I have two comments on the proposed regulation.

I have been researching professional courses in anticipation of the regulation.  I would like to see the board address how courses will be credited with more specificity.  One class  I reviewed has 40 contact hours, awards 3 CEUs and has been accepted for up to 2 credit hours of university credit.  It is not clear from 18VAC10-20-683 how many continuiong education credit hours would be credited by taking this course.

I recommend the board and staff issue, after some appropriate review period, a listing of vendors who provide unacceptable training.  I have been to excellent training, and pathetic training.  I would like to see a vehicle to tell the board when a vendor was sub-standard, to help others from attending worthless training.  I would also hope the Commonwealth's assumption is that training is adequate until the board determines a provider is not acceptable -- this will prevent us from being penalized for being duped, but will also not allow us to seek out "easy" training just to check off a requirement.