Pandemic-related CPE exceptions granted to auditors under GAGAS

By Ken Tysiac

The U.S. Government Accountability Office (GAO) is providing three exceptions to continuing professional education (CPE) requirements for auditors performing engagements under generally accepted government auditing standards (GAGAS) for circumstances related to the coronavirus pandemic.

In an alert that is effective Feb. 29, 2020, the GAO explained that auditors’ ability to complete the hours of CPE required by government auditing standards has been affected by the pandemic.

Under Paragraph 4.16 of the 2018 Revision of GAGAS, in every two-year period auditors are required to complete at least 80 hours of CPE. This CPE must consist of at least:

  • Twenty-four hours of CPE on subject matter directly related to the government environment, government auditing, or the specific or unique environment in which the audited entity operates; and
  • Fifty-six hours of CPE on subject matters that directly enhance auditors’ professional expertise to conduct engagements.

In addition, under Paragraph 4.17, auditors are required to complete at least 20 hours of CPE in each year of the two-year periods. The alert provides the following exceptions to the CPE rules for GAGAS auditors:

  • Six-month grace period for completing CPE: For two-year CPE periods that end Feb. 29, 2020, through Dec. 31, 2020, auditors who have not completed the 80-hour or the 24-hour CPE requirements for the two-year period may have up to six months immediately following the two-year period to make up the deficiency. Any CPE hours completed toward a deficiency in one period may be documented in the CPE records and may not be counted toward the requirements for the next period.
  • Waiver of 20-hour annual CPE requirement: Auditors are not required to complete at least 20 hours of CPE for a one-year period that ends Feb. 29, 2020, through Dec. 31, 2020.
  • Carryover of CPE: From the audit organization’s two-year period in effect on Feb. 29, 2020, auditors may carry over up to 40 hours of CPE, in excess of the 80-hour requirement, to the next CPE measurement period. Auditors cannot count CPE hours carried over from one CPE measurement period to the next toward the 24-hour requirement. For two-year periods ending after Dec. 31, 2020, only CPE hours earned through Dec. 31, 2020, may be carried over.

The GAO also clarified that if an auditor is working, including teleworking, auditors may not use the existing GAGAS CPE exemption in Paragraph 4.29, which grants exceptions for illness, maternity or paternity leave, extended family leave, sabbaticals, leave-without-pay absences, foreign residency, military service, and disasters.

Ken Tysiac ( is the JofA’s editorial director.


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