At 18VAC160-20-109, paragraphs H and I, the proposed regulations indicate that a "CPE instructor" may himself obtain CPE credit for developing, instructing and/or updating a continuing education course. While this proposal is laudable to the degree it encourages and motivates speakers, presenters, and other actual and would-be CPE instructors, some definition of "CPE instructor" may be in order. A definition should differentiate between instructors who develop and present such classes in a public forum, or instructors who come in to make a presentation from outside an organization, and those who arrange and conduct private classes "in-house."  I do not agree with the view that CPE instruction can be or should be met  in-house by the organization that benefits from it, which I regard as a conflict of interest, and so must take issue with language that would give further impetus to that trend. As another state puts it in their regulations, "For in-house training, an instructor from outside of the organization shall provide the instruction."

Dennis R. Wanless