CBA committee backs stricter continuing-education provider rules, flags AI safeguards

The Committee on Professional Conduct of the California Board of Accountancy on Sept. 19 approved staff-recommended policy directions to tighten continuing education (CE) provider requirements, including new safeguards intended to address risks from artificial intelligence in course content.

The committee approved the directions after a staff presentation and discussion about learning objectives, course quality, participant engagement and testing methods. Sarah Benedict, manager of the Licensing, Renewal and Continuing Competency Unit, told the committee the proposals are intended to protect course quality and help licensees choose appropriate CE.

"Course content must be reviewed by a human subject matter expert other than those who developed the course," Benedict said, explaining that human review is intended to catch inaccuracies AI could introduce. She added providers must include publication, revision or review dates on materials and review course content at least every two years. "When using a human instructor, they must be competent and current in the subject matter through training, education, and or expertise," Benedict said.

Among the specific directions the committee approved are requirements that CE providers: disclose delivery mode, field of study, knowledge level and credit hours; have course content reviewed by a human subject-matter expert; include publication or revision dates and review content at least every two years; require one element of participant engagement per course hour (or one for courses under 30 minutes); permit through-course tests instead of only end-of-course tests; adopt a technology-failure policy; disclose and resolve conflicts of interest; retain documentation showing how CE credit was determined; and issue certificates of completion within 60 days of course completion. The committee also endorsed language to require a human instructor for all synchronous CE courses.

Committee members pressed staff on the practical implications of some requirements. Member Bridal asked how AI might harm CE content; Benedict cited "hallucinations" in AI-generated references and said a human review would be needed to verify citations and accuracy. Member Bridal also questioned whether synchronous sessions should require attendees to keep video on; Benedict said the NASBA standards require two-way enabled video for some formats but that alternative engagement methods such as polls may suffice. "Having your video on is not one of the, say, standards," Benedict said, adding that mandating video could reduce the pool of providers and would be out of sync with prevailing practice.

Jason Fox of the California Society of CPAs spoke during public comment and said the proposed directions align with practices used by many quality providers and that his organization supports safeguards and continued coordination with the board.

The motion to approve the staff recommendations for inclusion in a future rulemaking passed on a roll call vote. Benedict said staff would include the committee’s directions in a rulemaking package and bring any exposure drafts — including any revisions prompted by forthcoming NASBA/AICPA updates to national CE standards — back to the board for review.

The committee’s action directs staff to proceed with drafting regulatory language that would implement the approved policy directions; final regulatory text will return to the board for formal rulemaking steps.