Having intially been licensed in a state that requires continuing education as part of licensure renewal and evidence of continued competency, I applaud the board for looking at this matter.  I have been practicing practical nursing in the metro DC area since 1981 and have been amazed that none of the three jurisdictions required continuing education.  I do believe the board needs to take caution with several areas:

• Continuing education is costly, and when mandated it often becomes more costly.  Given that you are about to raise licensure fees again, the board must excersise restraint in the fiscal demands in puts on those licensed in Virginia;
• As noted by other writers, continuing education, publications and other proposed areas of proof of competency, do not necessarily provide same; and
• What is the fiscal cost to the Board, will this new regulation cause fees to be even higher?

Thank you for the opportunity to comment.