My current employer requires 24 hours of continuing education/training yearly.  This involves annual ethics training, financial management, project management, management training as well as technical training.  Most courses/training opportunities are either internal to the organization or at professional meetings.  None of these provide continuing education credits and therefore would not satisfy the proposed requirement.  An additional requirement for 16 credits would be overly burdensome and unnecessary.

However, if this proposal becomes final, the effective date should be no less than two years after the regulation is final.  This will allow the same amount of time to earn 16 credits for the initial renewal as for subsequent renewals.