I would like to address the requirements for an EMS Educator to recertify.  I say this acknowledging the recent correction which drops the 12 hours of CE.  My concern is still with the process and that the process may restrict the pool of qualified educators within EMS, especially in volunteer agencies.  As it is written, EMS educators will have to teach 50 hours within their certification time, attend an update, and retake an EMS Educator’s test.  Unlike any other EMS certification in Virginia, there is no allowance of a waiver to this test.  I feel this process should be an either/or NOT an “and”.  This process, I feel is further contradicted when you add in the accreditation process which allows subject matter experts to be used to educate with or without any previous educator credentials.  As it is currently, it is my understanding that an accredited institution can use subject matter experts to teach a specific topic if the course coordinator (who is an EMS Educator) so desires.  Though I totally agree with the accreditation process, it contradicts the above requirement of requiring educators to recertify.  I totally agree with EMS educators having some form of recertifying process due to staying current with the administration aspects of providing EMS programs but I feel the above is excessive.  My view is if someone that has been through an EMS Educator training process that teaches the 50 hours or attends an update or takes a test (test being focused on administration and instruction abilities) they have met the intention, especially with the endorsement of an EMS Physician.  Having someone that has already proven their credentials to prove them again is excessive when individuals are being allowed to instruct that may or may not have ever proven instruction abilities before.  As with all processes, I feel great quality assurance is a must and should be accomplished through mentoring and/or monitoring, not through a recertifying process.  Thank you for the opportunity to express my opinion and my opinion should be considered as solely my opinion and not necessarily the opinion of any organization I may be affiliated with.