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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4/7/08  4:48 pm
Commenter: John G. Kuykendall, PE, Virginia Tech

CE is REQUIRED, Post Constructive Comments
 

Fellow registered PROFESSIONALS,

As someone noted in one of the many comments above, the Board is REQUIRED by Virginia State Code, Amended and Approved in April 2006, to promulgate regulations for continuing education required for registered engineers, surveyors and architects.  The amendment REQUIRES the completion of the equivalent of 16 hours of CE per biennium as a prerequisite for renewal or reinstatement of their certification, and REQUIRES that the Board shall establish the criteria for such continuing education.  Read the Code, that's what is required, we don't get to "vote" on it!  The time for that was when the legislation was going through the General Assembly.  Talk to your legislator about why he/she voted for or against it.

Instead of complaining, suggest some reasonable guidelines for the CE requirements to the Board, so that they won't be so burdonsome.   I would suggest the following:

  1. CE requirements should focus on updating and/or expanding the professional's knowledge of current practices, new technology, regulations, etc.   Allowable CE content should not be limited to the professional's primary discipline, but should allow other areas of learning.
  2. Board criteria for CE credits should be specific enough so that professionals KNOW that the coursework taken will be allowed.  They should not have to be subject to later audits.
  3. Carry-over credit should be allowed, so that excess credits earned during the biennium can be applied toward future renewal periods.  This seems to be a matter of Code interpretation.
  4. Coordinate the requirements with other states requiring CE's for re-certification, so that professionals holding multi-state registration are not unduly burdened.
  5. Provide specific guidance regarding the allowance of "webinars", "lunch-and-learn", on-line coursework and other more recent teaching venues towards the CE requirements. 
  6. Ensure that the CE requirements are structured so that they do not place an undue or unfair burden of time or expense on the professional to maintain their cerfication.
  7. Allow other non-structured learning experiences to substitute for formal continuing education requirements.  Possibly allowing participation on technical advisory boards or committees, regulator boards or similar experiences as a substitute for classroom contact minutes.
  8. Consider specific waivers of the CE requirements, as allowed by the Amended Code, for special situations such as non-practicing professionals, retirees, etc.

Thanks to the Board for the opportunity to comment on the Proposed Regulations.

CommentID: 1364