What are my compliance responsibilities if I (Registry sponsor) sell services to CPE providers?
A Registry sponsor may sell services to other CPE providers (including Registry and non-Registry sponsors). These services could include providing platforms for delivering group Internet-based or self study programs or a learning management system. 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.
When providing services to other CPE providers, 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 who is providing the course content.
If the content is provided by 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 provided by an entity not registered with NASBA on the National Registry, then the CPE program sponsor must independently review the course 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).
For more details on program development requirements, please review the section on “Standards for CPE Program Development” of the 2012 Standards.