Transition to New QAS Self Study Designation – Action Plan and Reminders

October 2013

The Statement on Standards for Continuing Professional Education (CPE) Programs (Standards), revised January 2012, raised the standards for all self study providers and eliminated the differences that previously existed between the QAS and Registry self study requirements. Accordingly, NASBA initiated changes to the administration of these programs to offer one designation for self study programs -- QAS Self Study. If you are a current QAS or Registry self study sponsor, there is a transition process to the QAS Self Study designation to ensure that the revised Standards have been implemented with respect to all of your self study program offerings.

As of October 1, 2013, we have approximately 130 QAS or Registry self study sponsors who either have a QAS transition application in process with NASBA or have not yet acted on the QAS transition.

We were hoping that sponsors would apply for the QAS Transition sooner and over the course of the transition time period.  The reality is that most applications will be submitted in the fourth quarter of 2013.  We have received numerous questions from sponsors on how we plan to handle to volume of applications as well as the “what ifs” related to the timing of application reviews.

We have created a plan to review and respond to these applications as efficiently as we can.  Our goal is to maintain the high standards of the National Registry without disrupting the marketplace and the availability of quality self study CPE for CPAs.

Our plan is as follows:

  1. As communicated consistently and frequently, all QAS transition applications (including those eligible for the “staged” approach) must be submitted and appropriate fees paid by December 31, 2013.  This means that the actual application with attached program materials and documentation for the program(s) selected by NASBA must be submitted by December 31, 2013.  Therefore, you should plan to submit a QAS Transition Initiation Form with a program list no later than November 1, 2013.  Once the initiation form is submitted, NASBA will select the program(s) for review and notify you of the program(s) as well as send you the link to the application.

    The QAS Transition Initiation Form will remain available until December 1, 2013.  In consideration of the time needed for NASBA to review and select programs and for sponsors to adequately complete the application, the QAS Transition Initiation Form will not be available subsequent to December 1, 2013. Therefore, if you have not submitted a QAS Transition Initiation Form and program list by December 1, 2013, you will not be able to receive and submit a QAS transition application.

    Any sponsor that does not submit a QAS transition application and payment as of December 31, 2013 will be removed from QAS and/or the Registry self study delivery method on March 1, 2014.  These sponsors may apply for reinstatement at a later date in accordance with standard procedures.
     
  2. In order to move more quickly to each application, NASBA will initiate a preliminary application review.  This review will focus on three primary elements: (1) CPE measurement methodology; (2) composition of the final examination; and (3) the learning objectives.  Our experience indicates that a failure in any one of these three elements usually results in other major deficiencies and, ultimately, a denial on the transition application.

    If there is a failure in any one of these three elements, the sponsor will be notified that the minimal requirements have not been met to further the application for review.  The sponsor will be notified of the preliminary review deficiencies and referred to resources to review and consider prior to re-applying for the transition.
     
  3. We have added additional staff to help manage the number of applications we anticipate receiving at the end of this transition process.
     
  4. We will extend the acceptability of the QAS and Registry self study designations for those sponsors who applied for the QAS transition as of December 31, 2013.  Any sponsor that submitted a QAS transition application and payment by December 31, 2013 will remain a QAS and/or Registry self study sponsor until NASBA has completed the review of the sponsor’s transition application, which will be completed by NASBA prior to December 31, 2014.

After December 31, 2013, any sponsor that receives a denial on its QAS transition application will be removed from QAS and/or the Registry self study delivery method.  The sponsor will be allowed to apply for reinstatement; however, the reinstatement application will go to the end of the queue of QAS self study applications.

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