Re-enrollment Time Is Almost Here!
My guess is you are already counting up your hours to make sure you will have your CE in by the end of this year, but what if you won’t make it? Do you have enough ethics credits? “Formal” education? What qualifies for ethics credit, anyway?
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Most of us were first enrolled before Jan. 1, 2014, so the requirement for the three years ending Dec. 31, 2016 is 36 hours of qualifying credits. If this is not your first full cycle, your 36 hours must include at least 12 hours of “core” subject matter. If this is your first full cycle (i.e., you were enrolled by Jan. 1, 2014, but not by Jan. 1, 2011), your 36 hours must include at least 18 hours of “core” subject matter. Newer EAs have lesser requirements. If you just became enrolled in 2016, you have no CE required. If you became enrolled in 2015, it’s 12 hours total, with six core; for 2014 enrollees it’s 24 hours total and 12 core. Regardless of how many core hours are required, at least two of the core hours must be “ethics” — no proration — and one-third of the total required hours must be from a “formal” program.
So, does it really matter if you don’t have all these hours completed by Dec. 31, 2016? Yes, it does. If you have completed the required hours by Dec. 31, 2016, and file a timely application (with payment) for renewal of enrollment by March 1, 2017 reporting completion of the required number of hours of CE, come April 1, 2017 you will remain on the active roster, and can continue to sign SBs. If you have not completed the requirements by Dec. 31, 2016, but complete the requirements in early 2017 and file your application by March 1, 2017, there is no guarantee that you will not suffer a break in your active status. If you didn’t complete the CE by Dec. 31, 2016, or didn’t file your renewal application by March 1, 2017, you must have received a letter acknowledging your renewal from the JBEA by April 1, 2017 in order to avoid a break in active status. In other words, get your CE in by the end of this year and file your application with your payment by March 1, 2017. Otherwise, you may have a period of time when you can’t sign off on that SB.
If you are not clear about what qualifies for ethics credit, or “formal” CE, the JBEA issued some Q&As on qualifying education programs that are very helpful in interpreting the final regulations.
The issue addressed in the first question is what topics qualify for ethics credit. A critical point made in the answer is that sessions covering ASOPS do not generally qualify for ethics credit because the ASOPS generally deal with technical matters, “not ethical considerations that arise when applying them.” As a result, you may have professionalism credit for Academy CE purposes for a session that does not qualify for JBEA ethics credit. (Note that as a qualifying sponsor, the American Retirement Association uses its best judgment in stating what credits are likely to be available for a session, but the final judgment is made by the JBEA.) I occasionally get a question about a session that included ethics in its description, but was not primarily an ethics discussion. If you read the Q&A, I think you will agree with me that you should not count on that session for ethics credit.
I have also had inquiries about the “virtual conference” ASPPA has been offering the past two years, questioning why we have not reported this as “formal” credit. If you watched the conference live in the same room as at least three other pension practitioners, you can qualify for formal credit, in the same manner as with a live webcast. But, as noted in the regs and the Q&As, “formal” credit includes both the availability of interaction with other pension practitioners in the same room, as well as the ability to interact with the presenter. Sitting alone in your room watching the virtual conference does not provide the peer interaction envisioned for formal credits.
We will let you know when renewal applications become available on the JBEA website. (On its renewal webpage, the JBEA says renewal forms will be available “soon.”) And we will be reminding you to file your application. In the meantime, if you have not gotten all of your credits, there are webcasts available, both live and on demand. Offerings from ACOPA include a Dec. 1 ethics webcast and a Dec. 13 webcast on floor-offset plans. And if you can’t make the December deadline, you can complete missing (and formal) credits at the LA Advanced Pension Conference, Jan. 19-20, 2017.
Stay tuned for more renewal info as we finish up 2016.