2021 ASPPA webinars not eligible for ERPA credits

Hello,

When I submitted my 2021-2023 renewal, I included many live and on-demand ASPPA webinars in my CEC counts, as I normally do (I don't normally pay attention to my PTIN record as I didn't think they normally rely on that). The IRS emailed me saying I was short a bunch of credits (all that weren't on my PTIN record), and that I had to submit the "IRS program numbers" for the courses in order to receive credit.

Upon requesting the program #s from ASPPA, I learned that none of their webinars that originally aired in 2021 (whether viewed then or on-demand in 2022) were eligible for ERPA credit. It appears that at least some of them had program #s at some point, and it seems like they were intended to qualify but something failed in the process (perhaps related to COVID?). Now I'm short a bunch of credits. I'm not able to find whether ASPPA originally communicated whether ERPA credit was available for each webinar, but I normally confirm that when I sign up.

Obviously, we need to monitor our PTIN records closely real-time.

Has this happened to anyone else? Were you able to resolve it with the IRS?

YES!

So I've had ERPA for a while, #373, and had successfully renewed twice before w/o any issue. The second time was w/o a PTIN as I let mine lapse when they were no longer required. My latest renewal in 2024 on my 21-23 cycle hit the same problem, all of a sudden they were looking at credits tied to PTINs (which they no longer required!). 

I too had accumulated a majority of credits through ASPPA and ASEA on-demand webcasts which stated they provided ERPA credit. However, the completion certificates that were issued by the website upon passing the quiz were not sufficient for ERPA documentation. I provided copies of all those non-compliant certificates to ASPPA customer service (I think) requesting the IRS program number. They re-issued ERPA compliant certificates to me for all those 2021-2023 sessions. There was one that they found did not count for ERPA. Certificates were signed by Chris DeGrassi, Chief of Retirement Education - all on 7/18/2024. Whoever told you they were not ERPA eligible probably just didn't want to be bothered. You only mentioned 2021 as an issue? ASPPA gave me 2021-2023, so I don't know how 2021 becomes an issue now.

I was told at the time that they were rectifying their website/process to "fix" this deficiency but looking at later 2024 sessions (under someone else's signature) the certificates are the old version. My guess is they figure there aren't enough ERPAs out there and no new ones possible, so why bother with the time and expense for a fix.

I think IRS would have accepted non-ERPA certificates and an itemized list of sessions with their IRS program numbers, but ASPPA provided compliant certificates. If you can't get satisfaction from ASPPA for 2021, send me an email with the courses you took in 2021 and if I took any of the same I can give you the IRS program numbers that were on my certificates.

Another IRS issue I encountered was that you needed 66 non-ethics credits and they only considered 6 ethics credits at 2 per year - so anything beyond that didn't count and was wasted credit, even though neither Circular 230 nor the 8554-EP form or instructions stated such. Since I had 72 with 7 or 8 ethics credits I had to take a course in 2024 to fulfill my 21-23 renewal requirement.

After all that, and being told I was renewed (which I've kept the email as proof), I never received my updated card in the mail, which supposedly they mailed out three times and verified the correct address. The same thing happened for my prior renewal, no card received in the mail, including a supposed second attempt then. I gave up on getting a new card, keep using my ERPA number and haven't had any issues in that regard. My next renewal comes up in 2027 and probably won't even bother.

Anyway, the last two issues are just me venting.

The conspiracy theorist in me thinks it's a concerted effort to hasten the elimination of the ERPA designation. 

Good luck and I'll help you if I can.

28 minutes ago, CuseFan said:

YES!

So I've had ERPA for a while, #373, and had successfully renewed twice before w/o any issue. The second time was w/o a PTIN as I let mine lapse when they were no longer required. My latest renewal in 2024 on my 21-23 cycle hit the same problem, all of a sudden they were looking at credits tied to PTINs (which they no longer required!). 

I too had accumulated a majority of credits through ASPPA and ASEA on-demand webcasts which stated they provided ERPA credit. However, the completion certificates that were issued by the website upon passing the quiz were not sufficient for ERPA documentation. I provided copies of all those non-compliant certificates to ASPPA customer service (I think) requesting the IRS program number. They re-issued ERPA compliant certificates to me for all those 2021-2023 sessions. There was one that they found did not count for ERPA. Certificates were signed by Chris DeGrassi, Chief of Retirement Education - all on 7/18/2024. Whoever told you they were not ERPA eligible probably just didn't want to be bothered. You only mentioned 2021 as an issue? ASPPA gave me 2021-2023, so I don't know how 2021 becomes an issue now.

I was told at the time that they were rectifying their website/process to "fix" this deficiency but looking at later 2024 sessions (under someone else's signature) the certificates are the old version. My guess is they figure there aren't enough ERPAs out there and no new ones possible, so why bother with the time and expense for a fix.

I think IRS would have accepted non-ERPA certificates and an itemized list of sessions with their IRS program numbers, but ASPPA provided compliant certificates. If you can't get satisfaction from ASPPA for 2021, send me an email with the courses you took in 2021 and if I took any of the same I can give you the IRS program numbers that were on my certificates.

Another IRS issue I encountered was that you needed 66 non-ethics credits and they only considered 6 ethics credits at 2 per year - so anything beyond that didn't count and was wasted credit, even though neither Circular 230 nor the 8554-EP form or instructions stated such. Since I had 72 with 7 or 8 ethics credits I had to take a course in 2024 to fulfill my 21-23 renewal requirement.

After all that, and being told I was renewed (which I've kept the email as proof), I never received my updated card in the mail, which supposedly they mailed out three times and verified the correct address. The same thing happened for my prior renewal, no card received in the mail, including a supposed second attempt then. I gave up on getting a new card, keep using my ERPA number and haven't had any issues in that regard. My next renewal comes up in 2027 and probably won't even bother.

Anyway, the last two issues are just me venting.

The conspiracy theorist in me thinks it's a concerted effort to hasten the elimination of the ERPA designation. 

Good luck and I'll help you if I can.

Thank you so much! This wasn't making sense to me, especially as they did initially provide me with some corrected certificates for 2021 then backtracked. 

I'll email you.

I also would not expect extra ethics credits to not count. Good to be aware of.

Neither I nor my business partner have ever received renewal certificates, and we've renewed several times. She also didn't receive credits under her PTIN for the same 2021 webinars and receive an email from the IRS.

I'm sure no one is thrilled with maintaining only a few thousand ERPAs.

 

I'm an Enrolled Agent with similar CE requirements as ERPA.  Although retired for a number of years, I've kept my EA active.  I carefully read and save any correspondence from IRS about my EA.  My renewal came up in 2024 and I submitted payment & renewal form online only to receive notice that I had insufficient CE for renewal.  I submitted all of my CE certificates and after considerable back & forth emails was told that CE not reported on the PTIN website would only be granted if the CE certificate has the IRS program number on it.  Some of this was my fault for not putting in my PTIN on the John Hancock or Erisapedia registrations, but I was unaware that it was required (having not received anything from IRS informing me of the new requirement).   I was able to pull program descriptions from the Erisapedia website that included the program # and resubmitted them to IRS.

From there, we went round and round via email and phone.  Finally, I filed an appeal with the Director of OPR in DC and pointed out that there was no legitimate notification to practitioners of the new IRS program # requirement or of the PTIN CE website requirement - here's what I included in my appeal:

1. OPR didn't publish (in the IRB) advance guidance of the requirement that CE had to be reported on the PTIN website or that CE certificates had to include the IRS program number.  Nor was I notified by letter or email of the new requirement. I scan and save all IRS correspondence related to my EA. I also save emails from IRS about my EA. I've searched my email and files and cannot find anything communicating this change in policy.

2. My IRS Letter 224B-(dated 5/25/2021) approving my 2021 EA renewal said nothing about the requirement that CE certificates include the IRS program number or that the CE must be reported on the PTIN website.

3. I've reviewed both Form 8554 (Application for EA Renewal) and the instructions for the form and there is no mention of the new requirement for CE to be reported on the PTIN website or CE certificates to include the IRS program # - https://www.irs.gov/pub/irs-pdf/f8554.pdf.

4. I've reviewed Publication 5186 (rev. 11-2022) and there is no mention of the new requirement for CE to be reported on the PTIN website or CE certificates to include the IRS program # -https://www.irs.gov/pub/irs-pdf/p5186.pdf.

5. I've reviewed your web page Enrolled Agent (EA) Renewal Reminders List (https://www.irs.gov/tax-professionals/enrolled-agent-ea-renewal-reminders-list) and there is no mention of the new requirement for CE to be reported on the PTIN website or CE certificates to include the IRS program #.

6. I've reviewed Circular 230 (rev. 6-2014, the current version) and there is no mention of the new requirement for CE to be reported on the PTIN website or CE certificates to include the IRS program # - https://www.irs.gov/pub/irs-pdf/pcir230.pdf.

7. After exhaustive searching, the only reference I could find to the requirement that a CE certificate must include the IRS program number was in FAQ 8 & 9 on your website (reviewed 7/29/2022) - FAQ #8 & #9 buried deeply in your website - https://www.irs.gov/tax-professionals/faqs-enrolledagent-continuing-education-requirements.  Please note that the IRS webpage entitled "General overview of taxpayer reliance on guidance published in the Internal Revenue Bulletin and FAQs" (https://www.irs.gov/newsroom/generaloverview-of-taxpayer-reliance-on-guidance-published-in-the-internal-revenue-bulletin-and-faqs) - includes the following directly below the title "The purpose of this reliance page is to confirm/explain that FAQs generally cannot be relied upon and describe authority that can be relied upon."

Maybe the above will be helpful in making your case - some of the Forms/Publications cited are for EA's rather than ERPA's, but you'll get the general idea.  My appeal was successful, but it took about 7 months from my initial renewal application to getting my renewal.  In my discussions with OPR, had the CE been disallowed, I would have had to make it up ASAP and then they'd process my renewal.

After all of that hassle, I'm watching my CE like a hawk - making sure every CE certificate shows the IRS program # and also checking that it shows up on the PTIN website.  I burnt a lot of time on the renewal that could have been better spent on the tractor.

I guy-read Cuse Fan's post and didn't catch the part about never receiving renewal cards.  You worked hard to earn your ERPA, not to mention your investment of time and money for CE.  As I recall I could get my renewal letter & card on the IRS website, which I think is a different login from the PTIN website.  If it's not there, I'd escalate that to the Director of OPR (if there's still anybody working there).  I did a lot of work for clients with IRS - it's a nice credential to have in your toolkit.

It seems like even though the IRS says you no longer need a PTIN if you are only preparing 5300 or 5500, in fact if you are an ERPA, you should maintain your PTIN and make sure all your CE gets reported to the IRS through the PTIN system.

I have also not received a new ERPA card so now I'm starting to wonder about my status.  The last card I received showed an expiration date of 2019.  Who do I contact about getting an updated card?  thanks!

Never mind, I found an email to use to contact the IRS about ERPA questions.

EPP@IRS.gov

On 5/5/2025 at 7:27 AM, ACK said:

Never mind, I found an email to use to contact the IRS about ERPA questions.

EPP@IRS.gov

 

My business partner has repeatedly requested an updated enrollment card by phone, and they always say they will send it but never do. Her most-recent one is 2012, mine is 2015. 

Last we knew, there was only one employee in the ERPA department. But it looks like it may now be handled by the regular EA staff?

Let us know if you're able to get the card!

On 5/2/2025 at 7:54 PM, Retired, but still reading said:

I'm an Enrolled Agent with similar CE requirements as ERPA.  Although retired for a number of years, I've kept my EA active.  I carefully read and save any correspondence from IRS about my EA.  My renewal came up in 2024 and I submitted payment & renewal form online only to receive notice that I had insufficient CE for renewal.  I submitted all of my CE certificates and after considerable back & forth emails was told that CE not reported on the PTIN website would only be granted if the CE certificate has the IRS program number on it.  Some of this was my fault for not putting in my PTIN on the John Hancock or Erisapedia registrations, but I was unaware that it was required (having not received anything from IRS informing me of the new requirement).   I was able to pull program descriptions from the Erisapedia website that included the program # and resubmitted them to IRS.

From there, we went round and round via email and phone.  Finally, I filed an appeal with the Director of OPR in DC and pointed out that there was no legitimate notification to practitioners of the new IRS program # requirement or of the PTIN CE website requirement - here's what I included in my appeal:

1. OPR didn't publish (in the IRB) advance guidance of the requirement that CE had to be reported on the PTIN website or that CE certificates had to include the IRS program number.  Nor was I notified by letter or email of the new requirement. I scan and save all IRS correspondence related to my EA. I also save emails from IRS about my EA. I've searched my email and files and cannot find anything communicating this change in policy.

2. My IRS Letter 224B-(dated 5/25/2021) approving my 2021 EA renewal said nothing about the requirement that CE certificates include the IRS program number or that the CE must be reported on the PTIN website.

3. I've reviewed both Form 8554 (Application for EA Renewal) and the instructions for the form and there is no mention of the new requirement for CE to be reported on the PTIN website or CE certificates to include the IRS program # - https://www.irs.gov/pub/irs-pdf/f8554.pdf.

4. I've reviewed Publication 5186 (rev. 11-2022) and there is no mention of the new requirement for CE to be reported on the PTIN website or CE certificates to include the IRS program # -https://www.irs.gov/pub/irs-pdf/p5186.pdf.

5. I've reviewed your web page Enrolled Agent (EA) Renewal Reminders List (https://www.irs.gov/tax-professionals/enrolled-agent-ea-renewal-reminders-list) and there is no mention of the new requirement for CE to be reported on the PTIN website or CE certificates to include the IRS program #.

6. I've reviewed Circular 230 (rev. 6-2014, the current version) and there is no mention of the new requirement for CE to be reported on the PTIN website or CE certificates to include the IRS program # - https://www.irs.gov/pub/irs-pdf/pcir230.pdf.

7. After exhaustive searching, the only reference I could find to the requirement that a CE certificate must include the IRS program number was in FAQ 8 & 9 on your website (reviewed 7/29/2022) - FAQ #8 & #9 buried deeply in your website - https://www.irs.gov/tax-professionals/faqs-enrolledagent-continuing-education-requirements.  Please note that the IRS webpage entitled "General overview of taxpayer reliance on guidance published in the Internal Revenue Bulletin and FAQs" (https://www.irs.gov/newsroom/generaloverview-of-taxpayer-reliance-on-guidance-published-in-the-internal-revenue-bulletin-and-faqs) - includes the following directly below the title "The purpose of this reliance page is to confirm/explain that FAQs generally cannot be relied upon and describe authority that can be relied upon."

Maybe the above will be helpful in making your case - some of the Forms/Publications cited are for EA's rather than ERPA's, but you'll get the general idea.  My appeal was successful, but it took about 7 months from my initial renewal application to getting my renewal.  In my discussions with OPR, had the CE been disallowed, I would have had to make it up ASAP and then they'd process my renewal.

After all of that hassle, I'm watching my CE like a hawk - making sure every CE certificate shows the IRS program # and also checking that it shows up on the PTIN website.  I burnt a lot of time on the renewal that could have been better spent on the tractor.

Thank you! This is helpful. I never ever receive anything from IRS regarding my ERPA other than the on-screen confirmation of filing/paying my renewals, and the email saying I'm missing a ton of CECs. My last renewal card is from 2015, so I always just have to assume everything's OK.