The benefits of required continuing education as maintained by this regulation are questionable at best and the implementation as described is clearly flawed.  As many others have already commented to stay relevant in our chosen practice we as common practice are constantly undergoing “continuing education.”  Ever changing laws, regulations, standards and methods require that competent professionals continuously pursue training.  To now mandate that we have to complete a specific amount of training but only if it meets certain requirements, is within a certain timeframe and that won’t be approved in advance is overly burdensome and quite possibly could be detrimental.  I can easily see a case where a busy professional who only has time for a limited amount of training may shy away from attending the training that they truly need in favor of an approved class in an area they are already familiar with because they aren’t sure if the training the truly need is approved or if it will give them the required hours.  The economic analysis, which appears very cursory, and seems to rave about the fact that company's providing continuing education will get a boost in the business; seems to ignore the fact that a lot of the training that we are already pursuing will have to be forgone because we are unsure if it will meet board approvals or it may not come with CEU’s.  While I question the benefits of implementing this Regulation, if it does move forward it is imperative that the Board either clearly spell out a process for approving training in advance or tailor a provision that we as competent professionals should be capable of determining if the training and classes that we have already been taking as a matter of practice meet the parameters of continuing education.