Each year the CAS Continuing Education Compliance Committee (CECC) gets together via conference call and email to organize and prepare for our primary task: reviewing a sample of CAS members’ compliance with continuing education requirements. On behalf of the committee, I offer this report to the Actuarial Review readers, especially those who enjoy statistics.
In accordance with CAS policies, the CECC reviewed 82 members’ documentation of their 2014 continuing education (CE) credits. This was a one-percent sample of the membership, plus documentation from every member of the CAS Board of Directors and Executive Committee. With rare exceptions, the CECC found that the selected members who attested that they “Have complied” actually had done so.
Based on a subsample of 45, about 89 percent of the “Have Complied” attestations were under the U.S. Qualification Standard, four percent were under the Canadian Institute of Actuaries’ (CIA) CPD requirements and seven percent under the CAS Alternative Provisions. Other national standards were not represented in the subsample.
CAS members providing actuarial services in the U.S. are subject to the U.S. Qualification Standard, and CIA members who provide actuarial services in Canada are subject to the CIA Continuing Professional Development requirements. See Section B of the CAS CE Policy, March 23, 2015, for a list of Recognized National Organizations.
The original CAS CE policy included Alternative Compliance Provisions, which were discontinued in the March 2015 revision. Members who have used the Alternative Provisions will need to determine the most relevant Recognized National Standard for themselves. If providing actuarial services in more than one jurisdiction, members should take care to meet the relevant qualification standards in each jurisdiction that applies.
With respect to the U.S. Qualification Standard, very few members showed any difficulty documenting compliance with the three credit hours minimum for professionalism topics, six credit hours minimum for organized activities, and 30 credit hours overall minimum. Likewise, few had any difficulty capping general business skills activities at the three credit hour maximum.
The online CAS member profiles show “Did Not Comply” for 474 members who either did not attest or attested that they “Did Not Comply.” Of these, 109 appear to be neither retired nor working in academia, but have job titles in the CAS Online Directory that appear to involve providing actuarial services.
Some members attested that they are “Not Providing Actuarial Services.” The CECC found 29 of these to be neither retired nor working in academia, but have job titles in the CAS Online Directory that appear to involve providing actuarial services. The CECC is following up individually with these and also with members who “Did Not Comply.” Updated member profile information may be all that’s required.
The CECC can refer noncompliant members to the CAS Executive Committee. Providing actuarial services without being qualified to do so would violate the Code of Professional Conduct and could entail consequences that include counseling or discipline. No loopholes exist.
How Did Members Comply in 2014?
By compiling data from anonymous PDF files, I looked at how a sample of 45 members documented their 2014 CE credits. Actuaries tend to put everything into Excel, and their CE documentation is no exception. Most submissions were some variety of spreadsheet. Some members used the American Academy of Actuaries (AAA) TRACE program, submitted hand-written notes or provided the output of their employer’s internal CE database. In general, the database outputs are the hardest to read. They often seem to be a raw dump with little effort made to format them for reviewers’ ease. It was common for the CECC to suggest improvements in members’ documentation.
The sample average CE credits documented for 2014 was 78.7. Excluding five outliers, the average for the remaining 40 was 57.3 credit hours. As you can see from Table 1, four members documented more than 100 CE credits, but at the other extreme, eight documented between 30 and 32. So, members varied widely in the number of CE credits documented. The members are assigned to “Documented Credit” groups to highlight the extremes. In particular, many members documented compliance with the minimum but probably did not document all their qualifying continuing education, so it is not possible to measure the time actually devoted to continuing education.
Judgmentally, I identified seven sources of CE credit or activity types:
(1) Webinars — Affordable, plentiful and generally structured to be “Organized” under the U.S. Qualification Standard.
(2) Multi-session meetings — Sponsored by the CAS and other professional bodies, these provide a lot of “Organized” CE credit but generally require travel.
(3) Committee work and public speaking — This may include time that qualifies as continuing education.
(4) Traditional educational institutions (i.e., universities) — Study or work with this type of organization is often an overlooked source for CE activity that should not be omitted.
(5) Educational meetings internal to the actuary’s organization — Caveat: These are not “Organized” under the AAA definition unless there are participants from outside the organization.
(6) Other Meetings — These can be sponsored by nonactuarial trade associations and various service vendors.
(7) Self-study — This can include educational reading, preparation for presentations and reviewing ASOPs.
Table 2 reveals the proportion of members that used at least some of each Activity Type. Members varied widely.
Actuarial meetings were used for documented CE credits by 84 percent (or 90 percent when the five outliers are excluded). Self-study and webinars were used by 60-70 percent, and employer-sponsored meetings were used by 50-60 percent. Only three out of 45 relied on university-sponsored activities. Those documenting a lot of CE credit relied most heavily on committee work, presentations given, “Other Meetings” and self-study. In contrast, those with 30-32 documented CE credits relied least on committees/speeches and self-study.
Fifty-eight percent of the 40 members documented educational meetings internal to their organizations. This is interesting because it implies that 42 percent claimed no such CE credit. Some internal educational meetings might be hard to document without disclosing proprietary information.
Table 3 shows the average CE credit by activity type.
For obvious reasons, self-study CE credit volume was greatest among exam takers and among the four members who documented more than 100 CE hours. Those who documented 30-100 CE hours probably did more self-study than they chose to document.
Webinars, though widely used, contributed an average of about five CE credits. Across the Documented Credits groups, except for the five outliers, actuarial meetings came closest to a uniform contribution to members’ documentation. The documented averages of 15-24 credit hours came from meetings sponsored by the CAS, CAS Affiliates, the CIA, the AAA and similar actuarial organizations. The SOA was not represented in the sample.
Four members out of 40 (excluding the five outliers) documented over 100 credit hours, and their totals reflect decisions to claim much more CE credit than others for self-study, internal educational company meetings and committee work. Committee work and self-study may be subjective sources of CE credit. Fifteen of the 40 (excluding the five outliers) claimed a total of 223 CE credits for committee work and presentations delivered, but two members claimed almost half of those credits. Twenty-six of the 40 claimed a total of 692 CE credits for self-study, but one member documented almost as much self-study credit as the other 25 combined. It’s likely that many of us have chosen not to include all of our self-study and committee work that could be considered CE in our documentation.
Indeed, a strategy for some was to submit only a short, defensible list of “Organized” activities. It is not surprising there is so much diversity in the way members documented CE, given the broad and diverse work our members engage in.
Good Faith Determinations
Judging “relevant” continuing education is up to the member, who needs to be able to support those decisions under applicable criteria. Continuing education is supposed to be new learning that will aid you in your current practice or prepare you for potential future practice. Remember what the U.S. Qualification Standard states:
Continuing education is “relevant” if: (1) it broadens or deepens an actuary’s understanding of one or more aspects of the work an actuary does; (2) the material expands an actuary’s knowledge of practice in related disciplines that bear directly on an actuary’s work; or (3) it facilitates an actuary’s entry into a new area of practice. Ultimately, it is an actuary’s responsibility to make a reasonable, good-faith determination of what continuing education opportunities will enhance an actuary’s ability to practice in a desired field.
Gordon K. Hay, FCAS, is the senior casualty actuarial examiner for the Nebraska Department of Insurance.
