This is a welcome change in the regulations and I am all for it.

Sincerely,

Jeffrey W Robertson OD LLC

I have no problem with the inceased hours required for licensure.  However, I can see no value in demanding that 50% of the classes be live. This is becuase: 1) There is significant lost time in the office when the doctor could be  helping people with vision problems and is instead attending classes.  2)  The greatly increased cost of travel to classes.  3)  It is difficult to get more than 8 hours in a single day at live classes which adds significantly to the cost of hotel and food since these often occur in expensive large cities. 4) The internet classes require that one pay more attention to the subject because there is a test that must be passed for credit. This is not true of live classes.

Last year for the first time I subscribed to SECO online CE. It consists of watching lectures online and then answering test questions.I can't tell you how valuable this has been in bringing me practical and important skills and knowledge.

 I can watch these lectures at my desk, taking notes, and when I hear something especially important I can backup and listen again.

If I am required to attend live lectures, with all the expenses, I'm not sure that it would be worth my while to spend an additional $300 a year to subscribe to the SECO lecture series.

I'm hoping that if you must require that Doctors attend lectures, that you will allow lectures that are presented on line as well. 

Requiring live CE is counter-intuitive is this connected, digital age.  Save the planet, reduce carbon footprint for all the travel, reduce expenses for the docs...unless of course, that was put in there by the ones putting on the CE class and making money on it.

Is CPR training still going to be allowed as a 2 hour course?

I feel the present amount and type of CE required is adequate.  It seems that some of the discussion I have heard is that other states have more and that we have to keep up.   It seems to be a race to see who can have the most hours, and will continue to escalate.  What is the benefit of the increased time away from practice and cost? 

I think it's good that we can carry over excess hours into the next year.  However, I agree that requiring certain hours to be live can be difficult for some folks.  I've done those live SECO lectures before and agree with the previous poster- those are easy to watch, rewind and review again, with test at end... I still prefer live CE but it can get expensive and some years is just difficult to fit into the schedule.  Adding practice management as a CE option is great.  Some good, some bad changes here.

Although I love attending live lectures, time away from office and family becomes expensive and burdensome. I actually think I learn more from online and at home CE courses with tests following.  Also think practice management courses should count since they help us take care of our patients better.

I fully support the Virginia Board of Optometry’s proposed changes to optometrist’s continuing education requirements.  While the majority of optometrists I observe at CE listen and learn, there are still some that talk, play with their mobile devices, or read a newspaper.  I would fully support taking this one step further by utilizing TQ for a percentage of course hours to encourage the learning process to occur.

The eight hours of proposed live or real-time interactive does not preclude internet hours as many webinars are often interactive.  Furthermore, there is no downside to “keeping up with the Jonses” in the number of required CE hours between states.  I would rather be leading than trailing the other states.  Both optometrists and patients benefit from better training in our world of evolving knowledge and technology.

Just what we need, more regulations that serve no real purpose.  I thought we were all professionals dedicated to the welfare of our patients.  Well, probably not 100%, but this regulation will have zero affect on the minority who are not.

Flaw 1.  Under NOIRA Agency Background Document, Purpose:  "MAY encourage attention at more in-depth..."  Really?  A regulation written HOPING it will improve knowledge and skills?

Flaw 2.  Action Summary, Item 5: "count for a portion of annual CE...".  This is sloppy and vague.  What shall be the definition of "portion"?  Who makes that decision?

Flaw 3.  The thinking that somehow in-class CE is necessary in this day and age.  I agree with other comments here.  I get more out of the on-line programs because you have to pass a test therefore you have to pay attention.  How many times have I seen half the audience asleep, reading the paper, playing with their electronics, during in-class CE?  And they get/deserve credit just for being there?

Flaw 4.  This appears to have been created as an image enhancer, not really for any meaningful benefit for our patients. 

I agree with other posts, Requiring live CE is not logical when many outstanding courses are available via Webinars.Even if they are recorded, they allow for the courses to be taken at your convenience. With major univeristies offering courses through free websites like Courera, I think it would be taking a huge step back. Time and expenses wasted on travel can be focused on obtaining more knowledge to improve patient care.

I am also licensed in several other states. One type of CE other states offer is surgical/clinical observation credits with subspecialist ophthalmologists. I think this is beneficial in fostering relationships with other members of the eye care community and helping to prepare patients for what to expect when a referral is needed. 

I do not think that requiring 50% of the hours be live is beneficial to anyone.  In this day and age, online courses are the most efficient and cost-effective methods of obtaining continuing education credits.  It is inconvenient to ask doctors to take time away from their patients and families to attend continuing education when it can be done in the comfort of my own home.  In addition, you are adding cost to the equation by requiring travel, hotel stays, and food.  During online courses, I am at my own pace and I have to pass an exam which means there is more effort required of me to make sure I throroughly understand the material.  Requiring the CE courses to be live does not cater to those doctors who are constantly on the move (traveling between states and/or countries).   

I spent my career practicing in the military and have been licensed in several states.  Frankly what we have now in Virginia is as good as it gets.   The number of hours is reasonable and sufficient for keeping current.  The specific requirements for TPA licensed optometrists are valid and meaningful.  What is the underlying reason for the changes?  Mandating how we obtain continuing education does not make much sense.  There are good reasons for obtaining live CE and good reasons for doing it online.  But why should either method be dictated?  What you learn is more important than how you learn it.  Allow folks to choose their own way.

I do support the carryover of excess hours to the next year.

I support a change that enables excess CE hours to be rolled over to the following year.  Awarding "credit" for practice management is a reasonable change since areas such as patient satisfaction, team building and business sense are critical to professional success. The current TPA hours and specifics of CE in the current law are sufficient.  Mandating the manner of CE is counterintuitive to professionals who everyday have to are trusted with decisions regarding patient diagnosis, treatment and referrals...can't those same professionals make a decision as to which type of CE is best for their practice and learning style?  I would hope that doctors continue to attend live lectures, not because they are "required or mandated" but because the "hallway conversations and professional exchange that occurs at these events is so valuable in learing from one another".  As both an attendee and lecturer at many CE events, over the years, I can assure you that just being in the audience does not guarantee an avid learner.  However, if a professional, who is able to chose when and where and what type to CE they want to attend, either online / live or a combination can make that decision independent of burdensome or restrictive regulations you will have a motivated learner.  Today's learning opportunities will only continue to grow online and with other media we cannot now imagine.  Let's not restrict this growth and opportunity with restrictive regulation.   

The only disagreement I have with the proposed changes concerns the requirement for 50% of CE to be "live or real-time interactive courses." Although I enjoy CE seminars and conferences, I do not agree that these courses are inherently more educational than online courses. I have taken online CE courses, participated in professional webinars,and watched online educational videos and presentations, and I have to say that the quality of the education I find online is excellent and could surpass many conference lectures. Some outstanding  optometric educators have excellent online resources (such as Jerome Sherman's Retina Revealed website). There is great value in live seminars and conferences, but also in online education. I feel it is important that the doctor be able to choose the best source of education available and not have this choice restricted by regulations which may become outdated as our access to online education only grows.

I like the carry over of 50% of CE hours to the next year. I do agree that when ever i have to do on line course with an exam i have to be more attentive and understand the subject matter . On the other hand live lectures are a great benefit as well because it is open discussion if u have any questions in mind u can ask and the questions asked by the other people are also helpful .I think a combination of both is great.

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.

I aggree with the other changes except that of requiring live CE and with almost all the other comments left before mine, that live CE offers very little, if any benefit to online CE. 

I support the proposal to increae the number of required hours and firmly believe it should have been greater than that proposed.  Having worked closely with the state legislature and third party entities, I understand the need.  It isn't a race (as another commented) to see who can require the most hours, it has more to do with being able to address allegations that we are not able to perform certain procedures or prescribe certain treatment modalities because we are not properly trained.  Our board cannot list procedure codes or even interpret the statutes to help defend us if challanged.   At this time, the only active benchmark we have is the number of hours we spend per year educating ourselves. This applies to both the legislative and third party fronts.  I also appreciate the portion allowing rollover hours.  As for the 50% face-to-face portion, I see the value in requiring this, but would take it one step futher as another said, and require a nominal test.  That would be alright with a liver webinar as well.  Without that additional requirement, one can sleep through the lecture and still receive credit.  I see it happening all the time.

I echo the statements of my colleagues where I am happy to see the increase in the numbers of hours required, but find that distance learning (through webinars, online education, and in journals) is often more informative, not less informative than in-person lectures.  Distance education requires the successful completion of a graded test, which shows understanding of the information, not just mere attendance.  I do not see a demonstrable reason why any of the CE hours must be required in person, rather than distance education.  Virginia optometrists have successfully completed their CE hours via distance learning for years, and should be able to continue to complete all of their hours via distance learning.

I oppose item "2" of the proposed action to change the continuing education (CE) requirements within 18VAC105-20-70 for Virginia optometrists.  Item "2" states:  "2) require that at least 50% of the hours (8) be taken in live or real-time interactive coures".  Each individual knows how she or he receives information best.  For example, I receive information best visually, as opposed to someone else whose brain may receive information better through their auditory system.  For me, perusing and reviewing written CE is more conducive to learning, then the potentially distracting environment of a live/real time event.  Additionally, there is a host of engaging and current CE that has already been written and recorded.  A "live or real-time interactive" requirement would effectly reduce choices of CE for practioners within the required hours, stifling and limiting, not enhancing educational opportunities.  Historically, I have typically obtained 50% of my CE in person, but I have made, and would like to continue to make, my CE selections based on the subject matter offered, the quality of the educators (authors or lecturers) and my professional needs or interests, as each practitioner should continue to have the right to do so, without limitation.

Respectfully Submitted,

Jeetandra M. Athelli, O.D.  "Jeet"

I just ordered a bottle of 10 %phenylephrine that a year ago cost 22 dollars a bottle and today 115$. I am in private practice and the financial pressure from accelerating goverment regulations, cost of goods, and stagnant insurance reimbursement is making this form of Optometry unprofatable. I have been grateful that I could save considerable money by doing my continueing ed on line. I do not have the money to take time away from the practice let alone the cost of registration, hotel, and travel expenses. I vote no 

Gary Best OD

Is the Virginia Board of Optometry responding to the complaints of the speakers at live CE presentations?  Perhaps lower attendance numbers means lower fees for the speakers.  This proposed change to 50% "live" CE does not serve the best interests of the public or licensed optometrists.    
  

I agree with most of the comments and oppose this change. Virginia has been ahead of the game by making their CE requirements friendly to ODs. It would be a move backwards to require in-person CE when the quality of online CE and present day technology don't require it. Also, working moms often don't have this extra time to spare.

I also oppose the change in adding restrictions to the type of CE. As other posters have mentioned with all the new technology available for different CE types, I feel it would be a step backwards.

The rapid advancement in technology for distance learning renders item 2 preposterous. As other commenters have noted, being physically present in class for CE lectures doesn't indicate any learning has gone on, indeed I have also seen plenty of colleagues reading the newspaper or checking their phones, even grabbing the attendance certificate and skipping out to play golf. Webinars, interactive chats, podcasts and such allow for much more flexibility as well rather than scheduling well at a large conference. You can ask more questions that are typically practical in a lecture setting, and are tested on the material. I am however strongly in favor of item 4, requiring that at least 8 credits must be in pharmacology, diagnostics, and therapeutics. 

Perhaps instead the VOA can tout how progressive and forward thinking we are to allow 100% of credits to be obtainable online.

I feel the proposal is a positive step forward for our patients and Virginia Optometry.  With the changing landscape of optometry and healthcare, this regulation helps "improve the knowledge and skills of optometrists in managing patient care and their practice".  Prior to practicing in VA, I was surprised by the current CE requirement of 16 hours where previously I was required to obtain 30 hours annually. 

One of the objections that I have seen is in regards to the Live CE/real-time interactive CE.  With this regulation, the 50% live is still easily attainable in a cost effective manner.   The "live" CE can be obtained via attending CE meetings (VOA, AOA, SECO, Review Meetings, etc.) or interactive "live" CE webinars and online conferences such as VOA Online CE, CEing is Believing and CEwire2016.  Less cost, no travel…the other 50% can still be obtained via online education with post-tests.  

I am proud of the CE discussion and action that our State Board of Optometry is taking. This is a long time coming and shows they recognize the flaws in our current requirements, are looking at the changes in healthcare and technology, and most importantly are protecting the public.  These changes help make the VA CE requirements more comparable to all other states. The changes do not make VA's requirements any stiffer than the national average.  Currently, VA is the only state to not require any "live" CE.  The educational value of recorded online and journal CE courses is very questionable.  Having no in-person requirement is not in the best interest of the profession and more importantly not in the best interest of the public.  Is every other state mistaken about the benefit of in-person CE? There are more opportunities than ever for in-person CE, therefore travel costs and time lost in practice can be greatly minimized.  And allowing "live webinars" to be equivalent to in-person CE is a good compromise for doctors in rural areas.  Because of the flaws in the current VA requirements, optometrists have been extremely fortunate compared to every other state.  Any CE change will minimally increase the costs, but VA practitioners will still be spending less to maintain their license than in the majority of other states.  The proposed CE enhancements ensure VA optometrists stay current, have access to the most advanced technology and training, and can provide the highest level of patient care...without putting undue burden on optometrists.  With all the rapid and sweeping changes in healthcare it is good to see our state board recognize the need for these CE improvements and looking out for the public.

This appears to be an unneeded change to the current Continuing Educational Requirement already in place and will increase the yearly educational costs of every Optometrist in the Commonwealth.  My vote is NO.

I have been in practice for over 35 years, and have taken CE courses in a number of settings. I prefer to stay home and take CE courses online or through Review of Optometry, for several reasons. One is personal: I have several interests which take much of my time. Travel for CE takes time away from my out-of-office activities. Another is educational: many smaller venues have limited subjects available, and some of them provide me with little interest, but I have to take them to take advantage of the hours provided, and to keep from having to go to yet another program to get more hours. The bigger one to me is the quality of education: I find that online education is almost uniformly informative, organized, and easy to digest. I do not find this in live lectures. I have seen far too many lecturers who worked very hard to cram 10 minutes of information into a 2-hour course. This makes it hard to concentrate long enough to learn anything. With online/journal CE, I can re-read until I understand the author's point; with live CE, if I miss the point, I miss it. Another advantage to doing this through journals is that I often find other articles in the same journal which captivate my interest, which I might not have read if I was not leafing through that particular journal. I see this proposed requirement more as a way to ensure that travel-CE programs are financially supported, and do not feel that this is necessarily an advantage. Forcing us to pay more and take more time to learn the same thing (and possible less) is not of value either for me or (more importantly) for my patients. Thank you for your time and your consideration.