Independent verifier
qualification criteria.

A. Organizational independence and conflicts

Require independence from CE providers under examination: no disqualifying ownership, common management or financial entanglements; written conflict-of-interest policies; disclosures of relevant relationships; and no fees or compensation contingent on a favorable verification outcome. Provider-paid verification may be permitted under Board-authorized terms with meaningful safeguards.

B. Written and transparent verification standard

Require a published, accessible standard addressing participation, instructional time, examination integrity, identity, instructor communication, audit records, complaints and corrective actions. Each decision should identify the applicable Board rules and any additional Board-adopted safeguards, not mistake suggested TRACE benchmarks for law.

C. Technical expertise

Demonstrate competence in learning-management systems, online video and reading controls, time-on-task systems, assessment security, identity methods, audit trail review, records management and regulatory compliance. Merely reviewing course descriptions or provider policies does not establish technical delivery competence.

D. Consistent individual-course verification

Use documented repeatable procedures for application screening, actual learner-path access, participation testing, exam settings, identity, certificate issuance and audit records. Record findings, deficiencies and corrective actions for each individual online CE course. Shared platform tests can support, but do not replace, course-specific review.

E. Documentation and auditability

Keep retrievable records identifying the reviewed course, provider, test date, applicable standard, reviewer, tests run, results, deficiencies, remediation, final determination, renewal/expiration date and evidence. Boards must be able to reconstruct how the result was reached, subject to appropriate confidentiality and privacy safeguards.

F. Personnel qualifications and disclosure

Maintain professional qualifications, roles, training, independence and conflict disclosures for reviewers, auditors, decision makers, appeals staff and supervisory personnel. Disclose relevant provider relationships and disciplinary or regulatory history where lawful. Provide records to the Board on reasonable request in applications, renewals, complaints and audits.

G. Reporting and transparency to Boards

Provide access to standards, current verification status for individual courses, relevant findings, deficiency/corrective-action history, suspension or withdrawal decisions, and conflict disclosures. The Board retains the ability to inspect and challenge the basis of a report.

H. Renewal and ongoing monitoring

Recognition should not be indefinite. The original criteria suggested periodic organizational renewal, for example every two to three years, with earlier reviews for complaints, poor-quality decisions, changes to technical standards or conflicts. Individual course verifications also need defined validity periods and reevaluation after material changes.

I. Corrective action and Board authority

Boards should be able to demand supporting records, require remedial action, reject a particular course report, order reverification, suspend reliance on an organization's reports, or revoke its recognition, subject to lawful process and appropriate appeals.

J. Multiple qualified organizations

Eligibility should rest on objective published criteria, rather than any named vendor or exclusive contract. Multiple competent independent organizations should be free to qualify, protecting competition, capacity and institutional neutrality.

K. Equivalent standards

Boards may recognize different transparent verification methodologies when they meet the Board's substantive course-delivery and documentation requirements. The original proposal permits equivalent standards that substantially address participation, time, identity, exams, instructor communication, auditability and accountability.

Relationship to TRACE's formal rulemaking proposal

TRACE's broad mission includes research, Board education and examination of multiple accountability approaches. Its specific formal regulatory proposal is that every individual online CE course shall undergo independent third-party functional compliance verification by a qualified organization as a condition of CE credit acceptance, where authorized through state-specific rulemaking. PACE recognition and existing Board approvals continue; independent technical verification supplements those processes. Each Board retains authority to adopt its own qualification and procedural terms.