While I am not opposed to continuing professional eduation requirements done right, the proposed rules appear to be unnecessarily burdensome and expensive for both registrants and the Board. Other states have effective programs that are much better. The most sigificant issue seems to be the requirement for board-approved Continuing Education Units. This may be particularly burdensome for registrants residing in another state. Some suggestions: The requirement for continuing professional competency should be based on Professional Development Hours (PDH), defined as a nominal contact hour of instruction or presentation. This term includes, but is not limited to CEUs. CEUs are typically expensive and not widely available. Experience in other states shows that PDH opportunities will be made available by professional societies at convienient times and low cost. Professional Development hours may include college courses, CEUs, correspondence, televised, videotaped and electronic courses such as webinars. PDHs may also include seminars, in-house courses, workshops or professional or technical presentations at meetings, conventions and conferences. Credit may also be give for teaching the above described PDHs, authoring papers, articles or books, and active participation in professional or technical societies. For example, see the rules in place in Mississippi. http://www.pepls.state.ms.us/WebCPCPDHLog.doc Another provision that should be considered would be to allow reciprocity to out-of-state registrants. For example, compliance with continuing professional competency requirements of another state. John Hamilton