These comments reflect my personal opinion and are in no way to be construed as representative of the U.S. Navy or any other organization/institution with which I am affiliated.

1552 Paragraph C, requirement for testing for EMS Education Coordinators. This is a new and potentially onerous requirement for active educators. While the Office's intent here is laudable and understood, successful conduct of multiple courses or C.E. programs demonstrates the Coordinator's familiarity with education program requirements and administrative processes. Suggest that in-person testing only be required for Coordinators with minimal teaching hours, Coordinators who have taught only C.E. versus initial certification programs, Coordinators with low certification pass rates, or some other screening criteria. Utilizing a screening criteria to identify Coordinators who are likely to have lapsed familiarity with program requirements will eliminate unnecessary testing costs for the state and unnecessary cost and inconvenience for active Coordinators.

The opportunity to comment is appreciated, and kudos to the OEMS and VDH on an overall very well done regulation update.