I hold licenses in five states.  New York State requires 1 professional development hour (pdh) per month.  The cost to obtain these is variable, from 0 to over $100.00 per pdh (1ceu=10 pdh).  Obviously, this cost must be accounted for, predictably in higher fees charged to clients.  Please do not compound these costs by requiring separate continuing education credits for each state of licensure.

New York State requires each professional to maintain a record of the courses attended during each renewal period.  These must be available if requested by the board.  This eliminates the need for lengthy renewal documents and for additional staff at the state level to review (check) the more involved license applications.

Therefore, I am asking the Board to review all of the comments received in making their decision as to whether to move forward with this proposal.  And if you decide to move on, look at what the other state's have done.  Don't reinvent the wheel.