This comment is regarding:

"C. Of the 15 contact hours required for annual renewal, at least five hours shall be obtained in courses or programs that are live or real-time interactive. Included in the five hours, the following may be credited:"

I do not support this new an onerous requirement. Mandating live CE is simply adding additional regulatory interference/burden, as there is no justification provided for why live CE is beneficial for the pharmacist, government, or patient safety. If there was research supporting live CE in association with better/safer pharmacy practice, I would support this. Having been a pharmacist for over 20 years, and completing various types of CE for licenses in different states, I find no association with live vs. written CE and better education outcomes. The impact of CE is unlikely associated with live vs. written CE, and much more likely to be associated with the professional's committment to learning. Why would this new requirement be instituted? There is no rationale, and it will result in greater work on the pharmacists, the government officials keeping track of all of this, and there is no proof of any difference in outcome. More work and more rules---without evidence of improved results (nor a citation to postulate impiroved results)---sounds inefficient and wasteful. Please remove this requirement and focus on priority issues (opioid crisis, etc.)