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March 2016

Surviving A CE Audit

This year marks the 40th anniversary for the film release of "Taxi Driver" where Robert De Niro delivers the iconic line, "Are you talkin' to me?" We bring this up because, yes, this month's article speaks directly to you concerning what every A/E licensed professional must understand about the auditing process.

During recent conversations with two separate jurisdiction licensing board executives, who routinely administer 20 audits per week, the following statements of caution were made: "It's bound to happen. A licensee will receive a CE audit notice from their licensing board. For some, upon the realization they have not met the requirement, this is a moment of despair. For others, who have taken advantage of record keeping services offered by various organizations, the CE audit is a breeze."

"Documentation: It's Your Responsibility
The key to a successful audit is documentation. Nearly all licensing boards place the responsibility for maintaining appropriate documentation on the licensee. This means adequate proof of completion of the requirements, as evidenced by a transcript or certificates of completion. These documents must clearly show that qualified coursework, offered by board-recognized providers, was completed within the appropriate time frame."

For example - the following language has been excerpted from a jurisdiction statute:

55-10-17-10 Licensee responsibilities

(a) The Architect or Landscape Architect is responsible for retaining proof of participation in continuing education activities. Such verification includes, the following as applicable:

(1) A log showing activity claimed, sponsoring organization, location, duration, etc. signed by the Sponsor; or
(2) Attendance certificates; or
(3) Signed attendance receipts; or
(4) Sponsor's list of attendees (signed by an individual in responsible charge of the activity).

As a reminder, the following is an example of CEU requirements Rules for a US licensing jurisdiction:

55-10-17-7 General course/program requirements

(d) Continuing education courses will be approved or disapproved by the Board based upon the information presented at the time of audit.

(e) To qualify for continuing education, the course must:

(5) Provide individual participant documents for record keeping and reporting.

55-10-17-9 Disallowance

(a) The Board has final authority with respect to approval of courses, credits, and continuing education hours

(b) If the Board determines through an audit, that continuing education hours are to be disallowed, an Architect or Landscape Architect shall have 30 calendar days after notification to substantiate the original claim or earn other continuing education hours to meet minimum requirements and submit documentation to the Board office. This section only applies to persons who met the requirements by the biennial deadline.

(c) Fraud or misrepresentation in certification of course attendance or any other aspect of fulfilling continuing education requirements will be disciplined in accordance with the Act, including revocation or denial of the renewal of License and/or Certificate of Authority, if applicable.

Each individual licensed professional is expected to know what qualifies as proof of completion within each jurisdiction. To protect the identify of several licensees the following case study examples names have been changed:

George A. submitted a credit card receipt and copies of PowerPoint slides as proof of completion, but this type of documentation is not accepted by the board, as this does not prove that he actually attended or completed the program. He was fined $500 by the board and his name appears in public records as having been disciplined.

Sam submitted a transcript with required number of hours. However, the transcript did not show enough Health Safety and Welfare hours because he had self-reported some of his hours to the professional association. Self-reported hours are not recognized by his licensing board. He was able to obtain certificates of completion from the providers showing the courses did have HSW credit and the hours were accepted by the board. No fine was issued.

Edith was audited and found to have completed only 8 of the 12 hours required annually. She was given 30 days to make up the missing hours. In addition, she will be subject to annual compliance audits for the next 3 years.

Joe did not complete any of his required hours in his state of registration. His license was suspended pending completion of the requirement and he was fined $1,500. He must also complete a course in ethics.

Now on a positive note, as stated by a licensing board executive "For others, who have taken advantage of record keeping services offered by various organizations, the CE audit is a breeze." is here to help you avoid serious professional licensing consequences including fines in excess of $30,000 plus legal fees, public embarrassment, probable additional tasks and scrutiny.


Facts, Fun, Quizzes and Quotes

"It takes less time to do a thing right than to explain why you did it wrong."

Quote By: Henry Wadsworth Longfellow


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