December 1, 2020
March 4, 2021 Update: Both Licensed and Registered CPAs have been receiving a yellow postcard in the mail regarding the sexual harassment prevention training requirement. This card is misleading as it would appear to have been sent from the Illinois Department of Financial and Professional Regulation (IDFPR--the licensing body for CPAs) regarding a licensure renewal requirement for all CPAs. IDFPR (who we have alerted) did not sent this postcard; it came from a continuing education vendor. Contrary to the assertions in the postcard, Registered CPAs do not have to complete this requirement as Registered CPAs do not have a CPE requirement. Licensed CPAs will be required to complete one hour of continuing professional education (CPE) in sexual harassment prevention in order for license renewal as outlined below.
The purpose of this Regulatory Alert is to remind CPAs of compliance requirements for all Illinois employers to provide employees with sexual harassment prevention training by December 31, 2020. Separately, Illinois licensed CPAs are also required to complete one hour of continuing professional education of sexual harassment prevention training for their 2021 license renewal.
EMPLOYER TRAINING REQUIREMENT
The Workplace Transparency Act (Public Act 101-0221) requires all Illinois employers to provide annual sexual harassment prevention training to employees by December 31, 2020. This requirement is applicable to employers with employees working in the state of Illinois. Employers may develop their own sexual harassment prevention training program that equals or exceeds the minimum standards for sexual harassment prevention training outlined in section 2-109(B) of the Illinois Human Rights Act (IHRA), or may use the model sexual harassment prevention training developed by Illinois Department of Human Rights. (See IDHR Model Training).
-- “Employer” means an employer who has 1 or more employee(s)
-- All Employees, regardless of status, (short-term, interns, part-time et al) must be trained by December 31, 2020 and annually thereafter
-- Employers are not required to train independent contractors
-- There are additional requirements for restaurants and bars as outlined in Section 2-110 of the IHRA. (See also IDHR FAQs)
-- Employers are required to keep a record of all training and to make such records available to the IDHR for inspection upon request.
--Records may be a certificate of completion or sign-in rosters
--Records may be paper or electronic
Licensed CPAs will be required to complete one hour of continuing professional education (CPE) in sexual harassment prevention in order for license renewal. (CPA licenses expire on September 30, 2021). It is possible for CPAs to simultaneously complete the sexual harassment prevention training required by the Workplace Transparency Act and the CPE requirement if specified conditions are met. (See ICPAS On Demand Sexual Harassment and Prevention CPE)
Public Act 100-762 requires a one hour continuing education course that all licensed professionals who currently have a continuing education requirement must take and complete in order to be eligible for license renewal.
-- A licensed CPA may count the one hour completion of this training towards the 120 hours of CPE required for CPAs
-- The sexual harassment prevention (CPE) training course must be provided by an Illinois Department of Financial and Professional Regulation approved continuing education provider
--The Administrative Rules specify, at a minimum, the topics that shall be covered in the sexual harassment prevention continuing professional education training. 68 Ill. Adm. Code 1130.400
--Completion of the training shall be a condition of renewing your CPA license
--This requirement is effective for license renewals occurring on or after January 1, 2020
The Illinois CPA Society Government Relations Office will be providing you with additional information on the 2021 CPA license renewal process. Please direct questions to [email protected]