The IRCA interview
INform talks to IRCA's director, Simon Feary, about the latest on IRCA's continuing professional development (CPD) requirements
IRCA introduced CPD as a certification requirement seven years ago.
At the time this was a fairly significant amendment to the certification
requirements. Has it been a success?
Before I answer the question, we need to remind ourselves of the intended purpose of CPD. The output of the CPD requirement is an improvement in auditor competence. Not, as some have argued, just another requirement with no relevance.
It has definitely been a success. Since its introduction we have seen the old auditing standard 1011 replaced by ISO 19011 and ISO 9001:2000. In the absence of any requirement for CPD we would have much less confidence that the majority of auditors certified prior to those events would be able audit effectively against and to these new standards. Although the CPD system is not foolproof nor is it perfect, in our view it is a significant and very worthwhile mechanism for improving auditing competence.
How have auditors reacted to the requirement?
At the time most accepted it without argument. There were those, mostly from the mature markets of UK, USA and Australasia who had been auditing for many years and who considered that any requirement for further learning was at best an imposition and at worst an insult. But most accepted our argument that incorporating a requirement for CPD was not only necessary and beneficial, but that it was a generally accepted practice amongst professions.
Were there difficulties?
There were two significant difficulties, which remain today. The first is encouraging auditors to take advantage of the huge range of activities that could enhance their competence, and which therefore constitutes legitimate CPD. The second is simplifying the bureaucracy that inevitably accompanies measuring and verifying these activities. We want auditors to take maximum advantage of the former, while reducing the prohibitive effects of the latter.
As an example, we accept that literature is a very valuable source of information and instruction, and have to recognize that studying this literature is a valid CPD activity. But how can we verify that someone has read a book? At one extreme we could approach this by not accepting any activity that cannot be verified. At the other extreme, we would accept without question all such 'soft' claims.
We debated at some length all these aspects as part of the process of developing the specification for the CPD requirement, and decided to pitch our approach somewhere between the two. We recognized if we were to achieve the maximum benefit from the CPD concept, then we would need to be flexible and open-minded in the way we evaluated CPD claims.
First, we accepted that the main priority was to make auditors more competent. This was far more important than the second priority, which was to verify CPD activities. And overall, the system had to be simple, easy for auditors (and for the evaluators) to understand and to comply with.
What we needed was a structure and adequate guidance - a structure that would encourage auditors to consider the whole range of activities available. But we needed some safeguards to reduce the temptation of some auditors to 'shortcut'. And guidance as to what we considered appropriate, and would accept.
Have you any recommendations for improving the requirements?
There is more we could do to clarify the concept of CPD to auditors. What we want to achieve is for auditors to manage their own competence, so understanding the concept of conducting a personal skills audit, identifying gaps in their own competence and addressing those gaps. Different auditors will have different needs, and no one approach fits all. This has to be one of the shortcomings of the CPD requirement, which is that we are imposing an arbitrary number of hours on everyone, where some will require less than ten hours and others more than 50. We want auditors to take greater responsibility for their own competence and training.
And finally, why 45 hours every three years?
Actually, it started out as 15 hours a year, a number proposed by us, based on the IQA's requirement for CPD points. We managed to get the International Auditor and Training Association to accept this figure although, as I recall, there was some very vigorous debate between those that didn't want any CPD at all and those that wanted at least 75 hours. 15 was an accepted compromise.
When IRCA reviewed this when developing its own CPD requirements, the 15 hours per year was changed to 45 hours every three years on the basis that there was no valid rationale to penalize someone for uneven distribution of their learning activity during their certification period. And most auditor certification bodies have followed our lead with 45 hours per three years now being the established norm.
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