Continuing-education committee backs mandatory BLS certification, directs staff to finalize regulatory text

The Board of Chiropractic Examiners Continuing Education Committee on Dec. 13, 2024, voted to recommend that the full board adopt a rule requiring all active licensees to maintain current Basic Life Support (BLS) certification at either the provider or advisor level and directed staff to finalize regulatory text for board consideration.

The committee, meeting by teleconference with its primary location at the Department of Consumer Affairs in Sacramento, also received a staff update on continuing-education (CE) modernization efforts, heard plans to ramp up CE audits, and discussed a proposed process to grant limited extensions for licensees affected by natural disasters or medical hardships.

Why it matters: committee members and staff framed the BLS recommendation as a public-safety measure and a regulatory change that will require drafting justification and regulatory language for Office of Administrative Law (OAL) review. The committee approved the motion by roll call; the recommendation now goes to the board for consideration. The committee also discussed operational changes that affect how providers apply for and how licensees document CE credits.

Kristen Walker, the board's executive officer, told the committee the office has "developed and implemented a new paperless CE course approval workflow" and that the department is exploring ways to replace static PDF course lists on the board website with a searchable, interactive listing. Walker said a planned upgrade to the DCA Connect system was "temporarily paused" because of limited vendor resources, and staff now plan to build CE functionality in the current system while preserving compatibility with the forthcoming regulatory changes.

Walker presented application statistics that show an apparent decline in annual CE course applications and reported hours after the board increased CE application fees and moved to a three-year approval cycle. She said applications dropped from about 1,900 applications representing roughly 9,000 hours to about 1,100 applications and about 4,000 hours, a level staff expect could be the new annual baseline once three-year approvals are in place.

On audits, Walker said the office will increase CE audits early in the year and provide advance notice to providers and associations via the board listserv. The office plans to sample about 5% of renewals but perform a four-year lookback for selected licensees rather than repeating an annual-audit snapshot. Walker described the change as a way to be "more effective" while keeping staff workload manageable; she said other boards typically audit about 3% and that the board once audited 10%, which was "not sustainable." The committee heard that audit outcomes have ranged from educational letters to citations and that, after a citation, a licensee generally has 30 days to pay a fine and comply with any abatement unless a longer period is specified.

The committee also discussed licensee use of DCA's Connect system for renewals and CE uploads. Walker said Connect adoption is "now a little bit over 40%" and that the renewal notices were updated to promote Connect as the preferred method; licensees who receive an audit notice will be able to either upload documentation into Connect or mail/fax paper records. "We're not trying to catch any licensees off guard," she said. "We're going to give licensees flexibility. We're going to send them the audit notification and give them the option that they can either upload it into the Connect system, or they could do it the old fashioned way, mail it or fax it to us."

BLS proposal and committee action

Staff reviewed the history of a previously mandated CPR requirement (in effect 2003'2007) and the more recent discussion about replacing it with a Basic Life Support requirement appropriate to health-care providers. Walker said the committee has sufficient justification to require ongoing certification in BLS (provider or advisor) on public-safety grounds but that staff lack sufficient evidence to justify a separate requirement that providers who hold an "advisor" certificate post public notification that they will not perform hands-on CPR.

Walker summarized options for the committee: (1) make maintenance of BLS certification (provider or advisor) an ongoing condition of licensure and active status; (2) impose a one-time requirement at licensure and a deadline for existing licensees, without ongoing verification; or (3) not proceed with a regulation. Walker said the office needs additional supporting data if the committee wants to pursue a patient-notification requirement for advisor-level certificate holders.

Committee members debated training frequency, competency testing and the meaning of "advisor" versus "provider" credentials. "If we're going to require it, it needs to be practiced, and it needs to be practiced," said Dr. Pamela Daniels, a committee member. "Minimum was every two years."

Dr. Lawrence Adams moved that the committee recommend the board adopt a regulation requiring maintenance of either BLS provider or advisor certification as a condition of licensure and active status and that staff finalize the regulatory text for board consideration. The motion was seconded and passed by roll call: Dr. Lawrence Adams (yes), Dr. Pamela Daniels (yes), and Rafael Sweet (yes).

Hardship extensions for disasters and medical conditions

Staff presented a draft proposal originally developed in 2022 to give licensees relief when they are affected by declared natural disasters or emergencies. The draft would require a signed request and supporting documentation (for example, proof of residence in an affected area, financial records, or a clinician's statement) and would allow the board or its designee to grant a limited extension. Committee members favored a move from a case-by-case "exemption" model toward a time-limited extension model and asked staff to craft clear application forms and objective criteria.

Walker explained the rationale for allowing a 180-day extension (half of a renewal cycle) so affected licensees could remain in active practice while they worked to meet CE obligations. She also said that, with the upcoming CE regulation changes, more synchronous and asynchronous online CE will be available, which staff expect to ease recovery for licensees who lose local access to live courses. Committee members asked staff to include an option for asynchronous coursework when appropriate and to provide a standardized form for extension requests that includes a signed statement by the licensee.

What the committee directed next

The committee approved the recommendation on BLS certification and directed staff to finalize regulatory language and present it to the full board. The committee also asked staff to continue developing the CE hardship/extension proposal, to build a standardized form for extension requests, and to report back to the committee with revised language and implementation plans (including how asynchronous courses would be treated). Staff said they will continue to report CE modernization progress to each committee meeting and will circulate March meeting-date options for the CE committee.

Ending

The meeting advanced a recommendation to the board on BLS certification and set the CE hardship-extension draft and CE modernization work for further committee refinement and future committee meetings.