Continuing education (CE) gets complicated fast when you’re licensed in more than one state. The NAIC’s Continuing Education Reciprocity (CER) Agreement was built to reduce that friction by allowing participating jurisdictions to accept CE courses approved through a home-state substantive review, rather than requiring duplicative approvals in every non-resident state.
The NAIC originally adopted the CER Agreement in 2004 and later refreshed it in 2019 through the NAIC Uniform Education (D) Working Group. For CE providers, agencies, and producers, the practical question is simple: does reciprocity apply in the states where you need credit—and are your internal workflows built to take advantage of it?
1) What the NAIC CER Agreement is (and why it exists)
The CER framework is intended to streamline multistate CE course approval for insurance producers. The core mechanism is operational: participating states can rely on a home state’s substantive review of a CE course, which reduces the need for each non-resident state to run a separate, duplicative review.
The 2019 CER Agreement also reflects modern CE delivery and filing realities. The NAIC’s materials include appendices aligned with electronic submission of CE courses for regulatory approval and delivery of CE through online platforms. For training teams, that’s not just background—it affects how you select courses, how you document approvals, and how you scale CE across a multistate producer population.
2) What changed in 2019: the “home state review” becomes more defined
The 2019 refresh didn’t just restate reciprocity—it clarified expectations. The updated agreement describes five steps for a home state’s substantive review of CE courses. For training operations, this matters because “reciprocity” is not a vague promise; it’s a workflow that starts with the home state review and then expands outward through reciprocity filings where available.
In practice, this affects:
- CE providers and education teams: how you package and submit courses, and how you track which jurisdictions will accept them through reciprocity.
- Agencies and compliance leads: how you choose CE options for multistate producers without accidentally creating gaps (for example, assuming a course will be accepted everywhere).
- Individual producers: how you plan CE so credits post correctly in each state where you hold an active license.
3) Participation is not universal—build a “state participation check” into your CE plan
The NAIC reciprocity page is a practical reference point. As of August 24, 2022, the NAIC indicates that 46 states/jurisdictions had signed the refreshed and consolidated 2019 CER Agreement. It also lists non-participating jurisdictions as American Samoa, Florida, Guam, Northern Mariana Island, and Virgin Island.
For CE compliance workflows, the key operational takeaway is: reciprocity is a verify-first item. Even where a state has signed, the NAIC notes that to be considered actively participating, a state’s Commissioner must sign and the state must also meet implementation-related conditions (such as needed policy/form changes and notifying providers of the start date for reciprocity filings).
Training implication: Treat reciprocity like a routing rule, not an assumption. Your CE selection and filing workflow should include a quick check of (1) whether the state participates and (2) whether it is actively accepting courses from other participating jurisdictions.
4) What to do now (CE students / active licensees)
If you’re a producer managing CE across multiple states, reciprocity can reduce friction—but only if you plan around it.
- Start with your license map. List every state/jurisdiction where you hold an active license and where you expect to renew.
- Confirm reciprocity status before you enroll. If you’re counting on a course to satisfy multiple states, verify whether each state is actively accepting reciprocal CE courses (and whether there are any state-specific requirements that still apply in your situation).
- Use a “home state first” mindset. When possible, choose CE that is clearly approved through your home state’s substantive review pathway and then accepted elsewhere via reciprocity, rather than assembling a patchwork of single-state approvals.
- Track posting and completion the same week. Reciprocity streamlines approval, not your personal compliance. Save completion certificates, confirm transcript posting, and keep a simple log by state so you can resolve issues quickly.
If you’re also studying for an initial license, use this as an early professional habit: treat compliance as a workflow. The same discipline that helps you pass an exam (structured plan, checkpoints, verification) is what prevents CE surprises later.
5) What to do now (managers / compliance leads / training admins)
For agencies onboarding producers and tracking renewals, the CER Agreement is a lever for standardization—especially for teams operating in multiple states. The goal is to reduce variability (different courses for different people), increase visibility (who is on track), and prevent last-minute escalations.
- Assign an owner for reciprocity decisions. Name a training admin or compliance lead who is responsible for confirming whether each state in your footprint is actively participating and for updating internal guidance when participation/implementation changes.
- Install a “reciprocity gate” in course selection. Before your team endorses a CE course/provider for multistate use, require a documented check of which jurisdictions will accept it via reciprocity and which require exceptions. Store the check result with the course in your approved-course list.
- Maintain a living “exceptions list” for your footprint. Use the NAIC list of non-participating jurisdictions as a starting point, then add internal notes for any state where your team repeatedly sees filing/acceptance friction. Review and refresh this list quarterly.
- Standardize evidence collection and audit retrieval. Require the same artifacts for every CE completion: course name/ID, completion date, certificate, and a transcript posting confirmation checkpoint. Store them in a consistent location so you can answer producer questions quickly and support audit-readiness.
- Run a 90/60/30-day cadence with escalation triggers. At 90 days confirm each producer’s state list and required hours; at 60 days confirm enrollments; at 30 days confirm completions and transcript posting. If any producer is missing enrollments or posting confirmation at a checkpoint, escalate to manager review the same week.
- Build reciprocity into onboarding. When new producers join, capture resident and non-resident states immediately, align them to your approved CE catalog (reciprocity-friendly where possible), and schedule their first CE planning check-in well ahead of renewal season.
Training implications for licensing prep and CE compliance
Even though CER is about CE course approval, it has direct training and compliance operations impact:
- For CE programs: Reciprocity supports a more scalable course strategy—fewer duplicative approvals and a clearer pathway to multistate deployment (where states actively participate).
- For producer development: Multistate producers can maintain a steadier learning rhythm when CE options are predictable and portable, reducing the “scramble” that often competes with sales activity and client service.
- For onboarding and exam-to-field transition: Teams that teach a structured study path for licensing exams can reuse the same operating model for CE: a plan, checkpoints, verification steps, and a miss-log style follow-up when credits don’t post as expected.
CTA: If you’re building a repeatable path for exam readiness and ongoing CE completion, explore TSI National’s licensing exam prep and continuing education options at https://www.tsinational.com/.
Source: Original article
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