Compliance Responsibilities - Purchasing Content

January 2013

What are my compliance responsibilities if I (Registry sponsor) purchase content from an outside vendor?

CPE sponsors may purchase courses from other vendors or course developers. However, the organization whose Registry ID is included on the certificate of completion is ultimately responsible for compliance with the Statement on Standards for Continuing Professional Education (CPE) Programs (Standards) and NASBA requirements.

The Standards provide a framework for the development, presentation, measurement and reporting of CPE programs. There are more individual standards in the area of CPE program development than in the other categories, which demonstrates the importance and focus on CPE program development to ensure the highest quality of CPE for CPAs.

If a CPE program sponsor plans to issue certificates of completion under its name and Registry number, then the CPE program sponsor must first consider the purchased content based on whether the content was purchased from an entity registered with NASBA on the National Registry of CPE Sponsors.

If the content is purchased from another Registry sponsor, then it will be acceptable for the CPE program sponsor to maintain the author/developer and reviewer documentation from that Registry sponsor in order to satisfy the content development requirements of the Standards.

If the content is purchased from an entity not registered with NASBA on the National Registry, then the CPE program sponsor must independently review the purchased content to ensure compliance with the Standards. If the CPE sponsor does not have the subject matter expertise on staff, then the CPE sponsor may contract with a qualified individual to conduct the review. The CPE sponsor must maintain the appropriate documentation regarding the credentials/experience of both the course developer(s) and reviewer(s).

Need a quick reference guide to use for content considerations? Please use the following:

  1. Is the content based on learning objectives that are S.M.A.R.T? (Specific, Measurable, Alignment, Realistic and Time-oriented.)
  2. Is the program level appropriately classified?
  3. Are prerequisites and advanced preparation requirements clearly stated, and do they correspond with the program level?
  4. Is the most recent publication, revision or review date clearly stated? Tip: Courses that undergo frequent change must be reviewed once per year. Other courses must be reviewed at least every two years.
  5. Is the content developed and reviewed by qualified subject matter experts? Tip: One CPA must be involved in the development process for courses in the accounting and auditing field of study. A CPA, tax attorney or IRS Enrolled Agent must be involved in the development process for courses in the field of study known as taxes.
  6. For specific delivery methods, such as group Internet based or self study, does the content include all requirements (i.e., review questions for self study programs, monitoring mechanisms in group Internet-based programs)?         

For more details on program development requirements, please review the section on “Standards for CPE Program Development” of the 2012 Standards.

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