changes||While live in person CPE is not currently available due to the COVID-19 pandemic, many conferences and seminars which were scheduled to take place in a classroom setting have migrated to virtual online events (webinars). The continuing education rules in Tennessee do not limit the number of hours obtained through self-study and/or online learning methods, thereby allowing all 80 hours to be obtained using these distance learning methods, with limited exceptions.|
|Texas||Triennial Rolling||Birth Month||Yes||Grace Period through August 2020||Continuing professional education (CPE) extensions will be automatically granted for 90 days to
complete your required credits. However, we still encourage you to complete your CPE as soon as possible. If your in-person CPE courses are being delayed or canceled, please consider online CPE providers and options to bridge any near-term gaps in needed credits.
UPDATE: Continuing professional education (CPE) extensions will be automatically granted through August 2020 for May, June, and July individual license renewals. However, we still encourage you to complete your CPE as soon as possible. If your in-person CPE courses are being delayed or canceled, please consider online CPE providers and options to bridge any near-term gaps in needed credits.
|Vermont||Biennial Fixed||07/31/2021||No||No Changes at Present||The Office of Professional Regulation has instituted a policy that will allow a continuing education renewal extension up to 180 days. The extensions are only in effect at renewal time and cannot be granted prior to the renewal opening. CPAs renew in July 2021. IF in July 2021, we are still in a pandemic there will be instruction given at renewal. Until then, CPAs should try to complete their CPE in a timely manner.|
|West Virginia||Triennial Rolling||12/31/2020||No||No Changes||Since the deadline for filing CPE Reports for the 2019 calendar year was January 31, 2020, no extension of time is necessary.
CPA license and firm permit renewals will be available through our online payment system on May 1, 2020. The renewal deadline of June 30 is set by Board statute. To date, the Governor has not issued an Executive Order extending the deadline set forth in that statute. However, for extenuating circumstances, the Board will consider requests for an extension of time to complete a renewal and approve on case-by-case basis.