Members of the Board:

My colleague, Joe Foley, D.C., has petitioned the Board of Medicine to amend the continuing education (CEU) requirements for Doctors of Chiropractic (D.C.). I am writing in support of eliminating the “clinical” CEU requirement but strongly oppose the proposed new in-person requirement for the required hours.

If the Board’s intent is to simplify requirements per Governor Northam’s directive while fulfilling its responsibility to protect public safety, removing the “clinical” requirement could benefit both the profession and the public by encouraging chiropractors to stay up to date on HIPAA, OSHA, the No Surprises Act, Medicare regulations, and other administrative obligations critical to compliant, safe practice. There is no public benefit in losing access to a competent provider simply because they fell behind on the complex web of non-clinical regulations.  This portion of the proposal, I support.

In contrast, imposing a new in-person CEU requirement seems inconsistent with approaches taken by other regulated professions. For example:

• Massage therapists, despite recent public concern over boundary violations, are not required by the Virginia Board of Nursing to complete in-person CEUs.
• Realtors ® are permitted to complete all continuing education online—despite operating in fields with significant ethical and legal responsibilities.
• Medical doctors in Virginia, similarly, are not bound to in-person CEU formats.

Why, then, single out Doctors of Chiropractic?

Moreover, does in-person learning demonstrably reduce unethical or illegal behavior in health care practitioners? If such a belief exists, is it backed by evidence?

If there were data showing that D.C.s have significantly higher rates of ethical lapses or substance abuse compared to other professionals, one might consider whether in-person CEUs could help. However, I am not aware of such evidence. In fact, challenges related to substance abuse and boundary violations are shared across many health professions. Targeting D.C.s with additional regulatory burdens seems to solve a problem that has not been shown to exist.

Finally, I urge the Board to consider the issue of provider burnout, a major threat to public health. A recent study published in Mayo Clinic Proceedings involving 7,643 participants concluded:

“Occupational distress in physicians remains markedly elevated relative to the US workforce. Meaningful, evidence-informed intervention is needed from government, payers, and health care organizations to address these issues.”

Requiring in-person CEUs only adds to this burden. Providers should be able to choose the format—online or in-person—that best suits their learning style, schedules, and educational needs. Trusting professionals to make those decisions is both practical and respectful.

In conclusion:  Though (if regulations so permit) I personally may choose in-person learning settings for some or all of my requirements, retaining the option for fully online continuing education supports provider well-being and, by extension, patient care. Thank you for your thoughtful consideration and for your service to the public.

Sincerely,

~Daniel A. Shaye, D.C.

Williamsburg, VA