Rewrite of JBEA Regulation on CPE Will Make Pandemic Waiver Permanent

American Retirement Association (ARA) General Counsel Allison Wielobob said Wednesday that the Internal Revenue Service (IRS) confirmed that it plans to publish a new rule by the end of January detailing a permanent change to how actuaries earn continuing education credit.

Wielobob, ASEA’s Executive Director, said the Joint Board for the Enrollment of Actuaries (JBEA) will permanently adopt the pandemic policy, allowing actuaries to earn JBEA credits virtually.

Historically, the JBEA maintained an in-person-only requirement. The new rule, first announced by an IRS actuary at the 2022 ASPPA Annual Conference, now has an approximate date for its release.

Wielobob’s predecessor, former ASEA Executive Director Martin Pippins, sent a letter to the JBEA in April 2020 advocating for a virtual option in the face of the COVID pandemic. The JBEA announced the virtual option in August of that year.

“To maintain their enrollment, actuaries must complete a certain amount of continuing professional education,” Wielobob explained. “The JBEA regulations specify how much and what type of course material it has to be and measures it on a three-year cycle. So, CPE is very important to enrolled actuaries. They accumulate it, and many rely on us for it. Sponsors of CPE are approved by the board and will review the credits being given.”

It will be much easier for enrolled actuaries to fulfill CPE requirements now that the JBEA will remove the travel requirement.

Before the 2020 temporary waiver, JBEA regulations provided that “a qualifying program qualifies as a formal program with respect to a participant if the participant simultaneously participates in the program in the same physical location with at least two other participants engaged in substantive pension service ….”

Also, “Groups of three or more participants who are in the same physical location may participate via in a formal program in person or via the internet, video conferencing, or teleconferencing” (section 901.11(f)(2)(ii) of the Joint Board of Regulations).

“The ‘same physical location’ requirement is imposed by federal regulation,” Wielobob concluded. “It has defined the CPE landscape for actuaries for some time.”