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The cart before the horse - RACE's new CE reporting requirement

    • 149 posts
    December 23, 2021 3:37 PM EST

    All veterinarians and some veterinary technicians (depending on the state in which they are employed) must be licensed to practice veterinary medicine. Licenses are issued for a defined period of time (varies from state to state) and must be renewed in order for an individual to be able to practice. Included in the requirements of a licensee - for the renewal of a license - is the mandatory fulfillment of continuing education (CE). Continuing education requirements of veterinarians and veterinary technicians in the USA vary from state to state. Variables include the number of required hours of CE, the interval or frequency of CE fulfillment and reporting, accepted methods of delivery (e.g. in person (seminar) vs. virtual and synchronous / interactive or asynchronous / non-interactive), subject matter type (e.g. medical vs. non-medical topics), and finally, caps on certain of those variables (e.g. non-medical topics, or online and non-interactive study).  As such there is no "one size fits all" approach to helping colleagues fulfill their CE requirements.

    The American Association of Veterinary State Boards Registry of Approved Continuing Education (AAVSB RACE or "RACE") has long been regarded as the authority on: 1) the establishment of the standards of quality veterinary medicine continuing education, 2) accreditation of CE program Providers, and 3) oversight of those approved CE Providers. As stated on their website, their "goal is to support the AAVSB member boards by ensuring that all RACE-approved continuing education programs meet appropriate standards of quality." Most of the state boards of veterinary medicine in the US regard "RACE-approved" program completion as qualifying for CE fulfillment in their jurisdiction. There are exceptions. New York, for example, has established its own standards and conducts its own approval process of prospective continuing education providers. As such, if a CE provider wishes to be supportive of NY state licensees in meeting their CE requirements, they must also seek accreditation as a CE provider in NY state (even if they are already deemed a "RACE-approved" CE provider).

    I am a veterinarian and over the course of my career I have held licenses to practice veterinary medicine in 4 different states. Historically, and for as long as I can recall, the onus was always on the individual veterinarian or veterinary technician (in these states) to maintain their own records regarding CE fulfillment. Each state varies in the reporting requirement. Some states require that professionals submit proof of CE completion by providing copies of CE certificates when renewing their licenses, while others are not required to submit those except in the instance of an audit (for example).

    Since 2009 or 2010 (around the time that VetVine became an accredited CE provider), one obligation and requirement of AAVSB RACE-approved CE Providers has been the maintenance of records. Record keeping has always been a requirement of RACE-accredited CE Providers. They are obliged to maintain records and to demonstrate proof of an individual's successful completion of CE in the event of an audit. The CE Providers must be able to demonstrate that an individual met the requirements associated with a particular program including proof of attendance or that the individual met the contact / viewing time requirement as well as completion of an evaluation. In the case of online, non-interactive CE programs, individuals must also pass a post-test associated with the approved CE program. These records must be maintained for at least four years after RACE approval and the Provider must be able to provide copies of these records, in the event of an audit by RACE or a state Member Board, within 10 days of such a request.

    In or around October of 2020, RACE notified its CE-approved Providers of a new system they were implementing in partnership with an entity called "CE Broker" for CE course application submission. This was followed in November of 2020 with an announcement that "New Race Standards" - which included a requirement of Providers to "upload attendee lists" into their portal - would become effective January 2, 2021. Their claim was that this improvement would assist attendees of CE programs in keeping track of their CE completion. This new reporting requirement of CE Providers was to sync up with "RACEtrack" - a system that permits individuals to keep track of their CE participation. Their goal was to provide a single system that would "provide a seamless connection between CE Providers, licensees, and regulators." In theory this seemed like a great idea.

    RACE's announcement of this requirement of CE Providers was jarring. There was essentially little to no time to prepare for this huge shift in required record-keeping, reporting, and departure from the customary issuing of CE certificates (which our constituents heavily rely upon). Further, the Providers were requested by RACE to "Please encourage all attendees of any RACE program to create a free RACEtrack account to track their CE." This single request was suggestive, to me, that RACE was leaning on the Providers to be the instruments for driving the change in CE tracking for its Member (state) Boards. Mind you, none of our many, many, many CE program attendees ever inquired (then nor any time since) about whether we would / could report their CE participation via RACEtrack.

    In February 2021, VIN News reported on this issue and brought to light a number of concerns shared by various CE Providers regarding these mandates. Shortly thereafter, RACE hosted a virtual Town Hall to discuss these change requirements and to address questions from CE Providers. Subsequent to that Town Hall, Providers were granted an extension (June 1, 2021), to permit them an opportunity to ramp up and come into compliance with the new reporting requirement. On June 23, 2021 an email was sent by RACE reiterating that the requirement was effective June 1, 2021. They also stated "The AAVSB RACE team understands that not every provider will be able to comply with the roster upload requirement immediately. As a result, the RACE Committee will allow Providers a grace period until January 2022 to meet this requirement without it adversely affecting your RACE Provider status."

    To date - since the initial announcement of this new system in 2020 - VetVine has not received a single request from any individual utilizing our platform to report their CE fulfillment via CE Broker / RACEtrack. Our constituents do continually request and entrust us to provide them with CE certificates that document their CE completion. Per an email communication earlier this month related to the ongoing coverage of this story by the VIN News Service, Edie Lau (Director, Editor, and Reporter) indicated to me that (at this time) only one Member Board (South Carolina) is requiring their licensees to use the CE Broker / RACEtrack system for CE reporting. This means that the remaining 60 (or so) North American regulatory bodies affiliated with AAVSB RACE have not implemented use of this system as a requirement for keeping track of the CE fulfillment of their licensees.

    So what exactly is wrong here? Quite a few things, actually. While this idea of a centralized system to coordinate CE Providers, licensees, and regulators seems like a good one, the implementation of it has totally lacked foresight and makes no sense. The roll out has been akin to putting the cart before the horse. Why is a requirement (aka burden) being placed on the CE Providers when only one state board has adopted its use? Who thought it was a good idea to make the Providers the instruments of this change? Shouldn't each and every one of the Member boards have signed on in agreement to actually use this centralized system? Shouldn't each of those Member boards have adopted use of RACEtrack and informed their licensees of this new reporting requirement ... before imposing a requirement on the CE Providers? The AAVSB Member boards themselves (not RACE) are charged with qualifying whether their licensees have met their stated CE requirements - not RACE! If the vast majority of these Member boards have not embraced this system (and continue to verify in the manner they have historically relied upon), why should it be a requirement of Providers to report this information to RACE?

    This RACEtrack reporting requirement calls for a massive change in operations for RACE-approved CE Providers. For CE Providers like VetVine - who offer online, on demand video programming for users to access asynchronously, 24/7 - these changes in reporting requirements are huge. VetVine literally has scores and scores of videos and CE learning opportunities. Think of our platform as something similar to Netflix. Individuals consume content in a piecemeal fashion - an hour here, 15 or 30 minutes there, etc. We are not equipped and sufficiently staffed to meet the new reporting requirement for each and every program that we host AND issue CE certificates of completion to our constituents who are still expecting those certificates. It's duplicative of effort and a requirement that seems to only be required by AAVSB RACE (not the vast majority of individual state boards). It's got to be one or the other. I don't mind change or technological improvements. I think that this centralized system makes perfect sense. What does not make sense is this mandate of CE Providers. We were not hired to be instruments of change for RACE. And, by all appearances, the state boards - for whatever reason - don't seem to be embracing use of this system. 

    Other issues and concerns that have been expressed by CE Providers center around the sharing of information and privacy. The reporting requirement of Providers includes publicly searchable information (e.g. profession (vet or vet tech), state and license number), coupled with the program(s) they've completed. That information can be mined to reveal the activities and subject matter(s) of interest of these individuals. We, as CE Providers, have no control over how that information is accessed or leveraged by this third party entity known as CE Broker / RACEtrack. This reporting requirement may actually put some Providers in breach of the assurances provided to their constituents as expressed in their privacy policies.

    On December 17, 2021 CE Providers received another email reminder stating " beginning January 1, 2022, you are required to upload RACE Attendee Lists for your programs." It's December 23, 2021 and I am wondering:

    1) How many users of VetVine's CE platform have ever heard of RACEtrack?

    2) How many of you have established a RACEtrack account for purposes of tracking your CE participation?

    3) For those affiliated with a state board of veterinary medicine, what is the status in your jurisdiction ... are you requiring your licensees to use RACEtrack as a method for keeping track of / reporting their CE completion?

    4) To our valued Members - veterinarians and veterinary technicians - if you don't use RACEtrack for keeping track of your CE completion, how do you feel about having your information reported and shared in this fashion?

    This post was edited by Sheri Berger at December 23, 2021 4:56 PM EST
    • 406 posts
    December 28, 2021 1:11 PM EST

    We recently conducted a poll of our Premium Membership subscribers and asked them a few questions regarding this issue as well as their preferences regarding CE reporting. Here are the results (based on data collected through 12/27/21):

    - 100% indicated that they had NOT received any request or requirement by their state board to establish a RACEtrack account

    - Regarding their CE reporting preferences: