It is that time of year again. You just attested that you are in compliance with the U.S. Qualification Standards (USQS) or some other standards on the CAS website. It’s time to start accumulating Continuing Education (CE) credits for the new year. But wait! You have heard that some CAS members had their CE credits from last year reviewed to ensure that they were in compliance with the USQS as they attested.
Let’s assume that you’ve already met your Basic Education (the exam process) and Experience requirements. What do you need to know about CE? The USQS requires 30 total hours of “relevant CE” per calendar year. At least three of these hours must be professionalism related, and at least six hours need to be from organized activities. Also, one hour must be bias related, and no more than three hours of CE can be related to general business instruction, like management training, communication or business writing sessions. What if you are selected for review?
What is the CE review process? Like most things, there is a beginning and an end. The review process starts in February when all members of the CAS who are subject to CE requirements are notified of the review process and are informed that they may be selected for a review of their CE activities.
Who is reviewed? The CAS picks a semi-random sample of 1% of certifying members each year.
Who is exempt? Only credentialed actuaries who either did not certify at year-end or did not pay CAS dues (i.e., nonmembers) are exempt.
Who is eligible? Some actuaries are automatically chosen for review: 1) CAS Board members in their first term, and 2) any member reviewed the prior year who was recommended for a follow-up review. Every other CAS member is fair game, although members who sign NAIC statements of actuarial opinion do have a greater chance of being selected for review.
What happens in the CE compliance review process?
- Members selected for review (reviewees) are notified that they have been selected for the review and are requested to provide supporting documentation through a software application within four weeks of the notification date. Each reviewee is assigned a unique number and any identifying information is redacted from the submitted documentation.
- Reminders are sent to the member two weeks prior to the documentation due date. Reviewees who do not respond or fail to provide supporting documents are contacted by CAS staff. If the reviewee still fails to submit the required documentation, a registered letter shall be sent indicating that the member is not in complicance with the CE requirements and their status on the CAS website will be changed to “Has not complied.”
- After all submitted documentation is received and sanitized, members of the CE Compliance Working Group (CEC) (reviewers) begin their review. Each reviewer is assigned a unique number to maintain anonymity.
- The reviewers will discuss with the other CEC members any questions or issues for which they request input. Reviewers will post questions or issues to the reviewee through the software application in an attempt to resolve unclear or incomplete documentation.
- After all reviews are complete, the CEC finalizes their pass/fail recommendations. Any outstanding issues or concerns stemming from the requests for additonal information are discussed in an attempt to resolve, and anything that cannot be resolved by the committee is sent to the Executive Committee (EC) for their next meeting.
- The EC Meeting Chair presents any records still in question to the EC for their input and response. The CEC then debriefs the results and feedback from the EC meeting and decides on the action to take.
- Once all additional documentation has been submitted and accepted by the CEC, the CAS Volunteer & Committee Coordinator contacts the reviewees with their results and thanks them for their cooperation in the review. This ends the CE review process. Members who have questions regarding the review process may contact the CAS Volunteer & Working Group Coordinator or the Chairperson of the CEC.
Reviewers note common problems, good and bad examples of logs, etc., to provide feedback to the reviewees and to add to the knowledge base of the CEC. Here are some examples of common problems with submitted CE documentation.
- Lack of adequate description of the CE. For example, an “internal actuarial meeting” does not provide sufficient information on what topics were covered or the time devoted to a topic. Was the entire meeting relevant CE? Was there time devoted to nonrelevant topics like upcoming rate plans that would be considered part of the job?
- Lack of documentation supporting CE. Documentation should at a minimum include date of CE, who sponsored the CE (e.g., CAS, Regional Affiliate), how many CE hours are credited (50 minutes = 1 CE hour), the subject of the CE (e.g., reserving with AI), and area of practice, if relevant (e.g., reserving, pricing). The CE should also be associated with any category that applies: Specific Qualification Standard, Organized Activity, Professionalism, Bias Topic and Business Skills.
- Bulk coding of multi-session events. Going to the CAS Annual Meeting and booking 12 CE hours under that description is not acceptable. Each session within a meeting should be recorded separately with all the pertinent information.
- Duplicate entries with the same description. For example, an internal pricing seminar listed for three separate sessions does not indicate if this was repeated in error or if there were three distinct sessions during the seminar that qualified for CE.
- Lack of information on how to determine if specific events should be considered relevant and/or “organized.” Events like internal meetings, company-required training could be either organized, partially organized or not organized depending on who is presenting or in attendance. For example, the entry “Training session by analytics department on deploying non-linear modelling techniques into model validations” clearly defines CE relevance but “Pricing presentation on upcoming rate change” doesn’t distinguish a business meeting from CE relevance. Also, some sessions of an internal event may qualify as “organized” because they are both relevant and include parties outside of your company. CAS webinars, for example, are an organized activity if attended “live,” but they are not an organized activity if you view the recording.
- Counting CAS Town Hall meetings, a company’s quarterly earnings call, or vaguely described CE (e.g., “I read the WSJ every day”) without describing how it is relevant and the CE time devoted to the relevant topic(s). It is your responsibility to determine and justify how a session is relevant to you.
- Relying on the prior year’s CE units to support this year’s attestation but not documenting the calculation and which prior year’s units are being carried forward. If prior year’s units are being used, then a worksheet of the prior year’s CE highlighting which excess credits are being used should also be provided. The USQS allows for one year of carryover CE units.
- Insufficient hours in one or more subcategories. This past year, there were a number of instances where there was no CE specified as bias training. When the reviewee was asked if they had completed bias training but not recorded it, some said they were unaware of the requirement. It also helps reviewers if you show totals for each category and overall so they can quickly determine if the submitted log is complete.
The best way to keep adequate documentation is to keep a log for each calendar year, updating new CEs as you earn them. The USQS provides a sample format in Appendix 5. (https://www.actuary.org/sites/default/files/2021-11/USQS_2021.pdf)
There is also an application called TRACE on the Academy’s website if you don’t want to build your own. (https://www.actuary.org/trace).
You can’t avoid having your CE reviewed for compliance if you are selected, but you can be adequately prepared.
- Keep good documentation of CE units you are claiming.
- Be prepared to show relevance of the CE units.
- Have adequate hours in all categories.
- Exceed minimum requirements, if possible, in case some of your CE is viewed as not qualifying.
- Refer to the USQS and USQS FAQs if you have questions.
As always, please feel free to send any questions or comments to ar@casact.org.
