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More CE Rule Controversy: The Push for Mandatory Policing Standards

The latest rambling CE rule changes being pushed by 4 of the 7 members of the Florida BOCM and two CE vendors has sweeping ramifications for every Florida-licensed DC.

The Board of Chiropractic Medicine made it official in August of last year that all forty hours of chiropractic license renewal CE’s can now be earned on demand, virtually or at live events from now on. With a split 4-3 vote, the BOCM removed the language that previously allowed 25% of online CE hours to make it a 100% online option. Life went on with plenty of great CE options for Florida DC’s who can choose from a plethora of in-person, live synchronous and online CE’s.

Why then is the chiropractic CE rule back in the news in 2022 after three years of working on the technicalities of taking online courses? One on-demand CE vendor decided that opening the door to 100% online CE’s wasn’t enough. He petitioned the BOCM at its very next meeting to again amend the CE rules and add more layers of regulation that will financially cripple live event producers and force them to police attendees in ways never before seen with any other sector of healthcare, business or education. Dr. Rick Warner of GoLearn Network filed his petition last November and based on public testimony, has been joined in this quest by the FCPA. Despite 10-1 testimony and written comments against the petition by CE provider stakeholders from the FCA, FCS, FCLB and numerous chiropractic colleges and licensees in a subsequent January rules workshop and the Board’s February 24th meeting, and in spite of expressed concerns from Fla. Dept. of Health officials and counsel that the proposed rule changes were unnecessary and would be difficult to defend if challenged, the same 4-3 vote was made at the Board’s February meeting to move forward with rulemaking to adopt these onerous changes. Your member bulletin of February 25th carried the FCA’s post-meeting report.

So, if you missed our earlier reports, you might ask: What is the big deal? What would these petitioned rule changes do? Here are just a few of the highlights directly affecting you:

• A proposed SURVEILLANCE REQUIREMENT would force in-person event CE providers to set up and monitor video equipment that “clearly” records every person entering and exiting a classroom, date stamped with the date and time. Every entrance/exit to every meeting space – even those that would normally serve only as fire exits – would have to be covered in this way. This is in addition to the already existing scanning or sign-in roster system that is now required, utilizing photo ID and showing the name, license, and time of entry and exit.

• Live event attendees would have to be TESTED during each hour of class time and would have to have 75% completion of the test to receive credit for that hour, a hassle for attendees and a costly administrative nightmare for CE in-person event providers.

• Registration fees for in-person events would have to triple or quadruple in order to cover the increased costs for just these two items, likely doing away with live multi-session events for chiropractic CE’s in Florida.

• Do you prefer to earn your CE’s online and on demand? The proposed rule would require that you be “video monitored” when taking your on-demand CE’s, meaning, as explained by Dr. Warner, that periodic snapshots of you would have to be taken and stored in order for you to receive credit. “Video monitoring” on-demand surveillance is currently used by two CE providers to our knowledge – GoLearn Network and the FCPA.

• Provisions in the proposed new rule would provide severe sanctions for CE providers who don’t follow the letter of the law regarding “clear” recording of each individual entering or exiting or testing with the 75% answer requirement. Sanctions require a minimum of a five-year suspension during which time they could provide no programs, classes, events or on-demand courses for Florida CE’s.

• Do you care about standards and want to hear from those most highly qualified to teach your post-graduate level CE courses? The proposed new rules would lower a CE instructor’s credential requirements to include no education, no chiropractic experience, and no accredited college sponsorship or faculty affiliation, requiring instead only six years’ experience “in the subject matter being taught.” This not only contradicts Chapter 460, Florida Statutes, but undermines the profession, as no other Florida healthcare profession allows for such low standards in CE instruction.

• Another proposed provision would allow licensees to repeat the same on-demand course for all 40 hours. That one needs no commentary.

There you have it. The advocate for supposed “CE Freedom” achieved it in August and by November themselves brought forth unparalleled policing and surveillance requirements that treat licensed DC’s like prisoners and punish all CE providers who don’t do exactly what they do, while lowering instructor credentialing standards to basement level.

What Is the FCA Doing About It?

FCA representatives attend every Board of Chiropractic (BOCM) meeting and workshop and have actively opposed this “CE Policing Rule,” testifying verbally and through its filing of an extensive Memorandum of Law, along with other service organizations and CE provider stakeholders and many individual licensees. The four BOCM members voting in favor of moving the CE rule overhaul forward include the two lay members, Chair Gretchen Saunders and attorney Ellen Ostman, and Drs. Jason Comerford and Anthony Oliverio. The FCA is committed to exhaust every administrative remedy in challenging it – an expensive ordeal – and will do so, hopefully with support from other representative groups and stakeholders who have recorded their intense opposition and voiced their concern for the future of chiropractic CE in Florida.

What Can You Do?

As a Florida-licensed DC, you have standing and access to contact the Board Acting Executive Director, requesting your comments be shared with Chair Saunders and the full BOCM.

For letters: Department of Health

Board of Chiropractic Medicine
4052 Bald Cypress Way Bin C-07
Tallahassee, FL 32399-3257

To call the Board office: (850) 488-0595

Acting Executive Director Joe Baker: mqa.chiropractic@flhealth.gov

What’s Next?

Challenging a proposed Board rule is a long, expensive and arduous process. There will be opportunities for public testimony. We will keep you informed of those opportunities and further developments through future member bulletins and web posts on fcachiro.org. Thank you to all who have already stepped up to testify and submit written comments in opposition. And thank YOU for your past and present membership, convention attendance and use of online learning opportunities through ChiroLearn that make possible every effort on your behalf. We will endeavor always to provide the services and CE opportunities you need and want within the confines of the resources you contribute.