The email read like a marketing pitch that Dr. Lance Roasa normally would readily delete, but the sender caught his eye.
It was a company that had just assumed an influential job working with providers of continuing education for veterinarians.
The company, CE Broker, was contracted to streamline and centralize the system through which continuing education courses for veterinarians and veterinary technicians in the United States and Canada are approved, completed and tracked.
One of several solicitations that Roasa's education business, drip.vet, received from CE Broker touted a program called CEB Now+ that would give participating providers "premium positioning for courses" being considered by a "captive audience" of veterinary licensees, in return for a 60% cut of the providers' revenues.
Roasa, a veterinarian and lawyer, saw it as a classic "pay-to-play" offer. "Whoever pays the most gets your listings higher," he said.
CE Broker's apparently conflicting interests in providing a technology platform to be used by veterinary licensees, CE providers and regulators, at the same time that it offered to promote courses that profit itself, has raised concerns about the company's role in a system that touches most veterinary professionals in the U.S. and Canada. The company, without explicitly referencing the concerns, told the VIN News Service today that it is "making some adjustments to our offerings."
Another issue identified by multiple providers interviewed by VIN News is that they are now expected to enter program attendees' license numbers and jurisdictions in the centralized system — a sharing of information that violates some providers' privacy policies.
"We have thousands and thousands of veterinarian and veterinary students that we've taught to, and we take data security and privacy very seriously," Roasa said.
At the center of the controversy is the Registry of Approved Continuing Education. Commonly known as RACE, it is operated by the American Association of Veterinary State Boards, a nonprofit organization representing veterinary regulators in state, district, territorial and provincial governments in the U.S. and Canada.
As is customary in the licensed professions, veterinarians and veterinary technicians are expected to periodically complete a number of hours of continuing education. Each jurisdiction sets its own requirements, but 61 recognize courses that are "RACE-approved" by the AAVSB.
In October, the AAVSB brought in CE Broker Inc., a business in Jacksonville, Florida, to provide and run the technology underlying the application process for RACE educators and course tracking for licensees.
Janis Knoetzel, education director at the Viticus Group, which provides CE online and at the Western Veterinary Conference, sees it this way: "The state has given away its control to AAVSB, and now it seems that the organization has given away a great deal of control to CE Broker."
'We want to make sure that our RACE providers ... are happy'
James Penrod, AAVSB executive director, said in an interview that the organization contracted with CE Broker because of the company's relatively long experience in doing similar work for other professions. Florida state records show CE Broker was incorporated in 2003. Today, CE Broker works with 110 state boards in the U.S., keeping track of continuing education records for more than 2.7 million licensees, according to the company.
Penrod said AAVSB has long been interested in providing an online system by which veterinarians and veterinary technicians can record and track their completed CE, and that regulatory agencies can access to quickly confirm that licensees are participating in ongoing education as required. The old-school way has been for states to request from licensees copies of their certificates of course completion.
The AAVSB also wanted to provide a more efficient way for CE providers to submit their materials for approval or renewal, Penrod said.
In 2014, the AAVSB deployed an in-house system called VCET — for Veterinary Continuing Education Tracking — but it wasn't easy to use, Penrod said, "so we were looking around for a vendor system that can do it better."
CE Broker stood out amid its limited competition. "There's not too many others" in the field, Penrod said. "We found a couple, but they didn't have the reach or the time into it."
Under the agreement between AAVSB and CE Broker, Penrod said AAVSB retains ownership of user data, and no money changes hands. "We don't pay for the services from them, and we don't receive revenue back," he said. (Asked for a copy of the contract, Penrod said he could not provide it without first consulting with CE Broker and AAVSB's lawyer.) The new system in place is called RACEtrack.
As the AAVSB understood it, Penrod said, CE Broker would make money by selling premium tracking services to licensees, priced at $29 or $99 per year, depending on the number and type of services. With the more expensive "concierge" service, for example, "we help you find the best CE/CME courses," among other perks, according to the company website.
The marketing options for CE providers were created by the company after AAVSB engaged its services, Penrod said, "something we were not involved in at all. That's an additional way they are looking to achieve revenue."
Penrod said he's heard concerns about it from some course providers, leading him to schedule a "town hall" gathering to enable providers to fully air their concerns and questions, which he intends to address. The meeting is tomorrow.
"Our RACE providers — our program — is considered the gold standard for quality continuing education, and we want to make sure that we do whatever we can to make sure our RACE providers are happy with the products we have and the process we have to make sure their CE is approved by regulatory boards," Penrod said.
"So we will do whatever we need to do to make sure we've heard their concerns; that we've addressed their concerns. If it means changing contract provisions, if it means canceling the contract, we'll do all those things to make sure we maintain the standard for the RACE program. It's really important for us."
A statement from CE Broker provided to VIN News by email today reads in part: "CE Broker's revenue model is the same for the AAVSB as any other client. We provide our services at no cost, and rely on optional subscriptions from licensees and optional program revenue from educational providers. We don't sell any data or provide our own course content."
About the educator marketing programs, the statement says:
"It's important to note that participation in optional provider programs is not at all required in order to list courses on the course search. The course search uses an algorithm to sort results in an order that we think best reflects what courses licensees are looking for. Provider participation in paid programs is not a factor."
Asked how that squares with information in its marketing materials, such as a flyer received by a provider that cites "premium positioning for courses in our course search" as a benefit of one of its programs, Justin Mann, chief operating officer of CE Broker, replied by email:
"The information contained in that flyer is no longer accurate. We have been making some adjustments to our offerings. Participation in premium provider programs will not impact course rankings on the RACEtrack course search."
Asked how CE Broker might still derive revenues from education providers, Mann replied further: "The only revenue generated by educational providers is associated with hosting their courses within RACEtrack. We collect a transaction fee in order to support our hosting service, customer service costs, and all other costs of the platform. There is no fee associated with listing courses."
'It just doesn't seem worth it'
Speaking of conflict of interest ...
Some providers have been so dismayed by the new system that they're losing interest in pursuing RACE approval; at least one has already skipped submitting some courses.
Dr. Andy Roark, who offers CE through Uncharted Veterinary Conference and drandyroark.com, has three chief concerns. First, he's worried about protecting licensees' privacy.
"I get so mad when people sell my [information] and then I start getting spam email from people selling me stuff," he said. "... Just at a personal level, we set out to treat people the way we want to be treated, and I just don't want to take these people's information and give it to someone whose stated mission is to sell them stuff."
Secondly, "their business model seems to be predicated on unfair business practices," Roark said, referring to the apparent pay-to-play offers made before CE Broker said it had eliminated paid promotional offerings in RACEtrack.
Third, Roark has found the workload involved in participating in the system to be prohibitive. "It's so burdensome and unwieldy; it's not worth doing. We have not applied for any CE this year because it's a whole issue of collecting information, getting license numbers and submitting them," he said. "We do some on-demand CE, and it's just like, you have to have a person who watches that and goes and takes that information [from participants] and upload it. We're just not set up for that."
Because the type of training he provides is centered on business and leadership training, RACE approval is more of a perk than a necessity, which makes it easier to forgo, Roark explained. "We're not there pushing the medicine that people need for their license."
Dr. Sheri Berger, CEO of PetsVetSpace LLC, which produces CE at vetvine.com, is in a similar position. "There's so much CE out there now that I would say a small percentage of our members who subscribe and participate do so for CE credit," she said. "More do it just for [the] information."
A course provider for more than 10 years, Berger said she's become increasingly disenchanted with RACE in the past three years. "It's become more expensive [to apply for approval and renewal], more obtrusive, and now there's more hurdles and it just doesn't seem worth it," she said.
Berger reported having trouble simply trying to register on the new system, and then could not obtain timely support from CE Broker. In her frustration, she contacted an AAVSB staff member and "I basically said, 'You're about to lose a customer.' "
Meanwhile, she's receiving messages asking her to promote the system.
"One of the emails I got was, 'Please ask your participants to create an account in CE Broker for tracking their CE.' It's ridiculous. Why would I bother people to go do that?" she said, noting that most states are not, to date, using the system to track licensees' CE completion.
Laura Shively, manager of online learning programs at the American Animal Hospital Association, similarly observed that on top of being asked to change how and what they submit in the way of course information, providers seem to be expected to shoulder the job of spreading the word to licensees.
"I understand from a learner perspective why it would be nice to have those CE records autoloaded for their tracking," she said. "But ... a big problem is that they would need to communicate to the learners to do that, [and] the onus falls to the providers."
Like Berger, Knoetzel at the Viticus Group reported technical difficulties with the system.
Beyond that, she is wary of the involvement of a for-profit company. "The agreement [to engage in CE] is between the licensee and the state; it is not with this third party. Where is their responsibility and liability?" she asked.
"The part I'm uncomfortable about is, I am giving them information on my speaker panel. What is to prevent them from taking this information and doing something else with it?" Knoetzel continued. " ... It's a competitive world out there for all education providers and conferences. It makes me uncomfortable to know that they, in essence, are building this database that I don't know what their end use can be. I can only imagine. And I have a pretty vivid imagination!"
Dr. Justine Lee, a veterinary emergency and critical care specialist who proffers CE through VETgirl, said messages from CE Broker to buy better positioning or partner to sell courses "raised red flags."
"We straight up said we weren't interested," Lee recounted.
She is less troubled by other aspects of the change in the system. Technical stumbles and the complaints they've generated aren't surprising, Lee said: "We in the veterinary profession know we are very slow to adapt to change, so any transition sort of rocks our world."
Lee said she understands why AAVSB would want to outsource the logistics of managing the many providers. (According to Penrod, there are 1,000 providers of veterinary CE.) Lee also said she's found CE Broker's customer service to be good, although she has some unaddressed questions about the logistics of handling certain information.
As for the privacy implications in being asked to share attendee information, Lee said she had strong concerns about it initially, but when she learned that the requested data was limited to license numbers and states, she felt better.
Attendee data request deferred to 2022
Asked how AAVSB will respond to CE providers who choose not to share attendee information, Penrod said the organization has decided to delay the requirement until January 2022 in order to iron out the concerns and give providers time to adjust their privacy policies and sort out the logistics of collecting and uploading the data.
Ultimately, Penrod anticipates states requiring such information be provided as a condition of course approval. "We have seen this trend, with state boards moving in this direction," he said, pointing to South Carolina as an example.
The South Carolina Department of Labor, Licensing and Regulation confirmed that its state Board of Veterinary Medical Examiners began using CE Broker in 2017 to "allow LLR to better ensure compliance with" statutory requirements for CE. In an emailed answer to questions from VIN News, the department communications director and ombudsman, Lesia Shannon Kudelka, noted that other boards in the state whose licensees are required to complete CE also use or are in the process of implementing CE Broker, or use other auditing systems.
Kudelka said: "CE Broker provides the service free of charge to the state, licensees and providers. Licensees have the option to pay for an upgraded service with additional features."
Penrod predicted that South Carolina won't be alone among regulatory jurisdictions in adopting a centralized CE auditing system. "There are definitely others working toward it," he said. He anticipates that course attendee information from providers will be required by those jurisdictions. "If the providers are unable to meet that, then they're unable to meet the requirements," he said.
In South Carolina, however, Kudelka said educators are not required to use that state's CE Broker platform (which is distinct from RACEtrack), although they may "join CE Broker for free" and "have the option to pay for better placement in course searches."