12VAC5-31-1552 is an UNFUNDED MANDATE adding new & additional requirements to EMS providers who are educators of the system.  NO OTHER STATE IN THE USA REQUIRES THIS, so why is VA?  The Office of EMS staff were asked the other day by a person who is an instructor where can this additional educational requirement be obtained, these 12 hours of instructor specific education every 2 years.  Greg Neiman from VDH/OEMS stated  & I'm paraphrasing, "at colleges, institutions of higher learning & the VA Office of EMS Symposium", this of course is a state event that costs money to individuals, hotel stays in the hundreds of dollars per night in Norfolk, college tution rates at over $300/per credit hour x 12 hours.  Who's going to pay for this?  You are loading up the backs of Virginians who cannot afford to pay for this.  CLEARLY AN UNFUNDED MANDATE that NEEDS TO BE COMPLETELY REMOVED FROM THESE PROPOSED REGUALTIONS-TAKE IT OUT.  Keep the current system the way it is today, do not change anything that costs an individual money or additional time right now, money not one of us has.  Keep the government out of my wallet and my pockets.  NO TESTING OF CURRENT EMS INSTRUCTORS OR EDUCATORS EVERY RECERT PERIOD.  NO OTHER STATE IS DOING THIS SO WHY IS VIRGINIA?  If you say it is essential to test instructors, shouldn't the very people they train then be tested as well? That means every single EMS PROVIDER/FIREIFGHTER SHOULD BE REQUIRED TO TEST EVERY RECERT PERIOD WITH NO WAIVER if what you are saying is correct.  Bad business, bad idea, not needed, more mandates passed along to finacially strapped people in Virginia.  Government should not be interferring like this!  REMOVE THE REQUIREMENT TO TEST TO RECERTIFY THE EMS EDUCATOR EVERY 2 YEARS!