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Two Clarifications about Continuing Education for SAPs

Do I need a certificate that indicates when my 3-year qualification expires?

No.  You don’t need a certificate that says you are qualified until a specific date.  And here’s why:
40.281(d) says that a SAP must obtain 12 professional hours relevant to performing SAP functions “during each three-year period from the date on which you satisfactorily complete” your SAP Exam.  This means that if the date of your original qualifying SAP Exam was May 11, 2007, your 3-year periods end on these dates:

  • May 11 2010
  • May 11 2013
  • May 11 2016
  • May 11 2019
  • May 11 2022
The date, May 11, NEVER CHANGES.  It will ALWAYS be May 11, regardless of when you obtain your continuing education hours.  Therefore, you don’t need a certificate every three years. 

But you do need documentation that you have obtained 12 professional development hours relevant to SAP functions.  Every employer or EAP or SAP broker who uses your services will simply have to figure out which courses or trainings fit into which 3-year period.  For that reason, you will be expected to always send evidence of your Qualification Training, your SAP Exam (with your SAP Exam date), and evidence of your 12 hours for every 3-year period that you have been qualified.  (Yes, this is a paperwork nightmare, but until DOT comes up with a central certification system, it’s the only way this can work.)

The date that auditors look for is the actual date of the SAP Exam, not the last day of the month in which you completed your SAP Exam.  You became qualified on the date that you passed the SAP Exam, not 2 or 3 weeks later.

You can obtain your 12 hours in increments (for example, 3 courses of 4 hours each, at different times during a 3-year timeframe), or you could do it in a single course or training of at least 12 hours, anytime during a 3-year period.  DOT requires only that all 12 hours must occur sometime during each 3-year period, and before your expiration date.  The actual dates of your continuing education hours don’t affect your expiration date, or change it in any way.

Each training or course or module that you complete must include what DOT calls a “documentable assessment tool.”  DOT has intentionally not called it a “SAP Exam.”  It is a test or a quiz on the materials covered.  That “assessment tool” is merely a way for you to determine how effectively you learned the material that was presented.

Not every employer or SAP broker understands this part of the rule.  Some wrongly add 3 years to the date of your most recent continuing education document.  Depending on when you completed that module, an employer could be asking you to spend time and money ahead of your actual expiration date.  When that happens, it may be necessary for you to explain this to whomever is telling you that you need 12 hours now.
 

I missed my 3-year continuing education requirement. What do I do now?

Let’s use the dates in the example above.  If you had obtained only 10 continuing education hours between May 11 2016 and May 11 2019, then you became disqualified on May 12 2019.  That means you can’t see any DOT clients, and you can’t perform any SAP services, until you have obtained all 12 professional development hours. 

If the lapsed time is only a few weeks or months, ODAPC does not want you to start over by taking a new SAP Exam.  ODAPC says that, if possible, you should make up these hours within a reasonable time and get back into qualification.  For ODAPC, it’s perfectly okay to obtain these hours within a few days, weeks, even a few months of your expiration, as long as you don’t see any DOT clients while you are disqualified.  Once you have obtained those remaining hours, you are immediately qualified again, and you can provide SAP services.  You are back in business.  However, you still need to obtain another 12 hours before the expiration date, and the expiration date hasn’t changed.

However, if your period of disqualification runs into years, (because you have been out of the country for a couple years, or your job description changed and you no longer provided SAP services for your employer, or for some other reason you have not kept up your qualification requirements), ODAPC says it would then make sense for you to start over by taking another SAP Exam.  That will give you a new qualification date. 

What ODAPC wants to avoid is taking another SAP Exam when your lapsed qualification has been only few weeks or months, since that will cause confusion on the part of auditors who may be reviewing your records.  Once the Clearinghouse starts next January, a second qualification date may also cause confusion on the SAP's registration on the Clearinghouse.  (In addition, taking a new SAP Exam also defeats the purpose of learning “new materials”, since a SAP Exam will more likely test you on what you already know, and in some cases it might even be the very same SAP Exam that you completed a few years ago.)

Just a reminder:  Your Profile on SAPlist should include ALL your SAP continuing education from the time that you became qualified.  Many employers look closely at those hours, because they don’t want to face a fine for using a SAP whose qualification lapsed.  If they think that you haven’t kept up DOT's qualification requirement, they might pass you by when they look for a SAP.  Unfortunately, there are a few SAPs on SAPlist who have been qualified for 15 years, but which show 12 hours of continuing education for only one 3-year period.  Your Profile should show 12 hours for every 3-year period following the date of your qualifying SAP Exam.

Training Summary on SAPlist
SAPlist has designed a page in your account to help you keep track of your continuing education requirement.  To see your customized page, do the following:

  1. Log into your account
  2. You will be redirected to your My Account home page. From here, navigate to My SAP Training > Training Summary
If you have not yet added your SAP exam date(s) and continuing education module completion dates, you can do so first at My SAP Training > SAP Training Dates. The Training Summary page will automatically update based on your date submissions.
My Account - Training Summary

EAPA SAP Training - St. Louis - September 28-29

EAPA will be offering a 2-day SAP Qualification and Update Training in St. Louis, following the world conference.  For information, and to register, www.eapassn.org

EAPA Training Registration

SAPlist UREMINDER: SAPlist U For Your Continuing Ed Requirement

SAPlist U provides 12 hours of continuing education related to DOT's testing rules.  It is endorsed by EACC, NASW, and NBCC.  It’s online, convenient, and you can complete it at your own pace.

Go to SAPlist U Continuing Ed
Until next time,

Lee Mauk signature

Lee Mauk  |  SAPlist.com and SAPlist U
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