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What are reasons for compliance audit failures for the Group Internet Based delivery method?
In general, the most common reasons for failed compliance audits during 2019–2020 are a non-compliant attendance monitoring policy, the lack of attendance monitoring and the lack of sufficient supporting documentation of the attendance monitoring mechanisms by participants in Group Internet Based programs.
Standard. No. 16 of the Statement on Standards for Continuing Professional Education (CPE) Programs (Standards) requires sponsors to monitor individual attendance at group programs to assign the correct number of CPE credits. During a compliance audit, NASBA reviews the written attendance monitoring procedure and supporting attendance documentation to verify the appropriate amount of CPE credits were awarded.
Standard No. 16 also 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 could 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 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 so that, if contacted several months after the date of the program, a sponsor could reissue the certificate with confidence as to the individual's attendance and the correct amount of CPE credit earned at the program.
Rev Date 07/17/2020