What Sponsors Need to Know

Each year, the NASBA National Registry team conducts random compliance audits to verify that sponsor assertions comply with the Statement on Standards for Continuing Professional Education (CPE) Programs (Standards). For the past several audit cycles, Registry staff have noted deficiencies within the attendance monitoring procedures and the documentation to support those procedures for the group live instructional delivery method.

Why the emphasis on attendance monitoring and documentation? CPAs must report CPE credits to Boards of Accountancy in order to maintain and renew their licenses. Typically, state boards only review the CPE certificate, so it's vital that attendance procedures support the assignment of CPE credits as reflected on the certificate. When there are concerns about the attendance monitoring process, this may raise a red flag about the validity of the CPE credits. 

Listed below are the most common deficiencies in this area and guidance on how to remedy the deficiencies.

The Supporting documentation does not match the attendance monitoring procedures as described by the sponsor on the audit form.

Example

Sponsor described the attendance monitoring policy as using sign-in sheets and a room monitor. The submitted documentation was a registration list with no individual signatures and no attestation from the room monitor.

Corrective Action

In this situation, the expectation is to review the actual sign-in and sign-out sheet containing individual signatures. The room monitor should include an attestation on the form or the sponsor should clearly explain how the room monitor accounts for attendance on the audit form.

The supporting attendance documentation is incomplete.

Example

Sponsor used a scanning system and mobile application to monitor attendance. The scanning system only captures a scan-in time. The scanning system does not capture a duration time or a time out.

Corrective Action

In this situation, the scanning report is not sufficient as it lacks duration and time-out stamps and details on how the document is used to monitor late arrivals, early departures and extended breaks.

Sponsor allows the CPA to self-report CPE credits.

Example

This is commonly done using CPE forms that allow the CPA to check a box certifying they were in attendance for specific sessions. 

Corrective Action

A participant's self-certification of attendance alone is not sufficient. The sponsor must have a policy to monitor individual attendance to assign the correct number of CPE credits. A sponsor could add procedures, such as requiring attendees to record key words during training sessions, stickers provided at the conclusion of breakout sessions to include on the form as indication of attendance, or combine registration procedures with room monitoring.       

The written attendance policy lacked sufficient detail.

Example

The sponsor stated only that they use sign-in sheets.

Corrective Action

This attendance policy is insufficient. It does not provide the necessary details to understand how the sponsor is monitoring attendance. The policy should be expanded to detail if the participant must sign in and sign out at the beginning and conclusion of the program. Are there facilitators or room monitors present to verify that extended absences do not occur? How are late arrivals and early departures accounted?

Sponsor has contracted with a client to conduct a training program for the client's employees. The client is responsible for the registration and is unable to provide complete and compliant attendance documentation.

Example

Client provided only a registration sheet to the sponsor.

Corrective Action

The responsibility for monitoring attendance lies with the entity registered with NASBA. If the sponsor shares responsibilities related to NASBA compliance with the client, then the sponsor should clearly communicate compliance responsibilities directly to the client and a determination made as to how the attendance will be monitored and documented. The sponsor must have access to attendance records that are maintained by the client.