I respectfully request the Board vote "no" for the proposed “in person attendance” requirement (for any number of hours); and rescind or reduce the separate Type 1 “clinical” category of CEU’s for chiropractors.

Addressing first the reasons against the new petition for “in person attendance”:

1. Chiropractors are unique from many other providers in our inability to provide care when away from our patients, as chiropractic services are typically performed in-person for our pain patients. An “in-person” CEU requirement forces providers to be unavailable to pain patients during travel and puts in place unnecessary logistics such as travel time and sometimes days away with travel for in person multi-day conferences.  With a virtual option, unavailability need not be an issue--for example attending a virtual partial day conference, then seeing patients for the remainder of the day--as well as eliminating travel time. Offering even more flexibility, virtual “On Demand” CEU’s eliminates the conflict with provider patient availability altogether, allowing providers to attend virtually outside of office hours, again without travel time.  With the virtual option, practice closure to complete CEU’s need not be an issue, but if the in-person attendance mandate is passed, provider availability to patients suffers.
2. I also urge the Board to consider the impact of pulling front line pain care providers from our practices during the ongoing Opioid Epidemic still being monitored closely by the Virginia Department of Health (as of June 2025 in its most recent report) and estimated as of 2021 to have cost $5 billion, according to the VDH website. The costs of forcing providers to temporarily close our practices I believe conflicts with the stated priority in combatting the Opioid Epidemic of increasing provider availability to combat patients in pain, directly impacting the reach of the Opioid Epidemic in Virginia. The needs of pain care patients and their treatment should be prioritized when determining whether to arbitrarily require providers to be unavailable for these patients’ needs in order to attend an in-person conference for Type 1 credits, which could just as easily be completed online/virtually without impacting patient care. 
3. As practices are just exiting the turmoil of the Covid pandemic and regaining their footing, adding an in-person attendance requirement creates an additional cost burden for practitioners, sometimes amounting to hundreds of dollars in travel costs. In many cases these costs more than double the base cost of conference attendance at a time when financial resources must be used especially wisely by post-pandemic practices just regaining their footing.

Virtual attendance is mainstream, a beneficial option to providers and their pain patients, has far reaching impacts on patient pain care and provider availability across the state of Virginia if removed as an option and should accordingly continue to be an accepted option.

Those who wish to attend “in person” should be allowed to do so; chiropractors who deem it best to attend virtually should be honored as well. 

I also request that chiropractors be held to the same standard as are other professions regarding Type 1 credit hours.  The medical field is one of the most heavily regulated fields in the United States and practitioners are required to stay abreast of many, many areas outside of clinical expertise that relate directly to accepted standards of care and education.  This modern practicality should be taken into consideration in delegating requirements types for CEUs and the Type 1 requirement should be rescinded accordingly.

I respectfully request that the Board vote "no" in response to the petition for an "in person" requirement and that the Type 1 requirement be dropped altogether to bring our requirements more in line with the commonly accepted CEU requirements of other providers across Virginia.

On a separate note, since I am unsure of whether the Board considers suggestions included in individual petitioner’s responses, I wanted to address and respectfully request the Board disregard the suggestion included in a petitioner’s response calling for the addition of a “hands on” requirement; it is not a request echoed by our profession as a whole.  As the Board is aware, chiropractors have extensive education—with “hands on” training starting in the first quarter of school and continuing for the entirety of our 4 years of education which is a year-round program—as well as four separate National Boards (each testing acumen, understanding, and mastery of the knowledge and skills required within the chiropractic field) which must be passed to obtain licensure. Following licensure, each chiropractor then goes on to have further extensive “hands on” hours, honing that educational expertise everyday in treating their patients. Beyond office hours, many chiropractors then see other chiropractors for manual therapy and this service is often and regularly exchanged free of charge between licensed chiropractors in the field. In short, we have many ways that we work with eachother that don’t necessitate our being required to have further “hands on” mandatory CEU’s.  I would very much appreciate the Board’s dismissing this separate suggestion from the petition being discussed out of hand.