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

I oppose this suggestion.  I agree with Daniel Shaye's previous comment 100%. To add face to face seminars is less time with my Friday evening & Saturday patients for the last 28 years. It hurts my income as well as being a disservice to my very role as a Doctor of Chiropractic.

OPPOSE.

Thank you,

Elizabeth K. Murphree DC 

I am writing in strong support of the petition to amend 18VAC85-20-235 to remove the clinical continuing education hour requirement and to require that 24 of the 30 annual chiropractic CEU hours be completed in person, face-to-face.

Chiropractic is a profession rooted in hands-on, patient-centered care, and our continuing education should reflect that. In-person education fosters true professional growth through live demonstration, peer-to-peer dialogue, and real-time feedback—experiences that cannot be replicated online. These face-to-face interactions strengthen our clinical skills, keep us connected to the latest best practices, and reinforce the sense of community that sustains our profession.

Equally important, removing the “clinical” requirement gives chiropractors greater flexibility to pursue the education most relevant to their practice. Every chiropractor serves patients in unique ways—whether through technique, integrative approaches, nutrition, or other supportive disciplines. By eliminating the restrictive “clinical” designation, the Board will empower doctors of chiropractic to select continuing education that is meaningful to their patient populations while still maintaining high standards of professional excellence. This flexibility allows our field to stay innovative, responsive, and aligned with patient needs rather than being limited by arbitrary categories.

This amendment not only protects patients by strengthening practitioner competence, but also supports the growth and vitality of the chiropractic profession in Virginia. I urge the Board to adopt these changes so we may continue to advance in a way that is both patient-focused and professionally adaptive.

Respectfully submitted,
Ainsley Hendon Flynn, DC

I approve the proposed action to remove the clinical component of the CE requirements.

I am opposed to adding a face to face requirement for CE

Respectfully

Michael A Pasternack, DC

3038 Valley Ave

Winchester, VA 22601  

Phone 1-540-545-7891

Email fixspinedoc@aol.com

It is important that doctors of chiropractic be able to get relevant continuing education requirements that are other than treatment related. There are many subjects that pertain to chiropractors that re not clinical: risk management, patient recordkeeping, HIPPA requirements, medicare requirements, cultural competency, etc. Therefore, I agree with this petition and ask that the word "clinical" be removed from statute.

However, I strongly oppose the “in-person/live” recommendation in this petition. There are many great programs that are online. Why limit chiropractors to 6 hrs. online out of 30 hrs. (only 20%) as acceptable CEUs? Seems arbitrary and punitive for those that prefer online training. Also, the added cost of travel and accommodations on licensees seems unnecessarily burdensome. Some in-person/live requirement might be good. I suggest 10 hours out of 30 hours required to be live and allow 20 hours out of 30 to be online or other method.

Dear Members of the Board,

I support removing the requirement that Doctors of Chiropractic obtain a specific number of clinical continuing education hours. This change allows us, like our fellow primary care colleagues, to choose education most relevant to our practices and patients.

However, I oppose the requirement that 24 of the 30 hours be obtained face-to-face. Such a high number restricts access to diverse topics, increases time and cost burdens, and is inconsistent with the continuing education standards of other Virginia medical professionals. Online education provides flexibility and equal quality, and our requirements should remain consistent with our primary care peers.

Thank you for your consideration. 

Blessings and Health,

Dr. Allison Schwartz
Doctor of Chiropractic and License in Virginia since 2011. 

I am writing to express my support for the proposed changes. The word "clinical" excludes HIPAA, Human Trafficking, etc. from fulfilling the CEU credits.

As for face-to-face time, I am in support of this change with one caveat, if a member due to a documented illness inhibiting travel is unable to accomplish this requirement is allowed to meet the CEU requirements through on-line classes.

Thank you,

Minesh Patel

Our CE requirements, governed by the Virginia Board of Medicine, should remain consistent across professions, excluding topics like Substance Use Disorder and anesthesia, which do not apply to our scope of practice.

I respectfully oppose the proposed change requiring any in-person continuing education (CE) for our profession. The assumption that provider isolation leads to potential issues—and that mandatory live CE courses would resolve this—is unfounded. In-person CE does not guarantee increased engagement, learning, or support, and for many, it creates a significant burden in terms of time, cost, and travel.

Many of us already practice in collaborative environments or actively participate in professional groups that provide robust peer support and ongoing dialogue—often exceeding the benefit of traditional live CE events. 

I urge the Board to maintain flexibility in CE formats and avoid imposing unnecessary restrictions that do not demonstrably improve practitioner competency or patient outcomes.

After reading the UVCA online share, some of the comments, the law, and the intent of the suggested changes, I would support the removal of the clinical requirement, but leave the 30 hour CEU's alone. We do not need to be mandated to attend in person and the current law does not prevent any one from getting their CEU's in person if they so choose. It is an individual choice and it should remain one and I am grateful that the current statute supports that. 

I've practiced in rural Southwest Virginia for 33 years and rely on online CE due to long travel times and high expenses.  Unlike those in larger cities, this was essential for me.   Back when CE was only available by weekend seminars, I would have to travel 4 hours to Charlotte, NC because that was the closest.  Occasionally, I could travel only 3 hours to Roanoke.   Therefore, I strongly oppose the proposed changes.

I am writing to strongly oppose any changes to CEU requirements for chiropractors. Requiring in-person attendance for any portion of our CEU’s puts an unnecessary strain on both finances as well as time for many people. It causes a particularly difficult burden for those of us who are parents and would have to find childcare for a weekend away. There are no regulations prohibiting chiropractors from attending in-person seminars if that is what they wish.

The online platform allows us to get high quality and affordable CEU’s with the much needed flexibility and decreased time out of the office. Please consider not changing the online format for our CEU’s. Thank you.  

I strongly oppose the changes proposed for chiropractic CEs. As a full time working mom, I don't have the time or resources to go away for a weekend or more. Online CE's are convenient, cost efficient, and high quality; and it offers flexibility and decrease time out of office. 

Therefore, I am strongly against the new proposed changes. 

Thank you.

I support changing the CEU to allow non-clinical educational hours. As others have stated, there are many topics that are critical for the practicing chiropractor to remain up to date other than strictly clinical subjects.

I do not support requiring in-person hours. There are plenty of online programs from accredited chiropractic colleges and others that are excellent and allow practicing chiropractors the opportunity to get top-notch education in topics that they deem relevant to their practice. There is no evidence that requiring in-person CEUs will make the public safer or make a better chiropractor.

As a licensed chiropractor practicing in VA I am opposed to changes that limit completing C.E. requirements online. The online platform allows for ease of access to collaborative efforts of the highest quality and most relevant knowledge created by colleges and associations across the nation and internationally. To limit and not further encourage online learning creates a barrier to knowledge dissemination.    

I strongly endorse the petition to revise 18VAC85-20-235 by eliminating the "clinical" requirement to continuing education requirement.  I am also in support on mandating at least 15 of the 30 annual chiropractic CEU hours to be in person. 

I'm writing to share my interest in removing the "clinical" requirement for the 30 hours of CE and my disinterest in requiring "in person" continuing education mandates.  I practiced in Florida when they required many in person CE's back in 2006 to 2010.  Many chiropractors signed friends in or out and or spent their time on phones or laptops and didnt pay attention to the lectures and complained about being forced to spend extra time and money at mandated CE's.  You cannot force people to participate just because you're in person.  In person education is not necessary for the majority of CE's in our profession.  Many people have different styles of learning and cannot pay attention to a full day or long weekend of classes.  Online gives you flexibility to stop and start a class on your own time.  

I'm for choice.  We all did the necessary education "in person" hours required by our accredited Colleges and passed National Board Examinations just like medical doctors.  I'd like the flexibility to choose online or in person education; not be forced to do one over the other.  Florida no longer requires in person and part of reason is mandates don't work well.  Just my opinion.  I enjoy doing the occasional in person technique/hands on seminars but don't require us to do so.  

I STRONGLY OPPOSE any requirement that would require CEUs to be done in person. If the Board were to make this change then it should be equitable and apply to all healthcare professionals in Virginia, not just DCs.

I do approve of the proposed action to remove the clinical component of the CEU requirement.

I fully support the importance of ongoing education and believe the opportunities to pursue courses which enhance and support our practices are essential. I also agree with the recommendation to remove the word "clinical" from the statute, and I recognize the value of including an ethics requirement.

However, I strongly oppose the proposed requirement that CEUS's be obatined "in person/live." Each doctor has a unique practice and personal circumstances, including family repsonsibilites, that make flexibility in continuing education critical. Dicataing the format of CEU's must be earned unecessarily limits access, reduces automony, and fails to recognize the diverse need of practioners.

Thanks for your consideration,

Jennifer L. Sims DC

I think that the current set up specific to chiropractic CEU/CME requirements works very well the way it is.  

I would cast my vote against this motion. I would like CE rules to remain the same.

Who's is going to manage the practice when going out to do seminars? Some of them are just way too expensive. Have to find a plane ticket and hotel for few CE hours? I have a business and two kids just like many doctors. It is way too difficult to perform all this. Again the live seminars are very market based...meaning they want your money and want you to continue to pay for next seminars. Learn nothing much. 

Everyone knows CE is a formality. Just charge us the fee to renew the license. Let us pursue other things we want to learn, but no doctor out there is only remaining competent due to a CE requirement. Practice makes us better and adding tons of CE hours in no way protects the public whether its online or face to face. That said, if CE must be there, forcing it to be face to face only takes away from doctors' hours they could be helping people as it typically requires office closures. Online allows us to do it in small chunks on evenings with no practice disruption

I am writing to express my strong opposition to the proposed changes to 18VAC85-20-235, which would remove the requirement for clinical continuing education hours for doctors of chiropractic and mandate that 24 of the 30 annual hours be in-person.

I believe these changes would be detrimental to patient care and professional development. Online continuing education provides an invaluable opportunity for chiropractors to access a broader range of high-quality, specialized courses from experts across the globe. This accessibility is especially critical for those practicing in rural areas or those with limited travel availability. Limiting online learning would not only restrict our educational options but also increase the financial and time burdens associated with travel, lodging, and in-person course fees.

Furthermore, removing the clinical hours requirement would dilute the focus on direct patient-centered skills. Clinical education ensures that we remain current with the latest advancements in diagnostic techniques, treatment protocols, and patient management. These skills are essential for providing safe, effective, and evidence-based care.

The current regulations strike a necessary balance between various learning formats, promoting both theoretical knowledge and practical clinical application. I urge the Board to maintain the existing requirements, which support flexible, accessible, and comprehensive continuing education for all doctors of chiropractic in Virginia.

Requiring in person CE requirements will limit the options Doctor of Chiropractic have when choosing CE classes. In such cases many DC's will have to attend classes that do not offer subject matter that is of importance to them. Online classes offer a much larger subject matter. In addition, having to attend seminars can be expensive and time consuming due to travel. In such cases it is often necessary to close our offices on a Friday and or Monday to allow for such travel. 

Dear Members of the Virginia Board of Medicine,

I am writing to respectfully oppose the recent petition proposing a requirement that chiropractors complete 24 of their 30 continuing education (CE) hours through in-person attendance.

While I fully support maintaining rigorous CE standards for chiropractors, I believe this specific change would impose unnecessary burdens on practitioners without meaningfully improving patient care or professional competency.

I oppose this petition for the following reasons:

1. Accessibility and Flexibility Online CE provides flexibility for practitioners with busy clinical schedules, family obligations, or geographic limitations. Restricting the majority of hours to in-person formats reduces equitable access to education.
2. Quality of Education Online CE programs have advanced significantly, offering evidence-based content, interactive modules, case studies, and real-time virtual engagement. The educational quality is not inherently diminished compared to in-person sessions.
3. Cost Burden Requiring in-person attendance adds significant financial burden, including travel, lodging, and time away from practice. These added costs may disproportionately affect smaller practices or rural chiropractors.
4. Consistency with Other Professions Many healthcare professions in Virginia and nationwide recognize the validity of online CE. Singling out chiropractors with restrictive requirements creates inconsistency and unfair disadvantage.
5. Public Health Considerations The COVID-19 pandemic highlighted the importance and effectiveness of online learning platforms. Continuing to allow all 30 hours to be completed online or in person respects this lesson and keeps the profession adaptive and resilient.

For these reasons, I urge the Board to reject the petition and continue allowing chiropractors to fulfill CE requirements either online or in person, with professional discretion to choose the most effective and accessible format.

Thank you for considering my perspective and for your continued dedication to ensuring high standards in chiropractic care within the Commonwealth of Virginia.

Doctor of chiropractic for 18+ years

I disagree with the submitted request to change the way a chiropractor retains their CE's. It should be up to the practitioner on how they obtain their them as long as they are completing the required number and type. 

As a practicing Chiropractor in Northern virginia. I am not in agreement with the change to make 24 of our 30 education credits be in person only I believe this limits the chiropractor’s ability to decide how they receive their continued education. It should be the practitioners choice on how they obtain their CE’s. Please allow the chiropractor to make the choice if they want to obtain the continue education credits in person or virtually or a combination of both.

If a concern is ethics and boundaries issues when it comes to chiropractors, then make those hours be in person. 

I totally support this change and think it’s a great move for the profession. 

As a practicing Doctor of Chiropractic in Virginia, I strongly oppose changing the continuing education requirements. If Doctors wants to complete their hours face-to face than that option currently exists. However, I find online continuing education very practical, applicable and appropriate to satisfy the current requirements.

As a Chiropractor, and a busy one at that, I personally cannot afford to take off long weekends on a regular basis to attend in-person CE hours. Having the ability to complete my hours online is absolutely essential for my practice. Limiting online CE hours would also hurt the companies that provide these crucial services to doctors like myself. Most of the time the in-person CE courses are out of state, as the Commonwealth of Virginia has very few opportunities for in-person Chiropractic CE's. There are no Colleges for Chiropractic here, so I am then burdened with not only paying for the courses themself, but travel and hotel expenses as well. I understand that some Chiropractors want more collaboration between the many offices across the state, but this is not a viable option for myself and many others. Financially it is actually more detrimental to us, not only from the travel aspect, but because of the time we have to take off to attend them. Closing our offices to travel to these events then becomes a day of lost pay from not seeing our patients, and also effects their treatment plans. 

Thank you for your time and consideration.

Respectfully, 

Dr. Ryan E. Hollingshead

I like the current requirements as it is flexible for all chiropractors needs.  There are a lot of great online programs that I have taken in the past including radiology, ethics and recently the human trafficking training that have all been very informative and educational.  

By limiting to in person only as counting towards the 30 hours, that seems very restrictive.  Is this the trend in other states? 

I REALLY enjoy in person continuing education and that is definitely MY preference, but there was a time when I had a baby and was not able to travel as much or get to in person conferences as much as I would have preferred.  These special considerations need to be addressed and, as another commenter stated, if a person has an illness, it may be difficult for them to acquire all of their continuing education in a year. I also think about the administrative energy it would take to keep up with these exceptions.  

I do not support amending 18VAC85-20-235 to (1) remove the requirement that doctors of chiropractic obtain clinical continuing education hours and (2) require 24 of the 30 annual hours be in person, face-to-face.

Rationale: This will add undue financial burden on doctors for unnecessary travel, airfare, lodging, rental cars. The majority of medical professionals already complete their continuing education on line.

After reviewing the proposed changes to CEU requirements in VA, I support the removal of the clinical requirement.

I do not support mandating all CEUs be acquired in person. This puts an undue burden on the practitioner with regards to expense needs to travel (hotels, car, etc).  It is also limiting the knowledge that can be acquired to serve our patient bases.  Not every topic is covered in person and in a location/timeframe that would suit.  Being able to take online courses opens up many more opportunities to learn about topics that actually serve our patient bases instead of just completing a requirement. 

I do Not want to change the Continuing education requirements to 24 hours face to face.

As a practicing chiropractor, I see the value in CEUs to help ensure that we are keeping up to date on the most relevant data and practices for our profession and craft. Most of us are doing this, however, without gaining CEU data just because we need to ensure we are up to date for insurances, billing and coding compliance, and ethically, it's the right and best thing to do. 

With that being said, the proposed amendment to make 24/30 CEUs "in-person" is not something that I support. As a provider who spends much of their time outside of practice traveling to conferences to disseminate her own research and policy work, other state's CEUs do not always qualify for Virginia specifically. The requirement for making the CEUs "in-person" fails to articulate if these requirements need to be within the state boundaries, which I believe is the primary goal of many of my colleagues who are petitioning for this support. Keeping the CEUs in-person likely means chiropractors in the state will be more willing to attend the state-chiropractic organization's events, which leaves the organization to gain financially from this requirement. As a member of the state association, it's important to acknowledge this to avoid biases. Other in-person conferences that are outside of the state of Virginia will likely require additional administrative work to submit for such approval for CEU requirements with this new change, and instead will prioritize the state-ran conferences for proximity bias rather than what is the best quality or most-relevant for chiropractors within the state. 

We also are in a moment where CEUs are quite accessible online. If this proposal were placed in the 1990s or early 2000s, when it was difficulty to obtain CEUs online or there was greater question of quality, this proposal may be more appropriate. However, without clear data indicating if online or in-person educational experiences provide greater value than the other, it cannot be said if it is better to have CEUs on line or in person. Instead, it's more logical to allow for physicians to have the choice to exercise their professional judgement  on what courses will help them best in clinical practice, and improve on their own skills with the CEUs that best suit their needs, in the educational format that works best for them. 

Compared to other states, I encourage you to look further at the following link which provides details by state of CEU requirements: https://fclb.org/chiropractic-licensing-boards.php
https://chiropracticfuture.org/resources/road-to-practice/

All in all, I oppose the "in-person" recommendation for 24/30 hours. 

I am retired from active office practice and see patients for 10 hours or less every week. It would be a hardship if I have to attend CEUs in person.  Please consider retirees or part time practitioners be excused from mandatory in person attendance. Thank you

 Susan  M Sweeten,DC 

smsdc89@gmail.com 

In this ever-increasing, expense-riddled world, forcing travel, hotel fees and time away from the business to do in-person CE hours is terrible idea.  We currently meet the VA Board of Medicine requirements via online hours, which saves considerable time and money.  Not all of us have multiple offices employing multiple doctors.  I am my practice, so time away detracts from patient care, not to mention practice income.

Thank you,

Dr. Eric C. Scott

The current continuing education requirements for Chiropractors are sufficient. By mandating that they be in person adds a financial burden on those doctors who have to travel enough of a distance that would require them to close their office, buy a plane ticket, have rental car expenses, pay for a hotel and meals, etc., all without gaining any additional knowledge or skill.

The economic ramifications of this change could be detrimental to a small practice. A third of chiropractors are women and the average age of a chiropractor puts half of those in what is referred to as "the sandwich generation." They are working/running a practice, taking care of children and their elderly parents. There is always an option to attend in person, however, making it mandatory is a burden not all can bear. 

I strongly oppose this change. If my name and email were not made public, I would have included that. There should be an option to leave contact information without allowing my personal information to be made pubic. Thank you. 

Who is Joseph Foley, DC? Does he sit on board of any type, or is he a chiropractor that thought things should be changed? 

The author of this petition does not provide any data to support any of his suppositions that this new requirement will benefit isolated practioners, the profession, or that even identifies isolated practicioners as more "at risk."  He even states that this is just his "belief."

In this ever increasingly automated world the training and continuing education content one has access to remotely is vast and of high quality.  Many of us practice very differently and so the many choices of courses online can help one to focus and continue to build on established skillsets or be exposed to other new keen interests.  

In-person continuing education is very limited.  There just aren't that many that come to the state of Virginia or even nearby states and the topics/content can be irrelevant to individual practices or the same old class coming round one more time.  This form of CE is incredibly expensive, both in time and money.  Time away from our families and our patients.  This is also wasteful from an ecological perspective.  Why involve planes, trains, and automobile travel, all of which aren't without personal risk and environmental emissions.  The presenter pays huge fees to the hotel to use the space for the class, the cost of which is passed onto the docs who are already paying $200 plus per night for a hotel room.  A doc from hours away often has to arrive early and cover an extra night's expense and then food expense as you are trapped for few days eating and paying for restaurant meals.

No disrespect to Dr. Joe, I am certain his sentiment is toward better connectedness of the chiropractic community, but this concept is fraught with inefficiencies and is taking a giant leap backwards as the world of tech keeps advancing our abilities to conquer the minutia of daily life remotely and with less expense.  With all of the ways to connect and form community online it has actually never been more difficult to be isolated.

Please vote no and keep us firmly rooted in the 21st Century.

Christopher Ubert, D.C.

As many other chiropractors have eloquently stated:  in-person CEs create extreme financial duress.  Most chiropractors are still hundreds of thousands of dollars in debt from our chiropractic school education and in-person CEs are exorbitantly priced including the cost to travel, pay for accommodation, etc.  It is vastly preferrable to have a greater variety of CE classes and subjects to pick from online and to be able to complete our classes when we have availability.

I have a son with profound disabilities.  It is all I can do to work full-time, complete CE requirements, and take care of him.  There is not nursing assistance or childcare available for in-person CE classes, so I would be forced to terminate my license due to this arbitrary idea.

Dead Board members;

I oppose the removal (or adding restriction) of the ability to obtain CEC virtually. All others professions allow it and it serves a huge benefit of decreasing travel, fatigue, delays, cost, time away from office, and time away from family. 

I am also not aware of the problems sited as the reason for the suggestion. I asked for data and received none. I am also not sure that the remedy is to "punish" or force the whole profession to attend in person seminars. I am not sure if that solves the problems mentioned. Perhaps a more focused approach to address the people who commit ethical violations is more appropriate. 

I support the removal of restriction that the 30 hours of CEC have to be clinical. This will allow more people to attend practice management, ethical, or liability CECs.

Thank you for your time

Tarek Elganainy, DC, DACNB

Dear Board of Medicine Members,

I am writing you all today in order to show support to having the clinical stripped from the CEU clause.  We have other non-clinical (non-hands on training) that we need to support our clinics and make sure that our patients are getting the best quality care possible, i.e. ethics, sex trafficking, etc.. Ideally, I wouldn’t mind making us have slightly more CEU’s to accommodate the other phases of practice.

I am also writing to oppose the in person CEU requirement. I do not believe that there should be one as we are and have been trying to be equal to the other Practitioners of Medicine in this state for a long time.  Why add something that will make us further from that. 

Changing the hours to largely in person hinders the ability for some providers to seek quality courses due to cost for travel on top of courses. Having virtual options has opened the availability to obtain hours while maintaining a better work/life balance as well as lowering cost to provider without sacrificing education 

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!

I believe that, Chiropractic, as a profession that uses a hands on approach to patient care, it is imperative that we keep a component of in-person learning. Online Continuing Education cannot approach the efficacy of learning new skills and perfecting current skills. Chiropractic techniques are tactile and motor skill dependent which is difficult to master in a remote learning enviornment. 

I feel that being surrounded by other practioners fosters discussion, exchange of clinical insights, and collaberation. Exposure to different practice styles broadens perspective.

Over my career I have done both in person and remote learning and feel that the focused time that one gets from in person and the lack of distractions from being at home or in the office leads to stronger retention. It has been shown that the kinesthetic component of in person learning activates different memory pathways compared to passive learning.

I have read the arguments against the in person requirement and nearly all are focused on the hardship on the practitioner but I believe the continuing education requirement is and should be for the betterment of the patient interaction and further the safety of clinical interventions which, from my perspective, are far superior with an in person requirement.

Lastly I feel strongly that the Clinical requirment should be dropped as there are many avenues that are for the improvement of the patient interaction that are notspecifically "clinical".

Regards,

Robert M. Pinto, DC

I fully support decreasing the required CE hours to 30 every 2 years and taking 'Clinical' out of the requirement for the 30 type1 hours of Chiropractic CE. I believe this would limit our expansion of being a fully rounded healthcare provider to the general public and our peers.

I fully oppose forcing Chiropractors to obtain any CE's in-person only. I think there are good reasons to do in-person CE's, but that should be up to the individual to decide what's best for them. Forcing in-person CE's takes our freedoms away, and I believe our profession is better than that. It additionally is very burdensome on the practitioner, their families, and financially.

Thank you for the opportunity to comment on these issues.

I believe that the CEU requirements proposed by the BOM and as well as the use of the term "clinical" in the subject of those hours should be equal across all professions that the BOM regulates and should not be different for Chiropractors compared to our allopathic colleagues. Although chiropractic is a unique type of healthcare, the public should rest assured that our professional requirement are on par with other physicians in the commonwealth. Furthermore, if CEU's are allowed to be obtained partially or fully online for other healthcare professionals, the regulation should be the same for chiropractors. In person or virtual choice should be left up to each individual practitioner. 

In conclusion, I feel the CEU hours of 30 hours every cycle renewal is acceptable. I am opposed to changing that 24 of the 30 hours be mandated to be in-person, specifically if you are a chiropractor. No matter how well intentioned this suggestion is, it does not mean that the majority are in favor of this. Not to mention that this change does not cut, eliminate or downsize regulatory and legislative burdens. 

Furthermore, I am for changing the term "clinical" hours being required for chiropractor's, if that is not a requirement for other healthcare professionals regulated by the BOM. The type of CEU allowed may not be clinical, but nonetheless relevant to the safety, health and well-being of the community and should not be discouraged by the BOM. 

In reviewing Dr. Foley’s proposal, along with the recent state-level changes that already cut CE hours in half and removed Type 2 hours, I want to share my perspective for the BOM’s consideration.

First, I support the reduction of overall hours, but I strongly believe chiropractors should be required to maintain some hands-on CE. Chiropractic is, at its core, a hands-on profession. Patients deserve providers who are continually sharpening their skills for both effectiveness and safety.

I urge the Board to remove the word “clinical” as it applies only to chiropractic CE at this time. Singling out our profession in this way, when our healthcare peers are not held to the same language, creates an unnecessary burden. I understand the BOM is tasked with reducing burdens on providers, and I support that mission. 

Here’s the reality: chiropractic adjustments can’t be refined alone in an office or through a computer screen. There is a touch, an art, and a nuance that requires live feedback and peer-to-peer interaction. Without in-person training, many doctors would essentially stop developing the day they graduate. That’s not only shortsighted, it’s risky. 

That’s why I propose requiring 15 in-person CE hours every two years. This can be completed in just one day per year. One day is not an undue burden, and if it feels like one, those are likely the doctors who need it the most and more importantly, so do their patients.

Being a licensed chiropractor is a privilege that carries responsibility. Regulations shouldn’t bend toward maximum convenience for doctors if it risks patient safety. Protecting the public is the BOM’s primary role, and I believe this balanced approach honors that mission.

Thank you for your time and for considering this perspective.

This proposed change is unfair an unreasonable. It would close practices more and take us away from patient care which is the most important. This is not expected of any other types of doctors and I feel this is predatory and unfair.