What are my compliance responsibilities if I (Registry sponsor) have contractual arrangements with clients?
The Statement on Standards for Continuing Professional Education (CPE) Programs (Standards) provide a framework for the development, presentation, measurement and reporting of CPE programs. CPE sponsors have flexibility in how to achieve compliance with the Standards; however, the organization whose Registry ID is included on the certificate of completion is ultimately responsible for compliance with the Standards and NASBA requirements.
If a CPE program sponsor is going to issue certificates of completion under its name and Registry number, then the CPE program sponsor must maintain proper attendance records evidencing the Registry ID number provided on the certificate of attendance. The scenarios below describe the proper application of the Standards in circumstances where programs are provided in-house to a client’s employees and the certificates of completion will be issued under the CPE program sponsor’s Registry ID number.
Scenario 1: Promotion or announcement of client training events
A Registry sponsor enters into a contract with a client to hold a CPE session for the client’s employees. In the contract, the Registry sponsor and client agree to learning objectives and activities for the program and agree to compensation for the event based on the number of participants. The Registry sponsor will conduct the training if one or the maximum number of participants per the contract attends. The client may make the CPE program mandatory. Those factors do not remove the responsibility of the Registry sponsor to comply with Standard No. 9, which requires certain information be provided to enable the CPA to assess the appropriateness of learning activities. The Registry sponsor must either provide the required information directly to the participants or to the client to distribute to the participants.
If the participants of the program are employees of the client, then the Registry sponsor may use the requirements of internal training courses to provide program descriptive materials to participants. For reference, sample compliant templates of program descriptive materials (promotional/course announcement materials) may be found on the Registry Forms and Applications page (located at the bottom of the page).
Scenario 2: Monitoring attendance and issuing certificates of completion
The set-up is the same as Scenario 1. The Registry sponsor will be compensated whether one or the maximum number of participants per the contract attends. The Standards place the responsibility of attendance monitoring on the sponsor. In addition, the Standards require that the Registry sponsor maintain records of participation, dates and locations of programs and number of CPE credits earned by participants. A best practice is to provide a sign-in and sign-out sheet at the session and have the client submit the attendance record to the Registry sponsor at the end of the learning event. The Registry sponsor will then issue the CPE certificates of completion and provide them to the client to distribute to the participants. The Registry sponsor should not provide the client with a certificate of completion template to generate certificates on their own.
For more details on sponsor responsibilities in attendance monitoring and issuing the certificate of completion, please review Standard Nos. 13 and 18.