Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Board for Architects, Professional Engineers, Land Surveyors, Certified Interior Designers, and Landscape Architects
 
chapter
Board for Architects, Professional Engineers, Land Surveyors, Certified Interior Designers, and Landscape Architects Regulations [18 VAC 10 ‑ 20]
Action Develop regulations for a mandatory continuing education requirement for architect, professional engineer, and land surveyor licenses.
Stage Proposed
Comment Period Ended on 5/2/2008
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3/20/08  1:20 pm
Commenter: Darryl Merchant

Continuing Education
 

 

House Bill 1054 (54.1-404.2) Continuing Education

 

House Bill 1054 states that ‘The Board shall promulgate regulations governing continuing education requirements …..’  ‘Such regulations shall require the completion of the equivalent of 16 hours of  Board approved continuing education activities …..’.  ‘The Board shall establish criteria for CE activities including, but not limited to…..’

 

It appears that the legislative authors of  House Bill 1054 are giving broad authority to the Board to decide what type of continuing education is required.  I would encourage the Board to use a broad interpretation when attempting to implement this bill.

 

I would like to see the Proposed Regulations under 18VAC 10-20-683  be revised and/or include the following:

 

1. Under line item C 5 e, I would broadly interpret activity to include time spent by professionals in presentations to students in a ‘Career Day’, the supervision of events such as ‘Trig Star’, or other community service activities (Boy Scout Merit Badge instruction, etc).

 

2. Also broadly interpret activity to include a review of your professional practice, such as conviction of failure to comply with existing regulations.  I would recommend that any professional convicted of any non-compliance issue be required to complete the full 16 hours of CE, while those not receiving any convictions during the prior two year period be allowed a credit of up to 8  CE hours. 

 

3. Revise C 5 c to allow for 16 CE hours for 1 semester credit hour of approved college credit instead of 15 CE hours.

 

4.  The proposed regulations also include requirements that Sponsors of continuing education activities have sufficient resources to, among other things, document course completion records, etc.  I am a bit worried that due to the relative low number of Licensed Surveyors, as compared to Engineers and Architects, Sponsors of CE activities for Land Surveyors will be limited.  I assume that the Virginia Association of Surveyors will be such a Sponsor.

 

Since there are over 500 Virginia Surveyors who are not  members of the VAS, I hope that the possible lack of Land Surveyor CE Sponsors does not result in abuse by the VAS.  If the VAS were the only ‘Sponsor’ available for educational CE credits, the possibility exists that a different fee structure would exist for members and non-members, thus creating a de-facto endorsement of VAS membership by the Board.  I would encourage the Board to require that Sponsors charge the same fee for the CE activity offered, regardless of membership in the VAS or any other organization.

 

Darryl G. Merchant

Va. Lic. No. 1606

P.O. Box 1508

Front Royal, VA  22630

CommentID: 1160