Wednesday, November 27, 2013

Just for CEU providers

Pesticide re-certification classes, like the 2013 Fall IPM Seminar held at
the AgriLife Center in Dallas, serve over 15,000 urban pesticide
applicators each year in Texas.

The Texas Department of Agriculture is changing the way pesticide applicator training providers must operate.  The recently published Texas Pesticide Re-certification Course Accreditation Guide provides step by step instructions on how to put on a re-certification course, and get course approval.  It also outlines the new process of completing and submitting course rosters to verify attendance at the meeting.  

After studying the requirements, it looks to me like the new system is not a major change overall, but the reporting requirements will increase the administrative burden on some CEU course providers. My office puts on two large CEU training courses every year, with hundreds of participants; but I've concluded that the new system shouldn't affect our office's administrative time significantly.  This is because (1) we already have all participant names and license numbers in electronic format, and (2) the courses we provide consist of one big all-day meeting (without concurrent sessions).  But for some providers, substantially more time will be needed to document attendance and credits awarded.

Under the new rules, now in effect, TDA requires CEU providers to send an electronic roster of all participants in a CEU course within 14 days of course completion (previously we only had to supply copies of the sign in sheets filled out by participants). Presumably this system wasn't working well for TDA. Paper records are notoriously slow to access and deciphering hand written rosters could be a problem. To address the issue, TDA now has two electronic forms depending on the type of CEUs being rewarded: form PA-411E for agricultural licenses (including 3A licenses) and form PA-418E for structural pest control license holders.  

Under the new reporting system, if a person holding both a structural pesticide applicator's and an agricultural pesticide applicator's license wants to receive both kinds of CEUs for attending a meeting, that person's name must appear on both rosters.  Each roster must list all the appropriate CEU credits earned by those on the roster. 

So far, so good.  The only big difference between the current and former system is that attendance records must be submitted electronically.  For many providers this shouldn't be too difficult, as the names, addresses, and license numbers can be cut and pasted from an existing electronic roster and placed on the appropriate TDA roster(s).

Unfortunately, things get tricky when real life hits.  Suppose 100 people attend a training in which five CEUs are offered, and 2 people leave early, missing the last CEU.  You will now need to supply TDA with two rosters.  One roster will list the 98 people who sat through the whole training and received credit for five CEUs, and one roster will contain only the two early-departers.  The second roster will show that they only earned (the first) four CEUs for the day.  

Consider a parallel situation where 98 attend the full day's training and two people miss one CEU each--however one person comes in too late for the first CEU and the other leaves early, missing the last CEU. Now the course provider has to supply three forms: one with 98 names on it (showing they earned all five CEUs), one (showing the last four CEUs) for the late-arriver, and one for the early-departer (showing that he earned only the first four CEUs).  Conceivably this could get complicated with a large program and lots of people not staying for the whole program.   

Another tricky situation occurs when concurrent sessions are offered at a training.  Suppose you offer two concurrent sessions at your meeting.  For the first concurrent session people can choose between a talk on, say, (A) Lawn and Ornamentals or (B) Termite.  At the second concurrent session they choose between a talk on (C) IPM or one on (D) General Pest Control.  For this scenario the provider will need at least four rosters including one for people who attended each of the following combinations of talks: AD, AC, BD, and BC.  If there are three sessions, eight rosters will be required; for four concurrent sessions there will be 16 possible roster combinations.  Most providers will conclude that it is easier to just have a separate roster for each concurrent session.  It will also take a very patient administrative assistant to retype the name, address and license number of each session attender.

I strongly recommend all CEU providers maintain session sign-in sheets, or use some other paper means of documenting attendance at each session.  This will help tremendously in ensuring accuracy of the computer rosters, and will serve as a backup for the spreadsheets.  Remind all course attenders that they must have their license number if they want TDA to verify their attendance.  If you're a sponsor, you must keep course roster and attendance records for a minimum of two years (six years for private applicators). And lastly, remember that certificates of completion must still be supplied for all attenders as their proof of CEU completion.  

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