In reviewing Dr. Foley's proposal as well as the changes at the state level already reducing the CE hours in half and getting rid of Type 2 hours I am submitting comment for the BOM to consider as they determine what is best.

I strongly urge the removal to the term "clinical" that is place only on the hours of the Chiropractic profession at this time to make it in line with our peers of other degree specialities. This is an unnecessary burden placed on one group, even if unintended at the time the regulation was created. 

I recognize that the BOM has been tasked with reducing the burden on providers but I do agree with there being an in-person requirement for part of the hours required. I do not agree with the rationale submitted by Dr. Foley that mental health is a primary reason or even much of a reason although I understand his point. This applies to a small fraction of practitioners for which the rest should not be burdened.

However, chiropractic is a very unique profession in that at its core it is a hands on practice. The public deserves providers to be at the top of their game for the most effective treatment as well as public safety. Chiropractic adjustments cannot be reviewed or improved in the solo office, as most chiropractors are, or online. There is a "touch" and an art to a chiropractic adjustment. This needs to be reviewed and improved in person with peers and educators. Having no in person needed would allow a practitioner stop learning at the moment of graduation for school. To think their skills will have peaked at this point is clearly not ideal. To also think that an individual practitioner will figure it out with their own patient experiences is also short sighted. It assumes that the practitioner already knows what they are doing at and there is no need for review or advancement. I have served as an instructor for over 20 years and I can report that in person is necessary, for the sake of the patients we serve. 

I believe that the BOM's primary role is to protect the public and in this light I propose that a requirement of 15 hours per two year be required to be in person. This allows the doctor to meet this requirement in just one day per year. One day per year is not a significant burden, in my opinion, and if it is then those would the doctors whom I suggest could benefit the most, and more so the patients they serve. 

Being a licensed doctor is a privilege and carries with it a responsibility. I do not believe that this regulation should be to the convenience of the doctor at the potential risk to the patients. And if the counter argument is that doctors will just be responsible enough to do this on their own anyway, I view my proposal as no burden at all. 

I see this as protecting patient care versus doctor convenience. 

Thank you for your time and effort!