Dear Regulatory Board,

I can understand that creating regulations is a difficult and arduous process and therefore, I commend you for your hard work on the PT Direct Access regulations thus far. 

However, I am concerned about the portion of the regulations that require additional continuing education (4 hours per biennium) directly related to practicing in the direct access setting.  To qualify to apply for "Direct Access Certification" initially a PT who does not have a DPT is required to complete 15 hours of continuing education/training in Medical Screening or Differential Diagnosis and they must pass a post-course examination.  I feel that this is sufficient.  Our current regulations for PT license renewal (regular license to practice) requires 30 hours of continuing education per biennium for PT's.   I do not feel that an additional 4 hours or requiring course work specifically related to Direct Access should be required to renew your DA Certification.  Most of the courses that I have attended in the past 2-3 years have been Evidence Based Practice courses.  In these courses there has been adequate time devoted to medical screening, red flags, etc., allowing me to remain current in practice that is safe, effective and backed by research.  It is my opinion (as well as the opinion of several colleague with whom I have spoken) that the additional 4 hours of continuing education that has to relate to practicing in the DA setting is unnecessary for clinicians to maintain best/safe practice, even when practicing under direct access legislation.  Therefore, I would request that this portion of the regulations be deleted.

Sincerely,

Terri S. Ferrier, PT