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Washington, DC 20548

This alert is effective as of February 29, 2020.

The work of auditors and their ability to complete the hours of continuing 

professional education (CPE) required by the 2018 generally accepted 

government auditing standards (GAGAS) have been affected by the 

Coronavirus Disease 2019 (COVID-19) pandemic.1 In this alert, GAO is 

providing three exceptions to the GAGAS CPE requirements for 

circumstances related to the COVID-19 pandemic. This alert also clarifies 

an existing GAGAS exemption that may be used in this situation.

GAGAS CPE requirements are located in 2018 GAGAS paragraphs 4.16 

through 4.18, with application guidance provided in paragraphs 4.19 

through 4.53. Under GAGAS, auditors are required to complete at least 

80 hours of CPE in every 2-year period as follows.

CPE hours Subject matter categories of CPE

24 hours Subject matter directly related to the government environment, 

government auditing, or the specific or unique environment in 

which the audited entity operates

56 hours Subject matter that directly enhance auditors’ professional 

expertise to conduct engagements 

In addition, auditors are required to complete at least 20 hours of CPE in 

each of the 2-year periods.

This alert does not remove the requirement for auditors to complete 80 

hours of CPE as noted above, and an audit organization may not change 

its 2-year CPE period because of circumstances related to the COVID-19 

pandemic.

This alert applies to GAGAS CPE requirements only. These exemptions 

and exceptions do not apply to CPE requirements of other professional 

organizations or other licensing bodies, such as those that license 

certified public accountants.

 1GAO, Government Auditing Standards: 2018 Revision, GAO-18-568G (Washington, 

D.C.: July 2018).

Letter

2018 GAGAS CPE 

Requirements
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Exception provided: For 2-year CPE periods that end February 29, 2020, 

through December 31, 2020, auditors who have not completed the 80-

hour or the 24-hour CPE requirements for the 2-year period may have up 

to 6 months immediately following the 2-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. Auditors who have not 

satisfied the CPE requirements after the grace period may not participate 

in GAGAS engagements until those requirements are satisfied. This 

modifies existing 2018 GAGAS paragraph 4.44, which allows audit 

organizations to grant a 2-month grace period.

Figure 1: Six-Month Grace Period for Completing CPE

Example: An audit organization’s 2-year CPE period ends on June 30, 

2020, and an auditor has only completed 50 hours of CPE as of June 30, 

2020, because of circumstances related to the COVID-19 pandemic. The 

auditor may take until December 31, 2020, to complete the 30 additional 

hours of CPE. The auditor may only apply the first 30 hours completed 

during the grace period to the previous period ending June 30, 2020, and 

may not apply those hours to the reporting period ending June 30, 

2022. If the auditor has not completed the 30 hours of CPE as of 

December 31, 2020, the audit organization may not allow the auditor to 

conduct GAGAS engagements until those requirements are satisfied.

Exceptions for 

Circumstances 

Related to the 

COVID-19 Pandemic

Six-Month Grace Period 

for Completing CPE
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Exception provided: Auditors are not required to complete at least 20 

hours of CPE for a 1-year CPE period that ends February 29, 2020, 

through December 31, 2020.

This is an exception from 2018 GAGAS paragraph 4.17, which requires 

auditors to complete at least 20 hours of CPE in each year of the 2-year 

period.

Figure 2: Waiver of 20-Hour Annual CPE Requirement

Example A: The first year of the audit organization’s 2-year CPE period 

ends on June 30, 2020, and an auditor completed 10 hours of CPE for 

that year. Under this exception, this auditor is not required to complete 

the 20 hours of CPE in the year ending on June 30, 2020, but is required 

to complete the remaining 70 hours, including any of the unmet 24-hour 

government CPE requirement, by June 30, 2021.

Example B: The second year of the audit organization’s 2-year CPE 

period ends on June 30, 2020, and an auditor completed only 10 hours of 

CPE for that second year but had completed 70 hours in the first year and 

had met the 24-hour government CPE requirement. Under this exception, 

this auditor is not required to complete the 20 hours of CPE in the year 

ending on June 30, 2020.

Exception provided: From the audit organization’s 2-year period in effect 

on February 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. 

For 2-year CPE measurement periods ending after December 31, 2020, 

only CPE hours earned through December 31, 2020 may be carried over. 

Auditors may not carry over excess CPE earned in prior 2-year CPE 

periods.

Waiver of 20-Hour Annual 

CPE Requirement

Carry Over of CPE
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This is an exception from 2018 GAGAS paragraph 4.45, which provides 

that auditors may not carry over CPE hours earned in excess of the 80-

hour requirement from one 2-year CPE measurement period to the next.

Auditors cannot count CPE hours carried over from one CPE 

measurement period to the next toward the 24-hour requirement for 

subject matter directly related to the government environment; 

government auditing; or the specific, unique environment in which the 

audited entity operates. CPE hours carried over cannot be used to meet 

the 20-hour annual CPE requirement. 

Figure 3: Carry Over of CPE

Example: An audit organization’s 2-year CPE measurement period ends 

on June 30, 2020, and an auditor has already met the current 2-year 

period’s CPE requirements as of March 1, 2020. With the exception

provided, the auditor may carry over up to 40 excess hours of CPE 

earned in the current 2-year period to the CPE period that lasts from July 

1, 2020, through June 30, 2022. This would include CPE hours earned 

from March 1, 2020, through June 30, 2020. The auditor may not apply 

the carry over CPE hours to the 24-hour government requirement or the 

20-hour annual requirement. Also, the auditor may not carryover CPE 

from the 2-year CPE periods ended June 30, 2018, and prior.

For auditors who are not able meet the GAGAS CPE requirements in 

2018 GAGAS paragraphs 4.16 and 4.17, 2018 GAGAS paragraph 4.29 

provides the following:

The audit organization, at its discretion, may grant exemptions from a 

portion of the CPE requirement in the event of extended absences or 

other extenuating circumstances if situations such as the following 

prevent auditors from fulfilling those requirements and conducting 

engagements:

Clarification of 

Existing GAGAS CPE 

Exemption
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a. ill health,

b. maternity or paternity leave,

c. extended family leave,

d. sabbaticals,

e. leave without pay absences,

f. foreign residency,

g. military service, and

h. disasters.

The audit organization may not grant exceptions for reasons such as 

workload, budget, or travel constraints.

Clarification: If the auditor is working, including teleworking, audit 

organizations and auditors may not use this exemption. The exemption 

provided for under 2018 GAGAS paragraph 4.29 can only be used if the 

circumstances prevent the auditor from both fulfilling the CPE 

requirement and conducting GAGAS engagements. An exemption may 

be used, for example, if an auditor or the auditor’s dependents become ill, 

and the auditor is not able to work on GAGAS engagements. The audit 

organization may use its discretion to determine the portion of CPE hours 

from which the auditor is exempted. Audit organizations may consider 

prorating the requirement based on the number of full 6-month intervals 

remaining in the CPE period, as discussed in 2018 GAGAS paragraphs 

4.42 and 4.43, but prorating using this calculation is not required.

Example A: An auditor contracted a serious illness and was incapacitated 

for 6 months. The auditor took leave and did not work for those 6 months. 

The audit organization may grant the auditor an exemption from a portion 

of the CPE requirements.

Example B: An audit organization closed its offices because of the 

COVID-19 pandemic. An auditor was able to telework and continued to 

work on GAGAS engagements, but was unable to complete the 80 hours 

of CPE by the end of the audit organization’s 2-year period. The audit 

organization may not grant the auditor an exemption from a portion of the 

CPE requirements as described in 2018 GAGAS paragraph 4.29. 

However, the auditor can use the 6-month grace period and the waiver of 

20-hour annual CPE requirement described above.
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To view a copy of the 2018 revision of generally accepted government 

auditing standards (the Yellow Book), visit 

https://www.gao.gov/yellowbook.

For technical assistance, call (202) 512-9535 or e-mail 

yellowbook@gao.gov.

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