I fully support the 4th portion of the proposed action-- TPA-certified ODs should definitely all be interested in keeping up-to-date with current procedures and meds, etc.  Portions 1, 3, and 5 show no detriment to any practicing optometrist-- these are purely options one may choose or not as one wishes, not requirements.

However, to require 50% of our CE hours to be live or real-time as portion 2 specifies is not something I support in any way.  I see no benefit in mandating live classes, as these lectures are not tested in any way, and typically there is no handout or reference given to which one can refer later.  Online/correspondance CE provides an option where an optometrist can learn at his own pace and may concentrate without the distractions of non-topic social chatter and food being served, etc.  It also provides a significant cost and time savings as it does not require a specific hour or location in which to learn.  The classes I have taken online or through other correspondance sources have been of very high quality and I have to really study in order to pass the tests, which ensures that I have truly learned something when the CE is completed.  This is not something I can honestly say about the live lectures I have attended.  I 100% disagree with that portion of the proposed regulatory action, and would hope that would be struck from the regulation.

Thank you.