1) Renewing registrants need to be allowed a full 24 months after the effective date of any adopted regulation, not just 12 months, to accumulate the required 16 continuing education credit hours. (The only equitable alternative would be to prorate the credit hour requirement for the renewal next following the effective date of regulations.)

2) No provision is made to allow continuing education credit for issuance of a patent to a registrant. As patent filings require research of prior art in some technical field, plus advancement of the state-of-the-art sufficient to persuade a patent examiner of its novelty, I find it most curious that such verifiable activity wouldn't qualify as continuing education. (Is this activity considered nonqualifying simply because it offers no economic benefit to "educator businesses"?)

3) No express provision is made to exempt retirees maintaining licensure from the added cost of continuing education, nor is there created a retired license status. (A retiree living on a reduced income shouldn't have to prove "undue hardship".)

4) No definition for "discipline" or "sanction" (new terms added by proposed regulation) can be found anywhere in the regulation language -- or in other sections of Virginia Administrative Code -- or anywhere in the underlying Title 54.1 (or anywhere in the Code of Virginia, for that matter). The accompanying phrase "or both" suggests that these two words convey separate & distinct concepts. But occurrences of the phrase "disciplinary sanction" in other sections of the Virginia Administrative Code don't help shed any light on the intended distinction.