IFoA CPD Consultation

The Institute and Faculty of Actuaries (IFoA) are currently holding a consultation on changes to the Continuing Professional Development (CPD) scheme for all members.  In this article, we look at why this proposal has come about, what changes are being suggested, and what you need to do to respond to the consultation.

Why change?

Following a review of the results of the recent pilot of an outcomes focused CPD scheme, as well as member feedback on the current arrangements and consideration of approaches taken by other professional regulators, the IFoA has developed this proposal with the aim of introducing “a modern, simpler approach to CPD that better reflects the IFoA membership”.

What changes are being proposed?

In terms of the amount of CPD that you have to complete – not much.  This is proposed to remain the same as is currently the case for most qualified actuaries, with a total of 15 hours of CPD being required, including the 2 hours of Professional Skills Training (“PST”).

However, there are several practical changes that impact the operation of the CPD scheme. The key changes being proposed are as follows:

Removal of categories

Under the existing scheme, each member is assigned to a category, and each category has its own CPD requirement (e.g. qualified actuaries without a practicing certificate are Category 2, IFoA Fellowship students are Category 5 etc.).  In order to simplify the CPD scheme, these categories will be removed under the proposals, with the single 15-hour requirement mentioned above applying to all members.

Instead, there will be exemptions for certain types of member:

• Students, who will remain subject to PPD instead.
• Actuaries whose employer is accredited by the IFoA Quality Assurance Scheme (“QAS”) and opts to implement the QAS outcomes focussed CPD scheme.
• Members with a “non-practicing status”, e.g. those not carrying out technical actuarial work as part of their normal role, are on a career break or are retired. Those on parental leave or absent through illness will be treated in the same way, but would not have to apply for this special status (simply notifying the IFoA at the time of renewal). Where this applies only for a proportion of a CPD year, a pro-rata requirement will be applied.

As currently, there will be additional requirements for practicing certificate (“PC”) holders. These are proposed to be an additional 15 hours relating to technical skills required for the role for which they hold the PC. This brings the total requirement in line with the existing 30 hour requirement for these members, but how these hours must be made up is slightly different from the existing scheme.

Wider range of CPD activities permitted

Under the existing scheme, the wording relating to CPD activity states that it should be “relevant to the nature of the member’s work or role and which addresses a personal development need”. Under the proposed changes, this wording would be relaxed to include a wider range of activities, including those relevant to a future role. However, some care may be required in choosing CPD activities to give a good balance between activities that support development for future roles and maintaining competence in a current role.

Similarly, the definition of PST will be changed to be CPD activities “with a learning outcome related to managing professional ethical challenges”, increasing the number of activities that may be considered under this banner.

Any activity can be recorded as CPD as long as it has a relevant learning outcome – this should help those who have limited access to traditional CPD activities such as conferences and seminars.

There will no longer be an explicit requirement to gain a particular number of hours of CPD from “external events”. However, members are encouraged to partake in a variety of types of activity, including consideration / exchange of views from people outside of their organisation.

Removal of CPD recording requirement

Under the existing scheme, members required to complete CPD must record their activities online. This requirement is proposed to be removed under the new scheme, with members signing a declaration that they have complied with the requirements of the scheme at each membership renewal date.

As a result, the CPD year will move from the current 1^st July – 30^th June to 1^st September – 31^st August to align with the current membership renewal timescales.

The ability to record CPD activities online will remain available to those wishing to use it.

Changes to CPD audit and enforcement

Under the existing scheme, a proportion of members are selected for CPD audit each year, which requires them to provide evidence of the CPD activities recorded. It is proposed that this process would be removed under the new CPD scheme (although it would still apply for the 2019/20 CPD year). This would be replaced with “Reflective Practice Discussions”, where members would have a meeting (via telephone / video conference) with a member of the IFoA team to discuss their learning objectives, CPD outcomes and plans for future development.

Further guidance around reflective practice discussions will be published if the CPD scheme proposals are accepted and implemented.

It is unlikely that all members will be selected to do this each year. However, it would be a requirement for members prepare for such a discussion each year. Members would be encouraged to discuss this with their manager / colleagues as part of their regular appraisal processes.

As part of this change, it is also proposed that the enforcement provisions for breaches of the CPD scheme are removed. However, there may still be disciplinary action taken where the non-compliance with the CPD scheme is considered to breach the Actuaries’ Code (in particular relating to ensuring “competence” is maintained).

Next steps

The consultation runs until the 17^th April 2020.  A link to the full consultation paper as well as the survey that can be used to provide your thoughts can be found on the following page of the IFoA website: https://www.actuaries.org.uk/upholding-standards/regulatory-communications-and-consultations/current-consultations/consultation-proposed-new-cpd-scheme.

Additionally, if you’d like to hear more or ask questions before responding to the consultation, the IFoA are running a webinar on the 2^nd April 2020 at 16:00.  You can sign-up for this via a link on the webpage above.  If you are unable to attend, you may submit any questions you have via email – details are in section 6 of the consultation package.  The webinars will also be uploaded to the IFoA website.

Currently, there is no date for when the results of the consultation will be published.  However, no matter what you think of the proposed changes, there is some news that should be welcome for all.  In line with the proposals set out above, the IFoA have extended the current 2019/20 CPD year by two months until the 31^st August 2020 (previously 30^th June).  This is the date by which all CPD activities must be completed, with the customary additional month (to 30^th September) available for recording of activities online.  Equally, if you will have already met your CPD requirements for 2019/20 by 1^st July, then there is the option to count any activities carried out in July or August to the 2020/21 CPD year if you wish.

Ross Gordon

March 2020