Letter to FSMTB regarding REACH and CE Approval Process
Purpose:
Communicate the Alliance for Massage Therapy Education (AFMTE) response to the FSMTB regarding the actions taken during the recent FSMTB Annual Meeting. The four Items of Concern are: Renewal Recommendation (6 hours annually), REACH Program (LMS for FSMTB), Taskforce Resolution (recommending vetting of Providers and Content), and the CE Standards Document (IACET Requirements).
Requests:
The Coalition of National Massage Therapy Organizations (ABMP, AFMTE, AMTA, COMTA, FSMTB, MTF, and NCBTMB) has a role to play in balancing and enumerating roles within our field. Now that the NCBTMB has ceded its role in initial licensure to FSMTB, the coalition needs to meet, discuss, help formulate, and then to support the roles and boundaries of all national organizations. We request that the FSMTB and NCBTMB take action on these items:
FSMTB hold off on making changes to the suggested License Renewal Recommendation until the Federation has delivered MBLEx Practice Exam module, the Study Guide Module, and any other pending projects. The Renewal Recommendation is controversial and needs more input from licensees, CE Providers, and Schools.
The FSMTB concentrate on their stated goals, including initial licensure issues, provide improved board member training, create remediation courses for disciplinary actions (not CE, these are disciplinary/remediation courses), and support approval of schools by verifying state educational requirements are kept and ensure that the schools continue to stay legitimate and well regulated.
Allow NCBTMB (and other organizations approved by the NCCA/ICE/IACTE) to continue to approve providers and content of CE courses required for renewal of State Licensure or renewal of Board Certification.
Support and make improvements by working with all national organizations regarding vetting and course approvals.
Make only minor changes to the renewal process. For instance:
Each licensee would complete these tasks:
complete renewal forms,
comply with established board renewal requirements (e.g., competency assessment, safety classes, combo, disciplinary history),
submit proof of completion of other mandated CE courses (if required),
pay renewal fees.
Commentary and Analysis:
Item #1 License Renewal Recommendation
“Massage therapists are required to either:
1. pass a competency verification assessment each renewal cycle; or
2. complete six (6) hours of public safety courses annually; or
3. complete at least three (3) of the six hours of public safety courses with
the remaining hours being exchanged for certain Professional Development Activities.”
Reference/source: Renewal Recommendation
Analysis: 6 CE hours per year, 12 per biennial renewal: 6 hours of Public Safety or 3 hours of Public Safety and 3 hours of Professional Development Activities. There is no recommendation on the balance of CE hours required by most state boards.
Questions: Is the FSMTB Task Force suggesting that all Boards move away from continued professional development and focus only on “public safety” issues as a means to renew a massage therapy license? Will Boards be encouraged to reduce renewal requirements? Will Boards petition to change statutes and reduce mandated hours? What is “competency verification?” What are “public safety courses?” Who develops and delivers these courses? Are there any costs to licensees, the State Boards, or the FSMTB? Is this an income stream? Will license renewal materials be generated by CE Providers?
Statement: The AFMTE believes the FSMTB Task Force Proposal has elements that will affect all CE Providers by encouraging State Boards to reducing required professional development hours and mandating only “public safety courses” or a “competency verification” assessment for licensure renewal. We believe professional development hours should still be mandated and that at least ½ of all total required hours be devoted to professional development.
Item #2 The “REACH” Program
“The Regulatory Education and Competence Hub” or REACH, is an online learning management system that houses regulatory-focused educational courses and services for the Federation’s member boards. When opened to the public, REACH can be found on the FSMTB website. “REACH serves several functions for the Federation including offering public safety courses for license renewal and remediation courses for disciplinary actions by its member boards. Each course is available for mobile devices and designed following best practices for adult learning using interactive multimedia experiences that engage the learner and deepen understanding of the content.”
Analysis: REACH is far reaching and has a clause about opening REACH to the public. This may have something to do with an aspect of the Resolution describing so-called classes offered to the “consuming public.”
Questions: What is, and who are, the consuming public? Can the FSMTB create and deliver all of the following in a timely manner: Practice Exam, Competence Verification Assessment, Public Safety Courses, Disciplinary Remediation, Board training courses, AND create (duplicate) a CE Approval and Course Approval system?
Statement: The AFMTE believes FSMTB CE Task Force has good intentions for the field, yet might overstep its bounds if the FSMTB begins to reinvent the CE Approval process. We do agree that sponsors and providers should meet IACET requirements; we further note that the NCBTMB already has a system to vet IACET compliance. We support most elements of REACH (i.e., MBLEx Practice Exam, Board Member Training, and Remediation for Disciplinary Actions). We have some reservations about the Competence Verification Assessment as an option to CE courses. We also are concerned about a possible conflict of interest in the development, delivery, and administration of Public Safety Courses. As proposed, the courses would be given CE credit and it appears that the FSMTB would be creating the courses — and not just setting the guidelines for CE providers to develop courses that meet the content criteria.
Item #3 Taskforce Resolution
“[…] THEREFORE BE IT RESOLVED, that the Federation of State Massage Therapy Boards will expand the organization’s services to member boards by implementing a program that provides reliable, unbiased, and appropriate vetting of continuing education providers and the classes offered to the consuming public. “
Analysis: “Vetting of continuing education providers and the class offered” is a direct threat to the viability of the NCBTMB and all CE Providers. There is a redundancy here that is bound to create problems for the field (e.g., Boards having to determine which agency to use for their approved providers and courses, CE providers being required to submit applications to multiple “sponsors”).
Questions: How does this effect CE Providers, Schools, and States with CE evaluation systems in place? How should the profession interpret this Resolution? How does the NCBTMB interpret this Resolution?
Statement: The AFMTE believes the FSMTB Task Force Resolution Oct. 2014 has elements that will affect all CE Providers and Schools. The Federation has other projects to complete successfully before embarking on a reinvented Provider Approval/Registration program. The NCBTMB has a system that is working and available. We recommend that the FSMTB cooperate and collaborate with the NCBTMB regarding approving continuing education providers and content.
Item #4 CE Standards Information – source: CE Standards 10/14 FSMTB
Administration: Sponsors: Our current CEs aren’t delivered this way. Most CEs are done through individuals.
Disclosure: Fine
Content: This is still extremely vague. Who decides what is relevant to the practice of massage therapy?
Assessment: This doesn’t work in the current CE environment. For example, a CE provider gives a 3 hr class at a conference for 150 people. According to this, now the participants will need to be given some type of assessment. This is unreasonable as it places undue burden upon the CE provider.
Instructor: We totally support the concept. Unfortunately, there aren’t many ways to ensure that instructors demonstrate knowledge. More importantly, from the Alliance’s perspective, this point addresses content knowledge, not teaching skills and abilities.
Feedback from Our Members:
The feedback from our members is that this move by the FSMTB could be perceived as a potential restraint of trade and a monopoly over required CE courses. We have received many calls from various folks who point out that this change will lead to a huge loss of income for CE providers.
Even if the CE requirements for license renewal get modified, the creation and delivery of CE courses to meet these requirements should be open to currently approved CE sponsors and providers. This is a conflict of interest: the organization making requirements should not be the one creating the courses — and getting the revenue from those courses. This is not the time to be making this change. It needs more research and refinement. Also, as an aside, once the FSMTB clearly defines the parameters for Public Safety courses and Professional Development courses it would be very easy for the NCBTMB to designate which of the current courses on its list meet those guidelines.
Summary:
The AFMTE represents all sectors of the massage education field: schools, teachers, CE providers, and vendors. Our mission is to support, strengthen, and elevate educational practices and standards in massage therapy and bodywork.
The AFMTE and the NCBTMB are working together on the new Board Certification CE renewal process and other issues. The AFMTE is relieved and excited that the FSMTB and the NCBTMB are working together for the good of the profession, as is demonstrated by the agreement of designating the MBLEx as the only licensing exam for the state boards. The pieces of the puzzle are coming together.
We believe collaboration among the stakeholder organizations is vital to move the profession forward. We encourage continued collaborative efforts among all stakeholder organizations and look forward to working with both the NCBTMB and FSMTB to better our profession.