Continuing Professional Education and Development Exposure Draft

IFAC
Education
June 2002
Exposure Draft
Response Due Date December 31, 2002
Committee
Continuing Professional
Education and Development
Proposed International Education
Guideline for Professional Accountants
Issued for Comment by
the International
Federation of Accountants
This Exposure Draft was approved for publication in May 2002 by the
Education Committee of IFAC.
The mission of IFAC is the worldwide development and enhancement of
an accountancy profession with harmonized standards, able to provide
services of consistently high quality in the public interest. The Education
Committee’s mission is to serve the public interest by the worldwide
advancement of education and development for professional accountants
leading to harmonized standards.
The Education Committee requests comments on this Exposure Draft.
Respondents are encouraged to comment on the specific questions
attached at the end of this document and any other issues related to this
Exposure Draft. Comments sent by email are preferred but they may also
be submitted by computer disk or in hard copy.
Comments should be received by 31 December 2002.
Comments received by the due date will be reviewed by the Education
Committee and may influence the final Guideline. Comments received
before 15 October 2002 will be reviewed by the Education Committee at
its November 2002 meeting. Comments received after that date will be
reviewed by the Committee in March 2003.Notwithstanding this,
comments received after the due date and on an ongoing basis are also
welcome. Respondents should note that comments are considered a matter
of public record.
Comments on this publication should be sent to:
Technical Director
International Federation of Accountants
535 Fifth Avenue, 26th Floor
New York, NY 10017, USA
Fax + 1 212-856 9420
E-mail responses should be sent to: EDComments@ifac.org
Information about the International Federation of Accountants can be
found at its website, www.ifac.org. Copies of this publication may be
downloaded free of charge from the site.
Copyright © June 2002 by the International Federation of Accountants.
All rights reserved.
CONTENTS
PAGE
PREFACE .......................................................................................... 2
INTERNATIONAL EDUCATION GUIDELINES FOR
PROFESSIONAL ACCOUNTANTS .................................................. 2
PURPOSE OF THE GUIDELINE ...................................................... 2
SCOPE OF THE GUIDELINE ........................................................... 2
BACKGROUND .............................................................................. 3
DEFINITIONS ................................................................................... 3
FOREWORD ..................................................................................... 9
ACKNOWLEDGEMENTS............................................................... 11
AVAILABILITY OF CPD ............................................................... 12
APPROPRIATE SUBJECT AREAS ................................................. 13
MINIMUM LEVEL OF CPD........................................................... 15
INPUT- AND OUTPUT-BASED SYSTEMS..................................... 17
COMPLIANCE PROCESS AND RESPONSES TO NONCOMPLIANCE ................................................................................ 19
Continuing Professional Education and Development
Proposed International Education Guideline for Professional Accountants
Preface
International Education Guidelines for Professional Accountants
1.
International Education Guidelines for Professional Accountants
(IEG) assist in the implementation of generally accepted good
practice in the education of professional accountants by
providing advice or guidance on how to achieve good practice or
current best practice.
2.
International Education Guidelines for Professional Accountants
may interpret, illustrate, elaborate, or expand on matters related
to International Education Standards for Professional
Accountants. In this function, the Guidelines assist member
bodies to implement and achieve ‘good practice’ as prescribed in
International Education Standards for Professional Accountants.
The Guidelines may also recommend practice that is wider or
deeper than the practice prescribed in a Standard. Alternatively,
they may outline exemplary methods or practices, including
those that are recognized as current ‘best practice’, which
member bodies may wish to adopt.
Purpose of the Guideline
3.
This Guideline is intended to assist member bodies in
establishing a requirement for an effective program of continuing
professional education and development (hereafter referred to as
continuing professional development or CPD) for members, as
prescribed in the proposed International Education Standard,
“Continuing Professional Education and Development”.
Scope of the Guideline
4.
This guideline:

2
addresses the objectives of CPD; the subject areas that
should be viewed as consistent with those objectives; and
the extent of the CPD commitment appropriate for
professional accountants in public practice, industry,
commerce, education and the public sector;
Definitions

explains the importance of mandatory CPD for all member
bodies on a worldwide basis;

explains the necessity of appropriate corrective and
disciplinary mechanisms to assure compliance with CPD
requirements;

assists in the implementation of the proposed International
Education Standard, “Continuing Professional Education
and Development”.
Background
5.
The IFAC Education Committee has for many years issued
guidelines and other papers on education issues. Previously, the
Committee released IEG 2, “Continuing Professional Education”
(February 1982, revised May 1998). The Committee considers
that it is now appropriate to issue individual Standards building
on this framework, by dealing with each major topic in a
separate Standard. In addition, Guidelines will also be developed
to support the Standards where necessary, providing advice,
guidance and examples to assist member bodies in implementing
good practice as prescribed by the Standards.
6.
This Guideline supports the proposed International Education
Standard,
“Continuing
Professional
Education
and
Development”, released as an Exposure Draft in July 2002,
providing further elaboration and interpretation of the standards.
Definitions
7.
Terms marked with an asterisk (*) indicate terms that are defined
elsewhere in this glossary.
Best practice
Refers to practices considered to be exemplary, of the
highest order, the most advanced, or leading in a
particular area in the education* of professional
accountants.
Explanation
“Best practice” refers to the best examples of
established practice in the preparation of professional
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Continuing Professional Education and Development
Proposed International Education Guideline for Professional Accountants
accountants. “Best practice” will often go beyond
“good practice” and, as such, is at a higher level than
the considered minimum requirements. Statements and
examples of “best practice” are essential for the
advancement of accounting education and provide
useful guidance to member bodies for the continual
improvement of their education programs.
Capabilities
Are the professional knowledge, * skills* and
professional values* required to demonstrate
competence*.
Explanation
Capabilities include content knowledge, technical and
functional skills, behavioral skills, intellectual abilities,
and professional values and attitudes.
Competence
Is being able to perform a work role to a defined
standard, with reference to real working environments.
Explanation
Competence may be assessed by a variety of means,
including work place performance, work place
simulations, written tests of various types and selfassessment.
Continuing
professional
development
(CPD)
Refers to learning* activities for developing the
capabilities* of individuals to perform competently
within their professional environments.
Explanation
Continuing professional development is aimed at the
post-qualification maintenance or enhancement of
professional competence. It involves the development
of capabilities through either formal, structured and
verifiable learning programs (sometimes referred to as
‘continuing professional education’ – CPE) or
informal, unstructured learning activity.
4
Definitions
Development
Is the acquisition of capabilities* which contribute to
competence.*
Explanation
Development refers to the growth of attributes that
contribute to competence, however achieved.
Individuals may develop their abilities through a wide
range of processes such as learning, including
education and training; experience; reflection;
observation or receipt of information; other structured
and unstructured learning activities; or through
natural growth over time.
Education
Refers to a systematic act or process aimed at
developing knowledge, skills*, character, or other
abilities and attributes within individuals. It includes
developmental activities commonly referred to as
training*.
Explanation
Education is a formal, structured learning process
whereby individuals develop attributes considered
desirable by society. Education is usually
characterized by the growth of an individual’s mental
and practical abilities, as well as maturing in attitude,
resulting in an enhanced ability of the individual to
function and contribute to society, in either specific or
non-specific contexts. While often conducted in
academic environments, education also includes
formal learning processes in other environments, such
as on-the-job and off-the-job training. Education is, by
nature, formal and therefore excludes informal,
unstructured learning and developmental processes.
Valuable learning, training, and development can also
take place in less formal environments through
processes that are not formal or structured enough to
be considered ‘education’.
Ethics
Refers to the professional values* and principles of
conduct applying to professional accountants* as well
as to students* and trainees* associated with the IFAC
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Continuing Professional Education and Development
Proposed International Education Guideline for Professional Accountants
member bodies.
Good Practice
Refers to those elements considered essential to the
education* and development* of professional
accountants* and performed at a standard necessary to
the achievement of competence. *
Explanation
“Good practice” relates not only to the range of
content and processes of education and development
programs, but also to the level or standard at which
they are performed (i.e. the depth and quality of the
programs). The IFAC Education Committee is
conscious of the wide diversity of culture; language;
and educational, legal, and social systems in the
countries of the member bodies and of the variety of
functions performed by accountants. Different factors
within these environments may vary the ability of
member bodies to adopt some aspects of “good
practice”. Nevertheless, member bodies should
continuously aspire to “good practice” and achieve it
wherever possible.
Information
technology
Refers to hardware and software products, information
system operations and management processes, and the
human resources and skills* required to apply those
products and processes to the task of information
production and information system development,
management and control.
Learning
Refers to a broad range of processes whereby an
individual develops capabilities,* including skills* and
attitudes in the application of knowledge.
Explanation
Learning can be achieved by formal processes such as
education (including training) or informal processes
such as day-to-day work experience, reading published
material, passive observation, and reflection
6
Definitions
Learning Plan
Refers to structured processes that help professional
accountants guide their professional development.*
Plans include a self-assessment of the gap between
current and needed knowledge, skills,* and abilities, a
set of learning objectives arising from this assessment,
and learning activities to be undertaken to fulfill the
learning plan.
Postqualification
Refers to a broad range of processes whereby an
individual develops capabilities,* including skills* and
attitudes in the application of knowledge.
Explanation
The term ‘post-qualification’ is usually associated with
activities and requirements relating to the professional
development of those who have already obtained a
professional qualification. It is often associated with
action relating to the maintenance or further
development of professional competence.
Professional
accountant
Refers to those individuals, whether they be in public
practice (including a sole practitioner, partnership or
corporate body), industry, commerce, the public sector
or education, who are members of an IFAC member
body.
Professional
knowledge
Refers to those topics that make up the subject of
accountancy as well as other business disciplines that,
together, constitute the essential body of knowledge for
professional accountants.*
Professional
values
Are the attitudes that identify professional
accountants* as members of a profession. They
comprise principles of conduct generally associated
with, and deemed essential in defining the distinctive
characteristics of, professional behavior.
Explanation
Professional values include technical competence,
ethical behavior (e.g. independence, objectivity,
confidentiality, and integrity), professional demeanor
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Continuing Professional Education and Development
Proposed International Education Guideline for Professional Accountants
(e.g. due care, timeliness, courteousness, respect,
responsibility, and reliability), pursuit of excellence
(e.g. commitment to continual improvement and lifelong learning), and social responsibility (e.g.
awareness and consideration of the public interest).
Skills
Refer to the various types of abilities required to apply
knowledge and values appropriately and effectively in
a professional context.
Explanation
Professional accountants are required to possess a
range of skills, including technical and functional
skills, organizational and business management skills,
personal skills, interpersonal and communication
skills, a variety of intellectual skills, and skills in
forming professional judgments.
Specialization
Is the formal recognition by a member body of a group
of its members possessing distinctive competence* in a
field, or fields, of activity related to the work of the
professional accountant.
Structured
learning
Is measurable, verifiable activity designed to impart
specific knowledge and skills.*
Explanation
Examples of structured learning include courses and
presentations; individual study programs that require
some completion by the individual; and participation
in formal conferences, briefing sessions, or discussion
groups. Structured learning is usually, in some
respects, not totally within the control of the individual
undertaking the learning. For example, a third party
may determine the scope or design of the activity, or
when or how the learning takes place.
Training
8
Refers to pre- and post-qualification* developmental
activities, within the context of the work place, aimed
at bringing a student* or professional accountant* to an
agreed level of professional competence.*
Explanation
Training includes work place-based education and
experience activities for developing an individual’s
competence to perform tasks relevant to the role of the
professional accountant. Training may be undertaken
while performing actual tasks (on-the-job training) or
indirectly through instruction or work-place simulation
(off-the-job training). Training is conducted within the
context of the work place, with reference to the specific
roles or tasks performed by professional accountants.
It can include any activity purposefully designed to
improve the ability of an individual to fulfill the
practical experience requirements for qualification as
a professional accountant.
Foreword
8.
Readers are referred to the proposed International Education
Standard
“Continuing
Professional
Education
and
Development”. Member bodies are expected to consider that
Standard in establishing CPD requirements. If CPD is a
legislated matter, member bodies are expected to advise
legislators of the international standard and strive for full
compliance.
9.
This pronouncement provides guidelines for the establishment
and enforcement by member bodies of an effective program of
CPD.
10.
The knowledge needed to function effectively as an accountant
in public practice, industry, commerce, education and the public
sector continues to expand and change at a rapid rate. This trend
is certain to continue. For example, there have been significant
changes in the environment in which accountants operate. These
include changes in accounting and auditing standards, new
legislation and regulation affecting the profession and the people
and organizations it serves, increasingly complex tax systems
and rules, and the ongoing development and greater use of
sophisticated financial instruments. These changes have been
9
Continuing Professional Education and Development
Proposed International Education Guideline for Professional Accountants
accompanied by the widespread use of technology, Internet
services and the everyday use of quantitative methods.
11.
10
Not only are accountants facing increased knowledge
requirements, but they and their professional associations are
also facing increased public expectations about the quality of
financial statements and independent audits. Related pressures
for disclosure of more information, some assurance on interim
financial statements and greater use of forecasts have had an
impact on management accountants and independent auditors
alike. In addition, the need to be competitive in a worldwide
economy has prompted a more intense focus on the role and
responsibilities of the management accountant in entities of all
types. Finally, there is an increasing interest around the world in
achieving greater public accountability by the business and
financial communities, as well as the public sector, and
accountants in all sectors have important contributions to make
to that process. All of this places a special responsibility on
accounting educators. The effectiveness of national CPD
programs is and will continue to be a significant factor in any
discussions related to international reciprocity.
Acknowledgements
Acknowledgements
The Education Committee thanks the Task Force members who have
contributed to the development of this Guideline:
Country
Canada
China
Malaysia
United States
Transnational Auditors Committee
Name
Shirley Reilly, Steven J Glover,
Robert W Dye
Shuang Li, WeiHua Liu
Dato Abdul Halim Mohyiddin, Tan
Shook Kheng and Albert Wong
Mun Sum
Gary Holstrum Beatrice Sanders,
Charles H Calhoun III
Melvin Berg (observer to the
Education Committee)
Membership of the IFAC Education Committee
The following were members of the Education Committee when this
Guideline was approved:
Country
New Zealand
Argentina
Canada
China
Czech Republic
France
Hungary
Israel
Malaysia
Pakistan
South Africa
Thailand
Turkey
United Kingdom
United States
Name
Warren Allen (Chair)
Hector Carlos Ostengo
Shirley Reilly
Shuang Li
Bohumil Král
Alain Burlaud
József Rooz
Yoram Eden
Abdul Halim Mohyiddin
S.M. Zafarullah
Steve McGregor
Usana Patramontree
Masum Türker
David Hunt
Gary Holstrum.
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Continuing Professional Education and Development
Proposed International Education Guideline for Professional Accountants
Availability of CPD
12.
IFAC member bodies should help their members meet the CPD
requirement prescribed by the proposed International Education
Standard,
“Continuing
Professional
Education
and
Development”, by facilitating access to CPD activities that
maintain and improve members’ technical and professional
skills.
13.
Member bodies should either directly provide relevant CPD
programs for their members or facilitate access to programs
offered by others (e.g., commercial providers, other professional
bodies, other member bodies, universities and colleges, etc.).
Relevant CPD
14.
Relevant CPD:
a)
maintains or enhances current professional competences for
their members;
b) assists members of the profession to apply new techniques,
understand economic developments and evaluate their
impact on their clients or employers and on their own work,
and to meet changing responsibilities and expectations; and
c)
serves the public interest by providing reasonable assurance
that members of the profession are competent to perform the
services they undertake to provide.
Objective of CPD
15.
The Code of Ethics states that it is the professional duty of the
individual members not only to maintain professional
competence, but also to strive continually to improve their
competence. Thus, the objective of CPD programs should be
continual improvement, not merely maintaining some minimum
knowledge level.
16.
Although maintaining and improving technical knowledge is one
objective of CPD, CPD should go beyond technical knowledge.
Appropriate subject areas for CPD are addressed later in this
Guideline.
12
17.
Clients and employers not only expect expert technical
knowledge from professional accountants but also that
accountants should be able to advise them on the impact of
changes in the economic and business environment. Such
changes may well affect the judgments and estimates
accountants make in the process of preparing financial
statements or performing other professional tasks. They may also
affect the nature, timing and extent of an auditor’s procedures.
Therefore, the business plans and strategies of clients or
employers may need to be revised when there are changes in the
economic and business environment. A professional accountant
is expected to constantly monitor business risks, threats and
opportunities. For these reasons, a program of CPD established
and operated by a member body or other parties should give
appropriate consideration to educational needs that go beyond
basic technical knowledge.
Appropriate subject areas
18.
CPD should contribute to the professional ability of individual
members. Therefore, acceptable CPD activities should be
relevant to the professional work of each member. Some member
bodies may choose to mandate specific topics for a program of
CPD. Others may choose to rely on their individual members to
select subject areas that are appropriate for them. In some
circumstances (e.g. for licensing purposes or for specialists) a
member body may establish some minimum requirements for
specified areas of CPD.
Members’ Responsibility
19.
Continuing professional education carries a cost to members in
terms of both time and money. The majority of members, trained
in accountancy and schooled in business matters, are unlikely to
select CPD activities where the costs exceed the benefits.
20.
Moreover, given the diverse activities that members of the
accountancy profession perform, it would be difficult to define a
common CPD curriculum that all members should be required to
follow. Any attempt to do so is likely to result in too rigid an
approach and might serve as a disincentive to many members. A
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Continuing Professional Education and Development
Proposed International Education Guideline for Professional Accountants
preferable approach is to establish, as a general rule, that the
subjects selected by members should be relevant to their work.
21.
In considering whether a CPD course or activity is relevant to
the work of a member, member bodies are encouraged to
recognize the changing nature of the environment and not to
inhibit participation in courses simply because they do not have
an immediate application to the member’s daily work (e.g.,
programs dealing with social, economic and environmental
trends should be recognized).
22.
It is recognized that a member body may need to be more
prescriptive in some circumstances ( e.g., licensed auditors or
certified specialists). Specific competences may need to be
developed for particular specialties (e.g. transnational auditors)
and these may require particular technical knowledge and
professional skills. IFAC's Transnational Auditors Committee,
for example, provides guidance for member bodies and members
active in transnational audits.
Knowledge and Professional Skills
23.
Accounting professionals in any field of employment need to
maintain competence in all matters related to fulfilling their role
as professionals. A person performing professional services
needs to have a broad range of capabilities. Thus, the concept of
professional competence should be interpreted broadly.
Accordingly, acceptable CPD encompasses programs
contributing to the development and maintenance of both
technical and non-technical professional skills.
24.
Technical skills include CPD in financial accounting,
management accounting, public sector accounting, auditing,
governance, consulting services, information technology, social
responsibility and environmental protection, management,
taxation, and ethics. Non-technical professional skills are equally
important (e.g., communication skills, leadership, knowledge of
different cultures when performing transnational work).
25.
To help guide their professional development, individuals may
find it useful to develop a learning plan. The learning plan can be
14
Minimum level of CPD
used to evaluate learning and competency development. It
should be reviewed periodically and modified as competency
needs change.
Minimum level of CPD
26.
The proposed International Education Standard, “Continuing
Professional Education and Development”, requires member
bodies to establish minimum levels of CPD that their members
should obtain within a specified period on either an input-based
standard or an output-based standard.
Flexibility in the timing of CPD
27.
Spreading the CPD requirement over a three-year period permits
greater flexibility in the application of the guidelines and enables
members to adapt their CPD activities to their particular
circumstances.
Structured learning
28.
It is for each member body to determine what activities would
qualify for recognition as structured learning. Member bodies
should focus on the need for an activity to be measurable and
verifiable, as well as the need to meet appropriate learning
objectives.
29.
Examples of structured learning include:

courses presented by educational institutions, member
bodies or employers;

individual study programs (correspondence courses,
audiotape or videotape packages, computerized learning
programs) that require some evidence of successful
completion by the member;

participation as a speaker or attendee in conferences,
briefing sessions or discussion groups;

acting as a lecturer, instructor or discussion leader on a
structured course but repeat presentations of the course
should not be considered for this purpose;
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Continuing Professional Education and Development
Proposed International Education Guideline for Professional Accountants

service as a member of a technical committee of a
professional body or individual firm as long as a specific
portion of the committee meeting is formally designed to
impart specific knowledge in preparation for committee
debate or discussion;

writing technical articles, papers or books, within reasonable
limits, because the output is clearly verifiable;

“on the job” experience for a finite period of time when the
member can produce reliable, objectively verifiable
evidence that a specific new competence has been
developed.
30.
In general, however, one single, repetitive activity, for example,
teaching introductory accounting to multiple audiences, should
not constitute a member’s total CPD activity.
31.
The recommended hours of structured learning need not be taken
in one block of time. They can be made up by participation in a
number of shorter programs throughout the period.
Unstructured learning
32.
Apart from their participation in structured learning, accountants
need to keep abreast of a wide range of developments affecting
their profession, clients and employers. This is done through
unstructured learning, such as regularly reading professional
journals and the financial and business press, discussing current
developments with colleagues, accessing relevant databases on
the Internet and other activities. Some member bodies may wish
to emphasize the importance of unstructured learning activities
by establishing requirements. Unless the enhancement in
knowledge, skills, or competences related to unstructured
learning can be assessed by objectively verifiable and reliable
measurements, any requirement for unstructured learning should
be an addition to, not a substitute for, the requirement set for
structured learning from input-based requirements.
33.
There are several reasons for this, and they are all related to the
need of providing reasonable assurance to the public that the
16
objectives of the member body’s CPD program are being
achieved:
a)
Structured learning (especially the inputs in an input-based
system) can be efficiently monitored and measured, while
unstructured learning normally cannot.
b) Structured learning is usually designed to achieve specific
learning objectives, while unstructured learning is typically
general and unplanned in nature.
c)
34.
Structured learning usually depends on approved instructors
or instructional materials, while unstructured learning
depends on the individual accountant.
Member bodies will be justified in recognizing unstructured
learning for satisfying CPD requirements if their members can
substantiate that learning occurred through objectively
verifiable and reliable measurement.
Input- and Output-based Systems
35.
Input-based systems traditionally have served as a proxy for
measuring competence. Because input hours of CPD are so
easily measured, hours have been recommended as the
measurement criterion.
36.
The effectiveness of CPD is, however, ideally measured in terms
of output; i.e., the knowledge, skills or competences that have
been acquired. Output-based assessments may not be practicable
in most situations. Member bodies are encouraged to experiment
with innovative approaches for measuring knowledge, skills, and
competences. With experimentation, eventually some workable
models may evolve. Readers and member bodies are referred to
the International Education Paper, Competence-Based
Approaches to the Preparation and Work of Professional
Accountants, which discusses these issues and profiles a
competence-referenced model.
37.
Some options for output-based approaches include periodic reexamination, practice inspections or peer reviews. For certain
sectors, a member body may be able to rely on mechanisms
17
Continuing Professional Education and Development
Proposed International Education Guideline for Professional Accountants
within employer or specialty associations, for example,
publication of articles in refereed journals for academic members
or government reviews of licensed bankruptcy trustees. For
members in remote locations, there may be organized and
monitored discussion groups (either face-to-face or through the
Internet) which discuss current topics and which the member
body could utilize to develop reliable, objectively verifiable
measurements to substantiate unstructured learning.
Members in Industry, Government and other Non-Public Accounting
Sectors
38.
The minimum requirement should apply to all active accounting
professionals, including those in public accounting, industry,
commerce, education and the public service.
39.
There are several reasons for this:
a)
The public interest arguments for minimum CPD for public
accounting are, in many cases equally valid for members in
these other sectors as they hold positions of importance
involving quality financial reporting, public accountability
and maintaining the public trust.
b) A member in industry, commerce, education or government
carries the professional designation, and any incompetence
or unethical behavior has the same consequences to the
reputation and standing of the profession as by someone in
public practice.
c)
Member bodies should not create an impression of a twotier profession by imposing lower or different standards on
those not in public accounting.
d) The arguments for CPD to cope with a rapidly changing
environment, and the consequential need to adapt the
strategic or business plans of those organizations relying on
the member's professional competence, are equally valid for
these sectors.
e)
18
Employers hiring members in these sectors rely, at least to
some extent, on the professional membership as proof of
professional competence and therefore would expect the
member body to impose equal professional standards,
including mandatory CPD, on these members.
40.
Member bodies should consider what specific or additional CPD
should be obtained by members working in areas of high risk to
the public, such as auditing, work with securities or the
preparation of financial reports of publicly-held companies.
Need for Continual Review of CPD Requirements and Arrangements
41.
The accounting profession is a dynamic one, operating in an
environment of change. Guidelines developed today are unlikely
to meet the needs of tomorrow. Every member body should
make formal arrangements to regularly review its CPD
arrangements to ensure that they continue to meet the needs of
the profession at any particular time.
Stepped (or Phased) Implementation Plan
42.
Some member bodies may find that adequate educational
resources are not yet available to meet the needs of members
wishing to comply with the proposed CPD requirements as
outlined above. For them, it may be necessary to adopt a CPD
program that is commensurate with immediately available
resources and increases gradually (in steps or phases) to the
recommended minimum requirement over a reasonable period.
Such a gradual, but firm, schedule of requirements is preferable
to one in which the requirements are contingent upon the
development of educational resources. The gradual, but firm,
schedule is likely to stimulate the development of necessary
educational resources. Making a requirement contingent on the
development of those resources is likely to delay implementation
of the plan.
Compliance Process and Responses to Non-Compliance
43.
In developing CPD programs, member bodies should implement
systems to effectively monitor the extent to which members are
complying with the CPD requirement prescribed in the proposed
International Education Standard, “Continuing Professional
Education and Development”.
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Continuing Professional Education and Development
Proposed International Education Guideline for Professional Accountants
44.
Member bodies should establish appropriate mechanisms for
dealing with non-compliance with CPD requirements. Such
mechanisms should focus on bringing a member into
compliance, and should explicitly provide for disciplinary action
when necessary.
System and Staffing
45.
A member body would need to set up its own system for
monitoring participation by individual members in structured
learning and for evaluating the quality of those activities. It is
suggested that a member body ensure that sufficient staff with
appropriate training administer the program or consider setting
up a board or committee under its control that would be charged
with oversight responsibilities.
Reporting
46.
Participation in structured learning can be monitored in several
ways. The following are some options, which are not mutually
exclusive:
OPTION 1
20

Require members to submit an annual report of CPD
activities.

Individual reports submitted by a representative sample of
members would be checked against the attendance or
completion documents that the CPD provider gives to a
member body.

It would be desirable to require these annual reports to
identify the specific structured learning that a member has
undertaken, rather than accept a simple representation on
compliance with the requirement.

This allows the member body to review the reports for
overall reasonableness and facilitates checking reports to
supporting information.
Compliance Process and Responses to Non-Compliance
OPTION 2

Require members to maintain documentation on their CPD
activities, which the member body “audits” on a selective
sampling basis.
OPTION 3

Build the review of learning plans or CPD documents into
practice inspection programs.

Member bodies may require that public accounting
employers impose CPD programs and effective monitoring
systems into their quality assurance programs and track
CPD activities within their time recording systems.

Practice inspection or peer review programs would include a
component that tests this element of quality assurance.
Discipline
47.
The sanctions initially applied for non-compliance should focus
on bringing the member into compliance within a reasonable
period of time. Care should be taken to strike a balance between
a sanction that in substance amounts to permitting a member to
defer or avoid compliance with the CPD requirement and one
that is excessively punitive.
48.
Member bodies should develop punitive sanctions based on the
legal and environmental conditions in their countries (in some
countries they might include expulsion from membership or
denial of the right to practice). Such sanctions should be reserved
for members who have made it clear, through a pattern of noncompliance or through their response to the member body’s
inquiries, that they are likely to continue to disregard the
importance of complying with the CPD requirements.
49.
Imposing sanctions is not an action that should be taken lightly.
A professional accountant’s willful failure to maintain and
improve his or her professional competence is, however, a
violation of a significant professional duty that justifies
disciplinary action. Moreover, it is unfair to the majority of
members who do and will continue to participate in required
CPD programs, at a cost of time and money, to allow others who
do not do so to escape any penalty.
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Continuing Professional Education and Development
Proposed International Education Guideline for Professional Accountants
Providers
50.
The quality of structured learning offered to members of the
profession, and the CPD credit to be granted for participation,
can be evaluated by approving the providers of those programs
or by approving individual programs. Approving program
providers is often more efficient and would focus on the
procedures and controls instituted by the providers to ensure that
programs are prepared, reviewed and conducted by qualified
individuals, that the learning objectives are appropriate for the
intended participants and achievable within the time allotted for
the program, and that the instructional materials are sufficiently
comprehensive and properly designed. Whichever approach is
taken, the member body should subsequently monitor offerings
of programs on a test basis. Member bodies have a right to
expect that the providers reimburse them for any costs incurred
in making these evaluations.
51.
Member bodies are referred to the International Education Paper
"Recognition of Pre-certification Education Providers" (to be
released July 2002). That Paper does not specifically address
CPD providers, but the principles and issues may be equally
applicable.
52.
CPD from other providers not previously approved may be
acceptable. Members reporting such should be prepared to
provide the necessary support to show quality if requested by the
member body. This might include providing copies of the course
outline, copies of learning materials, credentials of the teaching
staff, etc.
53.
The quality of structured learning offered by accounting firms or
other employers should be evaluated on the same basis as that of
other external education providers. Generally, member bodies
should recognize in-house programs of employers, provided
there is reasonable assurance of quality.
Other Activities
54.
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It should not be difficult to evaluate the CPD content of activities
such as service on technical committees and writing articles. The
journals or magazines a member writes for should be well
recognized, making it possible to rely on the quality control of
the publisher. The member body should be familiar with the
Compliance Process and Responses to Non-Compliance
work of the technical committees and thus able to recognize the
appropriate learning activity. The member body may request and
evaluate copies of outlines or other available materials from the
individual member claiming credit for participation.
55.
Member bodies may prescribe limits to the quantity of CPD that
might be allowed in each of the categories. For example, a
member body may decide that no more than 10 per cent of the
minimum CPD requirement may be allowable for work with
technical committees or no more than 20 per cent may be
allowable for technical writing.
Regulators
56.
Professional accountants must demonstrate to regulators or other
authoritative bodies that learning has occurred and that the type
and quality of learning is appropriate for their professional
responsibilities. Regulatory or other authoritative requirements
may mandate that professional accountants document their
learning activities.
Retention of Documentation
57.
Members should be required to maintain sufficient
documentation to support their annual CPD report to their
member body. CPD is an individual responsibility, and members
should be encouraged to maintain a lifetime record of CPD,
which may be useful to show to employers or potential
employers. In the absence of legal or other requirements, a
reasonable policy is to retain documentation for a minimum of
five years from the end of the year in which the learning
activities were completed.
Members in Remote Locations or Working out of the Country
58.
Member bodies should be prepared to provide extended periods
for compliance or greater flexibility in recognition of distance
learning or other unstructured learning for members in remote
locations or working out of the country. A member body may
make special provisions for out of country members who are
members of a member body with a CPD requirement in that
country.
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