Despite there being a common mandate from the EPA that states regulate continuing education in the water and wastewater industry, there are 50 different solutions among the 50 states. There was a report issued in 2011 by the U.S. EPA Office of Inspector General that cited the EPA for doing a poor job of overseeing this program and that hasn’t significantly improved. Unfortunately, this leaves the job of improving this conundrum on us, the industry. Worse, it has since been complicated by the rapid emergence of online education, which has become increasingly important as a result of the COVID-19 pandemic, as the resultant responses of authorities to limit contact that temporarily all but eliminated most traditional forms of continuing education. 

While states have enacted regulation for online continuing education, most regulators seem to have, at best, marginal means of regulating this rapidly expanding form of delivery that is transforming all levels of education. Unfortunately, many states are relying on guidelines that were established prior to the availability of modern online training technology and are using methodology of verifying compliance which allows for loopholes — resulting in credit being issued for courses failing to meet basic requirements. Further, many states have limited vetting and have no easy way to access a list of approved courses. To make this worse, regulatory guidelines put the onus on you, the operator — making you responsible for ensuring the courses you take will be accepted. 

So, how do we work together to ensure the quality of your continuing education?

First, let’s forget for a minute state pre-approvals. They are too different and diverse to discuss here. We can only discuss creating quality and compliant methodology — that’s what really matters. Remember, if this wasn’t important, operators wouldn’t be required to take continuing education courses. The quality of America’s water relies on you.

There are simply four basic criteria that, if met, can ensure the validity of any continuing education: in-person training, live web presentations, pre-recorded presentations, or online options. 

A program of continuing education must simply be able to satisfactorily answer the following:

1. How do you confirm that the materials presented are accurate and relevant to the job for which the continuing education is being earned?
2. How do you confirm the identity of the participant?
3. How do you ensure that the participant is provided education for the full time duration for which credit is awarded?
4. How do you ensure that the participant remains engaged throughout the course?

With traditional onsite training, these criteria are met and confirmed by the course provider. Online education is a little different, but modern learning management platforms address these same issues to ensure the integrity of the credit awarded. In order:

1. The course materials can be reviewed for content the same as live courses and, in fact, it is easier because content can be reviewed online. The content provider, supplier (distributor), and regulator should vet the content for accuracy to ensure quality.

2. The identity of the participant can be confirmed by use of a unique login with a secure password set up, editable, and known only to the participant.

3. Ensuring the integrity of a full hour of participation for an hour of credit is simply a matter of controlling the environment. In other words, a Certificate of Completion should not be awarded until the full duration of training has been completed and there must be no way to fast forward or otherwise override the time factor.

4. There are many complex mechanisms available for ensuring engagement, but whatever the method, this is important. 

When these criteria are met, there is no need for complicated verification or matching of certificates and rosters. Properly administered, there should be no mechanism for “earning” a certificate without meeting the criteria required.

Again, the purpose of continuing education is not about earning C.E. credits, it's about gaining knowledge to ensure that our water is as good as it can be. Credits are simply a measure for regulators, but responsible, accountable creation of continuing education programs combined with consistent regulation, provide the integrity of these programs critical to ensuring that credits awarded actually achieve their purpose. 

At Water Otter, we are encouraging suppliers of continuing education to join us in ensuring that their products meet these standards. We all need to work together to correct this. No one is getting rich providing these courses. It’s not about money. It’s about getting it right and making sure that anyone that takes our courses for credit earns it fairly.

And, we are strongly encouraging all states to re-evaluate their vetting of their current online suppliers and to review their policies to determine that they are written in such a manner as to ensure compliance and allow for secure use of modern technology. Do not assume that trade organizations or other third parties have vetted programs they submit for credit. 

Thank you for taking time to read this and to consider just how easy implementing a program of compliant online continuing education can be. We are committed to compliance, and we believe that the industry must raise their awareness of that standard. At the end of the day, this makes everyone’s job easier, makes regulatory oversight more credible, and, most important, contributes to ensuring that continuing education achieves its purpose. 

Thanks for doing your part to support America’s most precious resource — our water.

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