April 2023 Update: A quick review of the LPC Rulebook late last week revealed the existence of a 2nd "effective date" that 3-4 pair of eyes belonging to some of the most eagle-eyed talent in all of N. Dallas had failed to spot. Essentially, part of the newly minted renewal hour requirements took effect in March of 2023, the balance take effect on Jan 1 of 2024. The explanatory chart we created for the new rules has been updated and can be downloaded here. Bottom line is, assume that all of these rules are in effect now and plan/obtain your hours accordingly.

Last week we talked about the how-to's of getting on your board's "approved provider list", if you're a ce provider. My apologies, that post should have come with a downloadable 30 day supply of Lavender Essential Oils and 432 HZ music playing in the background. You might need something stronger, but try this protocol, first. I did promise you we'd talk about the tracking of these CEU's, though, and how to avoid the impending train-wreck so here we go.

Who Tracks My CEU's?

The short answer is, you will. Not your board, not the good people at BHEC, not the CE Provider you got the hours from; you do. Any thoughts on that?

How Do We Track All of This?

There's nothing in the rulebook that spells out the precise procedure for labeling the hours you turn in or who is supposed to make a) initial determination (probably you) or b) final blessing (BHEC staff) as to whether or not the provider's are A/P's or not. We're working on the honor system here.

Are you supposed to provide notation for each hour or is the BHEC staff supposed to guess at your various providers' status? Will they even do that? Or is the provider supposed to mark their ce certificates in some manner?

None of that was addressed by your board when they came up with this "penny on the train track" system so you're on your own to come up with something that works for all parties. Keep reading.

How Do I Know Who's a Preferred Provider?

First, your rulebook lists the (8) categories of provider that have been anointed A/P status. If you're wondering if a ce provider is an A/P because they haven't made it obvious to you in their marketing materials (more on that in a minute) then you're going to have to measure that provider against the list and ask yourself, "are they an association? Are they a higher education...." and so on right down the list. Yes, you will have to do that.

Second, the smart-marketing ce providers will make it obvious in their marketing materials, on their websites, and on their ce certificates. They will claim A/P status in both text and a nice "Approved Provider" icon, like this one. They will make it obvious that they are claiming A/P status and make it easy on you.

What If It's Not Obvious?

Yeah, the gray areas. They exist and you will find them; providers who don't clearly fall into one of the Big 8 categories. Like, Pesi, for example. Is Pesi an Approved Provider? No, they are not. No category for "ce provider aggregators" and they are not an association. BUT, you're not taking the course from Pesi, you're taking a course through them so the party that you need to be focusing on is the actual provider you're taking the course from. Does that individual provider fall into one of the Big 8 categories of A/P's? See how that works?

Other than that it seems you have (3) options.

1. You could ask the ce provider if they are an A/P provider according to your board in the state of Texas and hope they know what you're talking about. I wouldn't put much stock in this option.

2. Take the course anyway, and make sure you get enough verifiable A/P courses from other providers to get your minimum 50% hours in. (Inefficient, but it would work.)

3. Read the new list of providers in your rulebook (see 681.140) as BHEC will not be able to provide clarification as to whether the provider would be counted as Approved or not. It's in the rulebook.... SO get out your yellow highlighter and highlight section 681.140 for easy access, please. Go ahead. I'll wait...

Pretty much leaves you making the A/P determination for yourself per your rulebook, doesn't it.

How Will BHEC Know My Hours Are Approved?

They won't. No one will know for sure if the hours you submit at renewal are the required ratio of Approved vs Non-Approved hours unless you are audited (in which case the process of proving your claims will be dumped right back in your lap and you will end up doing the same verification work you should have done in the first place). This whole attempt at micro-oversight is run on the honor system and the only way to enforce it from Austin is through random 5% audits. Again, the BHEC staff is not going to contact your ce providers for A/P status clarification. That's on you.

You could just blow the whole thing off (except for the jurisprudence exam). Just take whatever ce courses you want to with no thought towards approved vs non-approved and still have a 95% chance of skating by just fine. That's better odds than you'll get in Vegas, although I'm not at all suggesting you embrace this option. Honor is always the preferred route.

Best Case Scenario

Two things you'll need to do to cover your....position on this and survive your next renewal submission.

1. Know right up front who you're taking your courses from and whether or not they are an approved provider, according to your Texas board.

2. Keep very detailed track of the ceu's you rack up prior to renewal. You'll need to practice #1 above and chart the hours, who they were taken from, and the type of qualifying institution from which they emanated. And, of course, keep track of your ce certificates.

Fortunately for our AMHP members we've put together a simple chart that you can print out and use to track your ceu's. When renewal time rolls around you'll have a comprehensive record of what you took, who you took it from, their A/P status, and verification that you've met the 50% Rule minimums (remember when this was easy?).

That form is available here for AMHP Members. Go register if you're not already a member then come back here to this link and it's all yours. And don't forget, these new rules are effective Jan 1, 2024 but that means anyone renewing Jan 1 or later will need to submit ce hours acquired according to the rules in affect on Jan 1. That means use the new rules as your guideline NOW.

You got this!