Auditing 84 Claimed CPD Points Against a 60-Point Renewal Threshold
Engr. Ngozi Bello submits her licence renewal application with 84 CPD points claimed across the three-year cycle. Council's published policy for the cycle sets a minimum of 60 points, of which at least 40 must come from Council-accredited providers; unaccredited activities are capped at 20 points in total. Activity caps are 10 points for mentoring, 8 for branch or division meetings, and 10 for technical publications at 5 points per paper. Duplicate claims are not credited: a point may be counted only in the cycle in which the activity occurred. Her submission contains 40 points from a five-day commercial 'Project Finance for Engineers' workshop run by a vendor not on the accredited list; 16 points for two papers in a peer-reviewed journal, claimed at 8 points each; 12 points for mentoring two graduate engineers, evidenced only by log sheets signed by the mentees; 10 points for attending her branch monthly meeting; and 6 points for a conference already credited in her previous renewal. Her employer, a road construction firm, also wants Council to recognise its in-house graduate development programme as an accredited CPD provider.
1. Compute the allowable points and decide the renewal outcome, showing each adjustment.
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Adjust the claim item by item.
| Item | Claimed | Allowed | Reason |
|---|---|---|---|
| Commercial workshop (unaccredited) | 40 | 20 | Unaccredited total capped at 20 |
| Journal papers | 16 | 10 | Publications capped at 10, 5 per paper |
| Mentoring | 12 | 10 | Mentoring capped at 10 |
| Branch meeting | 10 | 8 | Branch attendance capped at 8 |
| Repeat conference | 6 | 0 | Duplicate; credited in the previous cycle |
| Total | 84 | 48 |
Two failures, not one. She falls short on the total (48 against 60), and, more importantly, she has zero accredited-provider points against a 40-point accredited minimum. The second failure is the decisive one: even if she found 12 more points from unaccredited activity, she would still fail, because the unaccredited cap is already exhausted.
Outcome. The application cannot be granted as submitted. Because the shortfall is remediable within the cycle's grace window, the proportionate decision is deferral with a 90-day window rather than outright refusal: she must submit at least 40 points from accredited providers. Do not simply refuse - refusal without a cure path invites a successful appeal on proportionality grounds.
Note also that the mentoring evidence is weak: mentee-signed log sheets prove attendance, not mentoring. Even the 10 allowed points should be recorded as 'allowed on this occasion, evidence standard not met for future cycles'.
2. What should Council do about the vendor advertising CPD points without accreditation, and about the duplicate claim?
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The vendor is the bigger systemic risk. A commercial provider selling a five-day course as CPD without accreditation is not merely a nuisance - it is manufacturing the illusion of compliance across every engineer who attends. Refer the vendor to the committee responsible for CPD provider accreditation with a request for investigation and a written warning to cease representing its courses as Council-recognised. If it continues, publish a caution listing so that engineers cannot plead ignorance. Also check whether the workshop was marketed with Council's name or logo; that changes the matter from a compliance issue to misrepresentation.
The duplicate claim should be treated differently. Duplicates are usually administrative - engineers carry forward conference certificates and do not track cycles. Record the adjustment, require her to resubmit with a cycle-by-cycle schedule, and warn that a further duplicate will be treated as a conduct issue. Sanctioning an evident bookkeeping error with the same seriousness as the vendor's conduct is disproportionate and would not survive review.
Process point. Both matters arose from an audit, so the audit trail must be preserved: retain the claimed schedule, the adjusted schedule, the calculation, and the letter informing her of the specific shortfall. If she appeals, the arithmetic is the defence.
3. On what criteria should Council judge the employer's request that its in-house graduate development programme be accredited as a CPD provider?
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The central risk is that an employer becomes the certifier of its own staff's development, with a commercial interest in the answer. Accreditation must therefore be built to survive that conflict.
Criteria to apply.
- Structured syllabus mapped to defined engineering competencies, not a list of internal inductions; hazard awareness, temporary works, quality control, contract administration and professional ethics should appear.
- Qualified facilitation - sessions led or examined by registered engineers with relevant experience, named in the submission.
- Assessment and records - attendance alone is not competence; require an assessed output per module, with records retained for audit.
- Independent verification - a proportion of sessions observed or moderated by someone outside the employer, and an annual audit by Council or a delegate.
- Point allocation discipline - a schedule of points per module approved in advance, not negotiated per participant.
- Governance - a named programme owner, a complaints route for graduates, and a conflict-of-interest declaration covering line managers who assess their own subordinates.
- Time limit - accreditation for a fixed term with renewal on evidence, so a dormant programme lapses automatically.
Likely decision. Approve provisionally for one cycle, capped module content, with a first-year audit. A firm that builds roads has genuine technical content to offer; the objection is to self-certification, not to the training.