The ICAEW CPD rules are changing and verification is the key.
Old style CPD
Let’s start with a CPD history lesson. Back in the day, when everything was in black and white, CPD was straight-forward. Partners and managers rocked up to a course every couple of months.
Delegates sat, lecturers lectured, coffees served, certificate of attendance issued, CPD points awarded, everyone went home, job done, box ticked, CPD compliant. Provided you had enough points in a year you were awarded a metaphorical gold star and a pat on the head.
Then ICAEW decided members could choose the amount of CPD they could do. Many, thankfully, kept doing their CPD but others sort of didn’t. They’d write down ‘I have read Accountancy magazine’. ICAEW knew they hadn’t. The member knew they hadn’t. The member knew ICAEW knew. The ICAEW knew the member knew. But nothing could be done.
So now we are back to points, well hours, which gives certainty to all. Seemingly onerous but in reality is it not unreasonable for a member of the public to expect their appointed accountant is up to date?
Then digital stuff was invented and the world bloomed into colour with lots of CPD options. There begins the problem. External CPD courses are diminishing in number, probably won't recover and never should be the only option.
Nor can ICAEW provide a definitive list of what CPD is. It would probably be out of date before the first up date.
Verification
Verification sounds like a daytime TV quiz show presented by a minor mediaah celebrity – ‘do you want to verify or gamble?’ And that is the key bit. Incidentally for those employers amongst you daytime TV is what your team members do when they are working from home.
But this is really what the new rules are about. In brief it is ‘Prove you’ve done it’. It goes back to the Accountancy Magazine approach it wasn’t believed then and won’t be anymore.
Do you want to gamble with your CPD or collect verification as you move through the year? The answer is for you to decide.
To be verifiable the ICAEW basic principles are:
· objective - fact based rather than based on personal perspectives;
· corroborated - can be confirmed to be accurate; and
· retained - documented and stored in an observable format.
Note that only one piece of evidence is required per verifiable activity listed in your CPD record.
There is no definitive answer to this and every situation is different. Remember third-party evidence is better than your own generated but both are fine. Some are very easy. Attend a course, obtain a certificate of attendance, nice ‘n’ easy.
What if you research an area of tax in depth, as indeed I do for the podcast, but you could easily do for a client. Scan and retain documents you read, what about the notes you have taken – keep them.
An internal team meeting where one member of the team presents on their special knowledge area – keep some notes and slides. Date, time of meeting, duration etc.
Most of the profession do not undertake exams every year. (Though if you are considering CTA exams checkout our CTA podcast). However, many will take QXSA (Quick Books, Xero, Sage, And others) webinars to maintain their approved status with those suppliers. Most have a test of competence attached – what wonderful evidence.
Going back to our imaginary TV quiz – do you want to verify or gamble? If you have the evidence would it not be a good idea to keep it as you complete the training.
Just a note on podcasts. The initial guidance does say a podcast is not verifiable so I contacted ICAEW. Podcasts can be verifiable:
· they need a proper structure not just people randomly talking tax, so topic based
· you need to justify why that podcast was relevant to you – but you should do that for all CPD you select
· You need to verify. That is where our podcasts work we provide a short test of competence / quiz. You download from our site, it is password protected and the password is stated in the podcast. It is stated at different points in each so you have to listen.
· If you do not want to do the test the podcast is not verifiable and you might decide to treat the podcast as part of your not verified CPD – the choice is yours.
ICAEW will update the guidance soon.
Documentation
Every January I would receive requests for lists of courses people had attended in a dash to update CPD records. This is not going to work in the new world – there is too much choice.
You really need to document and obtain evidence / verify as you do it. It just needs a bit of discipline. Why wait to October 2023 – start today.
There is no required format to record CPD but would expect to see, as a minimum:
· Date, when and where etc
· Nature of training
· Duration
· Why it was undertaken
· What learning was gained
· Evidence – that is the key bit
In my past experience QAD expect to see more than one or two lines – so channel your inner author.
ICAEW checks
We cannot know at this stage how strict or lenient these will be. In my experience QAD inspectors are pretty good at spotting the genuine ICAEW member from those who seem to specialise in fabrication.
I would hope in the first year or so a member with a good approach to CPD but falls down a little on evidence would be given guidance and help not a mallet over the head. But we shall see.
My suggestion is to build a few extra hours above the minimum as a safety barrier. For category 2 in practice the amount of CPD is about 3 hours a month. Not a huge target but when you do not have a spare minute it can appear overwhelming. Podcasts do help - they are designed to listen to whilst you keep working.
If you gain only one thing from this article it should be: document, document, verify, verify.
Do you want to verify or play your CPD gamble card?
Next article looks at Ethics.
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