The CE Audit and the Duplicate Course
Priya is a Pennsylvania resident producer with a two-year license term ending October 31, 2025. Her CE transcript shows: 12 hours of approved classroom courses; 6 hours of approved online courses; 6 hours of "home office training" provided by her agency's carrier, not approved by the Department; 3 hours of approved ethics; and 3 hours of an approved course that duplicates a course she completed earlier in the same license term (same course number). She submitted 30 hours and expects 6 hours to carry over to the next term. The Department selects her for a CE audit in September. Priya's records include certificates for the approved courses, a screenshot of the home office training, and a prior certificate for the repeated course.
1. How many CE hours should the Department credit for the current term, and why?
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The Department should credit 21 hours: 12 approved classroom + 6 approved online + 3 approved ethics. The 6-hour home office training does not count because it is not approved by the Department. The 3-hour duplicate course does not count because it repeats a course already completed in the same license term. That leaves Priya 3 hours short of the 24-hour requirement, even though she submitted 30 hours.
Her expectation of 6 carryover hours is also incorrect. Pennsylvania does not allow excess CE hours to be carried into the next licensing term. The 9 hours that are disallowed or excess do not create a credit bank. Priya must complete 3 additional approved hours before October 31 to satisfy the current term. The ethics component is already satisfied because she has 3 approved ethics hours.
2. What should Priya submit in response to the audit, and what should she do before the term ends?
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Priya should respond with a clear reconciliation, not simply resubmit all 30 hours. She should provide certificates for the 12 classroom, 6 online, and 3 ethics courses, including provider names, course numbers, dates, and approved credit hours. She should identify the home office training as unapproved and the duplicate course as non-creditable. She should not claim the home office training was "state-approved" unless she can produce an approval number. She should also correct her carryover expectation in writing.
Before October 31, she should complete 3 additional approved hours and retain the completion certificate. She should confirm the provider reports the hours to the Department if required. She should keep a personal CE file for at least the period the Department requires, because audit responses depend on contemporaneous records. If she cannot complete the hours before expiration, she should address renewal or reinstatement status promptly rather than transact business on a lapsed license.