The sample would not have to ensure statistical validity; however, if the results of pilot testing are inconsistent, then the sample would have to be expanded or, if the inconsistent results are outliers, the inconsistent results would have to be eliminated. CPE credit would have to be recommended based on the representative completion time for the sample. Completion time would include the time spent taking the qualified assessment. Pilot testers would not be informed about the length of time the program is expected to take to complete.

The AICPA and NASBA have also proposed some clarifying changes to the standards. For instance, the draft proposes changing the definition of blended learning programs to include both asynchronous and synchronous learning activities; changing the definition of nano learning programs to require that such programs be a minimum of 10 and a maximum of 20 minutes each (and removing references to a tutorial program people found confusing); and defining a "subject matter expert" as "a person who has expertise in a particular area or topic. Expertise may be demonstrated through practical experience or education, or both," 

The standards were last revised three years ago, when the concepts of "nano learning" and "blended learning" were first introduced. The Society commented on the initial proposal in October in a letter. While it acknowledged the growing popularity of nano-learning modules, it warned that CPAs should not be able to rely on such courses for the bulk of their professional development, and so suggested an upper limit for how much nano-learning can account for one's total CPE credit. 

"We ask if the Joint Committee has considered limiting the number of nano-credits that may be earned by a participant. We believe that if true education is desired, too many credits earned exclusively through a nano format may not meet the Joint Committee’s ultimate objective, which is to educate and maintain the professional competence of a CPA practitioner," said the Society. 

At the same time, the Society also said that the criteria for when a nano-learning credit can be earned could be broadened: It said that requiring that the credit be awarded only through lessons delivered through electronic media, without any interaction with a real-time instructor, was too restrictive. It suggested allowing for a live self-study program or using other means, such as conducting research reviewed by a competent professional or subject matter expert. The Society urged the NASBA and AICPA to consider these alternatives.