My personal opinon is that continuing education is a good thing and this requirement is a long time in coming compared to our neighboring states like North Carolina.  Too many times have I met fellow professionals that refuse to look at innovative methodoligies,  new developments, and new technologies dismissing it out of hand as "unproven".

I find fault with the proposed text of the rules with the following:

• The proposed rules, in general, are vague, leave too much to interpretation, opinion of the Board members, and leave the licensee in a morass of unclear requirements.  More explicit implementation on what is acceptable education (such as the rules for NC Board) is needed.
• Implementation guideance is unacceptable.  I originally read that the full force of the requirement will be effect on the next renewal, in 2009 .  I think a gradual implementation, such as none for 2009 renewals, half requirements (8hrs) for 2010 renewals and full requirement (16 hrs) for 2011 renewals.
• I disagree with the non-carryover of excess CE hours.  Under the NC rules, a limit of the carryover hours are limited.  I think that up to half of the required (ie. 8 of 16) hours in excess of meeting the current requirement, should be allowed to be carried forward into the next renweal period.  Rarely do professionals acquire the exact amount of CEUs required.
• Exemptions to the CE requirement (similiar to those of the NC Board)  temporary active duty, inactive licensees, etc. should be included in the rules.
• I disagree with -683, 5.(f) as being vauge and having much possibility for mis-interpretation.  While I think the intent is not to have credit for the same CE course(s) year after year, harshly interpreted, taking CE courses on closely related subjects would be disallowed, even though the course is different.  Also, this rule does not allow for credit of new developments that may occur in subsequent renewal periods.

The Board could have done a better job with the proposed CE rules.

Link to the NC Board rules (http://www.ncbels.org/laws.htm).