Subcommittee debates 'two-week' application rule; staff told to draft flexible "prior to examination" language

Subcommittee members debated a standing rule that requires applications for off-campus certification courses to be submitted a minimum of two weeks before the examination date. Training officers and regional coordinators urged removal of the fixed two-week rule, saying course rosters and course-completion documents frequently are not available until the week a class concludes.

A member proposed changing the rule phrase "at the time of examination" to "prior to the time of examination" and deleting the minimum two-week requirement. Supporters argued that this change would permit the commission office to set internal policy (for example a 48- or 72-hour cutoff or noon-on-Monday roster deadline) and provide flexibility when the office is understaffed, while still requiring that all supporting documentation be submitted before the test event. Staff said they could implement an internal policy that distinguishes between open testing events (which could retain a week or two notice) and end-of-class testing events (which frequently require same-week verification).

Members discussed specific operational exceptions, such as accreditation visits that reduce staff capacity, and considered a formal policy allowing the director to grant exceptions. The subcommittee directed staff to change the draft wording to use "prior to the time of examination," remove the mandatory two-week phrasing, and return with a proposed internal policy describing reasonable cutoffs and exception processes.