CE Credits for ERPA

[Cynchbeast]

I just got off phone with an IRS agent in the Enrolled Agent department and I want to check the information I received with other ERPAs.

This concerns the requirement that you earn 72 hrs in 3 yr cycle with a minimum of 16 hrs each year (including 2 hrs ethics).  She told me that actually there is no 16 hour requirement as long as you get all the credits you need in the 3 years.

My current cycle is 04/01/16-04/01/19.  So I plan on going to a conference in November that will actually give me over 72 hours credit meaning all I need for 2018-2019 is a few hrs of ethics.  This is okay.

Does anyone disagree with this?  Does anyone have experience to the contrary?

And speaking of Ethics, does anyone know a good source for Ethics hours?

[RatherBeGolfing]

27 minutes ago, Cynchbeast said:

I just got off phone with an IRS agent in the Enrolled Agent department and I want to check the information I received with other ERPAs.

This concerns the requirement that you earn 72 hrs in 3 yr cycle with a minimum of 16 hrs each year (including 2 hrs ethics).  She told me that actually there is no 16 hour requirement as long as you get all the credits you need in the 3 years.

My current cycle is 04/01/16-04/01/19.  So I plan on going to a conference in November that will actually give me over 72 hours credit meaning all I need for 2018-2019 is a few hrs of ethics.  This is okay.

Does anyone disagree with this?  Does anyone have experience to the contrary?

And speaking of Ethics, does anyone know a good source for Ethics hours?

The problem is that the IRS is not consistent in how they enforce the CE requirements.  Circular 230 § 10.6 (e) (2) (i) states that you need 72 hours including 6 hours of ethics per enrollment cycle

230 § 10.6 (e) (2) (ii) states that you need a minimum of 16 hours of continuing education credit, including two hours of ethics or professional conduct, during each enrollment year of an enrollment cycle.

The requirement is clearly there.  Whether they follow the rules is a different question.  Unless you have it in writing that you can ignore  § 10.6 (e) (2) (ii), I would be very careful.  What happens if you get another person reviewing your renewal?  

I know people who have gotten renewals when they had less than 72 hours in a cycle or lacked the ethics credits.  They were told to do an additional credit in their next cycle.  I also know people who have had to fight tooth and nail to get their renewals because their paperwork never made it to the appropriate office even though they had proof of delivery.

Follow Circular 230 and you are always safe.  It isn't worth risking a credential that you can no longer test for.

[CuseFan]

From Form 8554 (ERPA Renewal):

• You must complete 72 hours of Continuing Professional Education (ERPA–CPE) over the three-year enrollment cycle to remain active. This must include at least 2 hours of Ethics CPE each year.

• Exception: If this is your first renewal, you have to complete 2 hours of CPE for each month you were enrolled, including 2 hours of Ethics each year.

If you have re-taken and passed the ERPA Special Enrollment Examination (ERPA-SEE) since your last renewal, you are only required to take 16 hours of CPE, including 2 hours of Ethics, during the last year of your current enrollment cycle.

The Form seems to confirm what the IRS agent said, although I agree with RBG with respect to following C230. 

On another note, what November conference provides over 70 hours of ERPA specific CPE? Heck, I would automatically renew you on the spot for sitting through that!

[Cynchbeast]

No, I already have a lot of credits.  The seminar is on cash balance plans from Datair and it is worth 20 hours - still a great deal.

And that puts me at over 72 hours with yet a year to go in my cycle.  All I am lacking is 4 hrs ethics, and so plan to still do that.

[thepensionmaven]

I do not see a problem, ASPPA AC has plenty of workshops that offer ethics credit as do their ethics webinar.

[MSN]

Make sure you pay attention to the recordkeeping requirements too.  I had the IRS reject a lot of my credits because I didn't adhere to the robust recordkeeping requirements. 

[Jim Chad]

I have never been to a Datair seminar.  How was it?

Was it live or on-line?