FSMTB Unveils Plan for Continuing Education

Last week, the Federation of State Massage Therapy Boards published a document outlining their proposal to jump into the continuing education market. They are calling the new program Maintenance of Core Competency – to be abbreviated as “MOCC”. I don’t know what planet this thing came from, but it sure ain’t from this solar system.

Coming fast on the heels of the unresolved conflict-of-interest mess with the FSMTB President spearheading legislation in her home state of Iowa that would eliminate the education hours from that massage law, the timing of this MOCC release is strange, to say the least.

But let me get to the main event here: When you have a problem on your hands, there’s nothing more aggravating than a solution that is worse than the original problem itself. That’s exactly what has happened.

For many years, those of us who teach continuing education courses, as well as the sponsors of continuing education, have had to put up with an absurd and ineffective system for CE approvals. Most regulated professions have a single national entity that handles this function; we have the national provider approval program run by NCBTMB, as well as individual approval processes operated by about 10 state massage boards. The standards are inconsistent, and it forces CE providers to go through redundant and costly approval processes to be able to offer their courses in more than one location.

There was a cause for hope when we started to see some activity about this last year at the national level. In a press release entitled “FSMTB to Establish New Continuing Education Approval Program” (dated March 29, 2011), the organization announced:

“…the launch of a project to develop a new national program for the approval of both continuing education courses and providers. Once it is established, the program will provide state regulatory agencies with a centralized quality assurance process for all courses taken by massage and bodywork therapists for the renewal of State licensure or State certification.

As the representative for the regulatory community, FSMTB has responded to requests from its Member Boards to create a unified system to ensure that continuing education courses are taught by qualified instructors, relevant to the scope of practice, and meet the needs of the regulatory community.”

This all sounds wonderful, but the MOCC Proposal does not resemble this in any way. What happened to FSMTB’s clearly stated plan?

The MOCC Proposal introduces a totally new concept to our field: that there is a limited group of subjects that are specific to the “core competence” of massage therapists, such as ethics and boundaries, hygiene and sanitation, scope of practice, and unsafe massage practices. These subjects are supposed to be more important to “public safety” than all the other subjects typically studied by massage therapists in CE seminars – which are lumped into a new category called “professional enhancement”.

Based on this concept, the MOCC Proposal makes three recommendations:

1) Requirements for the renewal of state licensure should focus on public protection and maintenance of core competencies. All therapists should complete a required educational program for re-licensure focused on public safety issues. FSMTB would be the provider of this educational program.

2) A transition phase addressing maintenance of core competence as well as current continuing education for professional enhancement will be needed. FSMTB will provide state massage boards with guidelines to assist in the transition phase.

3) After this transition phase, professional enhancement and continuing education is voluntarily attained at the discretion of the therapist and not mandated for licensure renewal.

Instead of working to get broad-spectrum CE mandated for license renewals in all states, the MOCC Proposal recommends doing the opposite. In light of the relatively low number of education hours to enter our field, CE is essential to help practitioners continue to build and strengthen their base of theory and methodology. The narrow scope of “core competencies” suggested in the proposal as the only mandatory elements for renewal do little or nothing to advance levels of skill and awareness of the craft. While looking into how some of the other associations and federations of state regulatory boards of licensed professions handle their CE approval process, I did not locate a single one that imposes a limitation to “public protection” on continuing education the way the FSMTB is proposing to do.

The proposal also contains a statement that, “It is important to the FSMTB that all stakeholders have a voice in the process. The FSMTB requests feedback on this proposal from the Massage and Bodywork community and other interested parties.”

That’s a very open-sounding invitation, but does it strike you as odd that the MOCC Proposal makes no mention whatsoever of NCBTMB and the Approved CE Provider program they’ve been operating for the past 20 years? I would consider NCBTMB a stakeholder – and I’m relatively certain they’re an interested party. Last May, a rep from FSMTB attended the multi-stakeholder summit held by NCBTMB that looked at improving their CE approval program; it doesn’t appear that the invitation was reciprocated.

As I see it, the recommendations contained in the MOCC Proposal will drive the two organizations further apart, and will make it impossible for a global solution to be developed. This is both foolish and unacceptable. There is general support for continuing education being tied to license renewal, as it benefits both practitioners and their clients. Ongoing coursework in certain key subjects (like ethics) can continue to be written into state standards to ensure that licensees stay current with the behavioral aspects that influence their work.

If we’re going to have a single entity handling CE approvals on behalf of the entire profession, which should it be: FSMTB or NCBTMB? In reality, it could be either one – but it would take new levels of cooperation, along with well-crafted agreements to satisfy all the legal and structural considerations. Creating a unified approval program should be the focal point of discussions between and among the major stakeholders in this arena. Anything else is a waste of time.

When it comes down to it, FSMTB is a collective of the state regulatory boards; it has no regulatory authority in and of itself. They cannot force this plan on any state that doesn’t want it. Any state approving their own providers will be free to carry on, and any state that wants to continue to accept courses taught by the NCBTMB-Approved Providers will be free to carry on. The MOCC Proposal states that another document will be forthcoming that details recommended standards for states that choose to continue their own approval process.

As mentioned above, this is currently just a proposal and FSMTB is seeking feedback. I definitely encourage you to give it to them. Click this link.

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9 thoughts on “FSMTB Unveils Plan for Continuing Education

  1. Vicky Karr

    I, too, would love to see a single national entity rather than dealing with, what feels like, endless research, applications, renewals, payments to individual states in order to be able to teach an NCBTMB approved class. But, when the issue arises, turf wars & ego/control issues seem to overpower the philosophy of teamwork and a unified program. From the sounds of this new MOCC concept, I can’t seem to comprehend that this has been developed for the good of the mass majority. How can “professional enhancement” be considered voluntary & optional? Not only will our profession suffer as a whole, but there will be numerous hardworking & dedicated continuing education providers struggling for registration of students.
    I VOTE “NO”!

  2. Michael Breaux

    I think perhaps that you are misinterpretting the word “stakeholder” in the case of the FSMTB. Unless I am mistaken, the acronym stand for Federation of State Massage Therapy Boards. Each of the state boards that joined the Federation and contributed to it both with funding and information constitute the stakeholders in this case. It’s not an association of individual therapists or other organizations. I was the chairman of the Louisiana board of massage therapy during the organizational phase of the FSMTB. I believe that as stakeholders, each state board actually “owns” a share of the Federation and voting privileges etc. I don’t think the NCBTMB was not invited to provide input, I think they were excluded because they are not a state licensing board. The NCBTMB has been a valuable help to our profession and I believe that the FSMTB is as well, seeking to unify the various state boards into more common languaging in their laws and establish national standards that are truly applicable. The NCBTMB sought to do this but without the buy-in of the individual state boards. Yes they are now competitors in the field – but both have good products and lets face it; competition is good for business. It brings prices down and makes the businesses seek to provide a little more value in their wares. I don’t think that there is a big conspiracy theory to limit CE providers. There are therapists out there that are workshop junkies and will always consume mass quanitities of CEs over the required amounts. Conversely, I think that a lot of what is offered in the CE market is repetitious, similar techniques with a new name and worse, a lot of it is just bunk, fads, and nonsense. After over 20 years in this profession, it’s really hard for me to get excited about CE’s. I do wish there were one standard for CE providers, but as long as the state laws are as different as they are, that will probably never happen. Our law in Louisiana is filled with quirks that limit CEs – forcing us to exclude the word “Stretches” (or replace it with something similar) and limits aromatherapy classes to be for “self-care” only rather than client focused. I think both boards want the same things and are moving us as a profession in that direction, but probably by different means. I continue to remain open, believing that there is plenty of room in our field for diversity and that both boards are good for the health of our profession.

  3. Laura Allen

    I am a past state board member, and a past delegate to the Federation. I am well aware of how they work. I have supported the FSMTB because I believe any time people come together with the intent to find solutions to common problems, it is a good thing. I also concede that there is a lot of CE that could stand to go by the wayside, and also that I am one of the workshop junkies…I always have way more CEs than I can turn in by the time renewal gets here (NC does not allow us to carry over hours.) There are a lot of us junkies–but just as many more who don’t care a whit about CE and many who actually resent having to take it.

    I cannot support this proposal in its present form, and I answered the survey with my objections. I hope everyone answers it, and gives their own reasons of why they think it’s good or bad.

  4. Rick Rosen

    To clarify: the term “stakeholder” is used in a number of different ways in our field. The individual state massage therapy boards that comprise FSMTB are stakeholders in that association. FSMTB, in turn, is considered one of the primary stakeholder organizations that make up what is commonly referred to as “the massage therapy profession”. Individual massage therapists are general stakeholders in the field as well.

    There are a few important pieces to recognize in this discussion about continuing education approvals. While NCBTMB does have a long-standing provider approval program, it is a private non-profit corporation that has no formal (contractual) relationship with FSMTB or its Member Boards. That’s a big problem.

    If a state agency outsources a function that is mandated to it by law (statute), it is required to have a direct mechanism of supervision and control over the third-party entity that handles that function. This kind of outsourcing is most often seen in the areas of licensing examinations, software applications and application review processes used by boards, as well as continuing education approvals. The lack of oversight in an outsourced situation is called *Improper Delegation of Authority*. It puts the state agency, and its mandated responsibilities, on shaky legal and procedural ground.

    This has been the perennial objection to the use of NCBTMB’s certification exams for licensure purposes by state massage boards. The sticking point is not one of psychometrics — it’s the lack of supervision and control by these state agencies.

    That’s why the MBLEx was created by FSMTB: to give state boards direct ownership and control over the test program used for entry into the field. Even though the MBLEx now has the lion’s share of the entry-level testing business in the U.S., MBLEx vs. NCE is not a Coke vs. Pepsi kind of consumer contest. State licensure must have a solid legal foundation, and it can’t happen while states are still accepting NCBTMB exams over which they have no authority. There’s just no getting around this point.

    So, the same kind of structural problem exists with continuing education approvals. State boards that have chosen to rely upon the NCBTMB Approved CE Provider Program — instead of creating their own in-state approval process — are doing so under Improper Delegation of Authority.

    When I served on the NC Board of Massage & Bodywork Therapy, we wrote NCB’s standards into our CE rules, because we thought it made sense to use an existing national program rather than reinvent the wheel and create yet another standalone approval program. However, we were newbies at this “regulation thing”, and didn’t know about the broader legal principles that have come to our collective attention in more recent years.

    This is the primary reason a number of Member Boards went to FSMTB: to ask that the organization develop its own single-source CE approval program. Around the same time, the Alliance for Massage Therapy Education approached FSMTB leadership to indicate its interest in working towards the same kind of unified solution. The Alliance, in its role as the designated representative of CE providers and schools, also wanted to see the current patchwork approval system consolidated and streamlined.

    With all this as the lead-in, it’s hard to fathom the MOCC Proposal that FSMTB has just published. As Laura said, it’s a solution worse than the original problem itself. NCBTMB cannot be excluded from these discussions, because they have the only bona fide national-level CE approval program. They’re not going away.

    If FSMTB and the members of this Task Force got to the edge of the Grand Canyon and decided it was not the time to attempt flight, they should have turned immediately to NCBTMB to begin negotiations to forge a working relationship with that organization. The delegation of authority issue can be solved in a straightforward legal agreement that gives FSMTB a formal mechanism of participation in NCBTMB’s CE approval program. The education experts at AFMTE could also be brought in as ongoing partners.

    Instead, FSMTB had a spasm. The MOCC proposal is based upon a phase-out of mandatory CE requirements for the renewal of state licensure, which is the worst of all possible directions to pursue. Let’s remember that we have CE requirements in this field to improve the quality of service provided to clients. We have requirements for the approval of CE providers (and courses in some instances) to ensure that therapists are getting good training, and a solid return on the investment of their CE dollars.

    Time to reboot this process and get back to essentials. This is too critical a piece to let it die in the blogosphere.

    Rick Rosen, MA, LMBT
    Body Therapy Institute
    Siler City, NC

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  6. Shirley Henderson

    Typically state regulations for professional continuing education seek to enhance practitioners’ skills. I can’t think of a profession where the goal is simple maintain original pre-licensing competencies, forcing licensees to take the same material over and over again. In fact most licensing agencies specially exclude relearning what schools taught prior to licensing.

    It is not clear how the Federation’s example of EMTs translates to massage therapists.

    Their goal appears to remove continuing education requirements from state regulations, but forcing massage therapists to take redundant education. This they are calling MOCC which, by the way, is administered exclusively by them.

    By driving out all the massage continuing education schools, they will create a monopoly for themselves, doing away with competitors and competitive pricing.

    If legislators agree to this, they will put hundreds of schools out of business and thousands of people out of work.

    Another problem, the Federation wants to present one set of ideas nationwide, taught in one manner. This negates originality and variety. Traditionally in this country, we have relied on the marketplace to provide a choice of opportunities to meet relicensing requirements. Students have different ways of learning. Computer illiterate therapists will be unable to relicense under the Federation’s plan.

  7. Emmanuel

    When I went to drivers ed, took and passed my test, the state gave me the drivers license because I proved that I knew enough not to harm others. When I went to renew my license I did not have to prove that I was a better driver than when I started. I only had to prove that I still knew what I was supposed to know so that I do not harm others.

    This is along the same lines. It puts the burden on the individual to improve and will perhaps will cause industry forces such as professional associations and the ncb to revamp their own ce requirements.

    What FSMTB is proposing may actually be good for the profession if given the chance.

  8. Linda Lowry

    I would like to extend commendations to the FSMTB for taking well thought out and clear action toward being proactive in our profession on a State Board level. It appears to me that the MOCC proposal is NOT phasing out continuing education in our profession but making it clear that focused competency in the areas of Public Protection is in alignment with State Board licensure renewals. Just as the FSMTB made clear with a State licensure examination that State licensure exams and certification examinations were two different examinations.

    It makes perfect sense to me that the mission of State Professional Boards is generally the protection of the public. In that regard, I really like the idea that the FSMTB has come up with a National approach to satisfy the mission of State Boards while creating a no-fail licensure renewal exam defining competencies in the areas directly relating to protection of the public.

    Continuing Education as we have known it for 20 years would be better served under the leadership organizations within our own profession rather than at the hands of State Boards. Rick Rosen gave the best argument for this case by pointing out that State Boards are limited by their own mandates on outsourcing such things as examinations. Why should we allow State Boards to have control and direct supervision over our professional certification examinations and professional continuing education certifications? The FSMTMB has done a great job in outlining a fantastic opportunity for our profession to work cooperatively with the mission of State Boards while also creating an opportunity to allow our leadership organizations much more latitude in the areas of continuing education.

    Make a choice to see this as OPPORTUNITY. I do not know anyone at FSMTB. I have not taken the FSMTB exam…yet! Nor do I know personally anyone at or on the NCB or the ABMP or the AMTA leadership positions – that I know of anyway. I have voiced my written opinion to these organizations many times over 17 years but I have no direct affiliation other than a yearly membership. I simply see this as a fantastic opportunity for growth and cooperation within our profession. Yes, continuing education in our profession needs upgrading and change. Let’s keep that under the umbrella of our leadership organizations rather than under the legislative diction of State Boards.

    We all know whether we like it or not that anyone meeting minimum requirements and willing to pay the fee can acquire a State professional license – in any regulated profession. Certification and continuing education within our profession (Massage and Bodywork) is better served under the management and oversight of our leadership organizations. Joining leadership organizations is a completely voluntary choice. Let’s keep this simple. Kudos to the FSMTB! I look forward to responding to the FSMTB’s offer for feedback on MOCC. THank you for this opportunity to express my opinion here.

  9. Rick Rosen

    Ms. Lowry’s comment above misconstrued statements I have previously made regarding the legal obligations of state massage regulatory boards. She said:

    “Continuing Education as we have known it for 20 years would be better served under the leadership organizations within our own profession rather than at the hands of State Boards. Rick Rosen gave the best argument for this case by pointing out that State Boards are limited by their own mandates on outsourcing such things as examinations. Why should we allow State Boards to have control and direct supervision over our professional certification examinations and professional continuing education certifications?’

    Actually, state regulatory boards (from any occupational field) are broadly permitted to outsource functions that are mandated to them by their enabling legislation. The basic criteria that must be met is control and supervision over the outsourced function. This kind of working relationship is set forth in formal agreements between state boards and third-party service providers.

    Some examples: The processing of criminal background checks is often outsourced to other state or national agencies. Many boards rely on software products and other services from private vendors to handle certain administrative responsibilities. And state boards typically outsource their examination requirements to providers at the national level — most commonly to a federation of the state boards for that particular profession. The resources needed to create and maintain a legally-defensible exam that meets psychometric standards are far beyond the scope of boards today. (That was the main reason I worked with a group of state massage board reps in 2005 to form FSMTB.)

    This same kind of outsourcing can be found in most professions around the approval processes for continuing education providers and/or courses. In the majority of professions I’ve analyzed, it is the board federation that handles that function on behalf of its constituent state regulatory agencies — NOT the professional membership associations. It’s also important to note here that most regulated professions have mandatory CE requirements for renewal of licensure.

    I have great respect for ABMP and AMTA, as they provide essential services for the community of massage therapists. However, they are PRIVATE associations, and are different in their basic structure and purpose from state massage boards, which are established by their respective legislatures to protect the PUBLIC interest.

    In the wake of the MOCC Proposal, we are left with a number of hanging questions: 1) Should there be mandatory requirements for continuing education to renew one’s state massage license? 2) If so, should there be a single national-level approval program to assure the quality and relevance of that CE? 3) If so, what is the optimal entity to handle this critical function?

    Here are my responses to these questions:
    1) Given the relatively low number of education hours required for initial entry into the massage therapy field, I believe it is essential to have mandatory CE standards to ensure that therapists build upon their base of theoretical knowledge and practical skills throughout their careers. There is a minority of passionate lifelong learners in our community who would take courses no matter what. The majority of practitioners would not.

    2) The current system of a national CE approval program run by NCBTMB along with 10 individual state-level approval programs is ineffective and wasteful. It also forces CE providers to jump through the hoops of multiple agency processes to be able to teach across state lines, which is an unfair burden. We need a single system.

    3) Looking at the structure of other professions, it seemed to me that FSMTB was the most logical choice to take on the development of a new unified CE approval program. I was part of industry conversations last year that led to FSMTB’s exploration of this specific opportunity. Their formation of a Task Force with reps from ABMP, AMTA and AFMTE seemed like a natural starting point. Since I had absolutely nothing to do with the process that resulted in the recent publication of the MOCC, I don’t know how things got so off track.

    Where to from here? Just yesterday, NCBTMB announced a major (and much-needed) reorganization to their primary certification program, along with an expansion of their CE approval program to review courses as well as providers. Since they have the only national-level approval program at the present time — and are interested in improving it — the other stakeholder organizations should look to NCB for participation.

    It’s time for full cooperation to solve the long-standing problems in our field. This CE project would be a good place to start.

    Rick Rosen, MA. LMBT
    Body Therapy Institute, Siler City, NC

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