Policy Advisory Board Policies and Guidelines (Optometry)
Table of Contents
Policy on the use of IPL Devices by Optometrists
The Massachusetts Board of Registration in Optometry voted on August 21, 2019, to adopt the following policy guidelines on the use of IPL devices by licensed optometrists.
The Board of Registration in Optometry hereby recognizes that a licensed, TPA-certified optometrist, with appropriate skill, education and training, may utilize Intense Pulsed Light (“IPL”) devices to treat dry eye disease and ocular surface disease, provided said use complies with the requirements of this policy and any other applicable regulation or law. An Optometrist who provides IPL services must have proof of the optometrist’s completion of appropriate training available on-site for Board inspection and upon request. Appropriate training could be a training program by manufacturer, approved continuing education course, or IPL training in optometric college. An optometrist may use an IPL Devices only in a nonablative and non-invasive manner and for a documented optometric purpose within the scope of the practice of “optometry” as set forth in G.L. c. 112, s. 66. An optometrist utilizing IPL shall be prepared to handle any complications from the treatment. An optometrist may not delegate the use of the IPL to any other person.
Optometrist must ensure the IPL machine they utilize meets all applicable state and federal requirements. The optometrist must retain a copy of the manufacturer’s instructions for the IPL device on-site for Board inspection and upon request. An optometrist shall not use any device, setting or apparatus on any device for any purpose which is outside the scope of optometric practice in Massachusetts. An optometrist may not provide IPL treatment to a patient solely for aesthetic benefit or after the optometric purpose for the treatment has been achieved.
Advertisement of Post-Licensure Certifications Issued By Entities Other than This Board
The Board of Registration in Optometry voted at its regular meeting on May 18, 2011, to adopt the following policy guidelines:
Policy No. : 11-011
Purpose: To provide guidance regarding the advertisement by licensed optometrists of post-licensure certification issued to the optometrist by an entity other than the Board of Registration in Optometry.
Policy: An optometrist who holds a current license to practice optometry in the Commonwealth of Massachusetts may publicize post-licensure certifications issued to that optometrist by entities other than this Board, provided the optometrist does so in compliance with all applicable laws and Board regulations and does not engage in any form of misrepresentation or deceit.
Discussion: The Massachusetts Board of Registration in Optometry ("the Board" or "this Board") has the statutory authority to enforce initial licensure, scope of practice, and renewal requirements for the practice of optometry in the Commonwealth. Numerous private organizations now offer "certification" or "fellowship" status to licensed optometrists who meet specific experience, testing and/or educational requirements. Such post-licensure certifications have no relation to an optometrist's licensure status with this Board and this Board does not endorse, require or support any post-licensure certification process. Each Massachusetts licensed optometrist must continue to comply with all standards of practice and renewal requirements enforced by the Board to retain his or her authority to practice optometry in Massachusetts. See G.L. c. 112, s. 69; 246 CMR 2.00.
Although the Board does not endorse any certification process above the statutory requirements for licensure in Massachusetts, it recognizes that some licensed optometrists have obtained or will be obtaining such certifications. The purpose of this guideline is to clarify that a Massachusetts optometrist may publicize post-licensure certifications issued to that optometrist by entities other than this Board, provided the optometrist does so in compliance with all applicable laws and Board regulations including but not limited to, 246 CMR 3.07, 246 CMR 3.10, 246 CMR 3.11, and does not engage in any form of misrepresentation or deceit.
Board regulations at 246 CMR 3.07 require that an optometrist clearly identify him or herself as an "optometrist" or use the "OD" designation when engaging in the practice of optometry. Designations of post-licensure certifications issued by non-state entities may be listed after the "optometrist" or "OD" designation if the optometrist has completed all necessary steps to receive such certification and currently holds such certification.
Any designation used to describe the attainment of a post-licensure certification must clearly identify the entity issuing the certification. General designations, such as "Board Certified," without further identifying detail regarding the certifying entity, are not permissible because they fail to distinguish between certification of registration issued by this Board, which is the statutory pre-requisite to practicing optometry in the Commonwealth, and certifications issued by a private entity, which documents the successful completion of a voluntary process.
Any optometrist who lists a certification from an entity other than this Board must be able to verify that he or she has received such certification. The optometrist must be able to show continued studies to maintain certification and competency for continued use of the designation, when this is applicable and appropriate. Because it cannot be factually substantiated, at no time should an optometrist advertise that by having such designation that they are "better, superior, or more advanced," or any other superlative, compared to other licensed optometrists in the Commonwealth.
Should the Board or any member of the public have questions or want clarification concerning the listed certification, the optometrist should have available a complete description of the course of study and the agency from which it was obtained, and the optometrist should be able to provide this to the consumer. This may be done in writing or by directing the customer to the appropriate website. All optometrists are reminded that Board regulations prohibit false, misleading or deceptive advertising and the use of any designation that confuses the nature of the optometrist's practice. See 246 CMR 3.10; 246 CMR 3.11.
Advertisement of Optometry Services
The Board of Registration in Optometry voted on March 16, 2011 to issue the following guideline.
Policy No. : 11-010
Purpose: To provide guidance to optometrists, non-optometrists and public regarding the advertisements of optometric services in Massachusetts.
Policy : Reminder that all advertisements for optometric services shall include the name or names of the licensed optometrist providing services at the advertised location.
It has come to the attention of the Massachusetts Board of Registration in Optometry ("the Board") that some paper and web-based advertising companies are listing individuals and/or businesses under the heading "optometrist" who are not licensed to practice optometry within Massachusetts. Please be advised that Massachusetts General Law, Chapter 112, Sections 66 to 72A, prohibits anyone who does not possess a current Massachusetts optometry license from practicing or offering to practice optometry in the Commonwealth.  In addition, Section 72 of Chapter 112 requires that if optometric services are advertised under a trade or service name, the names of the optometrist(s) providing the advertised services must be "prominently displayed . . . in all print advertisements that identify the location or locations where optometric services are provided." See G.L. c. 112, § 72.
In light of the above law, all advertisements for optometric services shall include the name or names of the licensed optometrist providing services at the advertised location. Inclusion of non-licensed individuals under the heading "optometrist" is misleading to the public because the public could construe that the individuals listed under such heading are licensed optometrists. Furthermore, inclusion of the names of unlicensed individuals or businesses without a licensed optometrist under the heading "optometrist" could expose such individuals and business to allegations that they are engaged in the unlicensed practice of optometry.
Review and Approval Standards For Continuing Education Courses and Programs
The Board of Registration in Optometry voted at its regular meeting on June 18, 2014, to adopt the following policy guidelines:
Policy No.: 14-001
Purpose: To establish uniform criteria for reviewing and approving continuing education courses and programs to ensure that the education is under responsible sponsorship, capable direction, and qualified speakers. The criteria established are the minimum requirements and are meant to be consistent with the intent of the Council on Optometric Practitioner Education (COPE) standards to establish continuity for all providers. This document outlines, at a minimum, the information that must be submitted to receive Board approval to conduct courses and programs acceptable for awarding continuing education credits for optometrist registration renewal requirements.
The following are the Board guidelines for review and approval of continuing education courses and programs:
- Course Information to be supplied by the Course or Program Sponsor
- The date the application for approval is submitted. A minimum of sixty (60) days must be allowed for the review process as required under 246 CMR 2.01(4)(d)(1)(a).
- The name of the Sponsor and his or her address, phone/fax numbers and email address so that the Board may contact the Sponsor with questions concerning the application. Notification of action on the application will be sent to the Sponsor.
- The time and location of the course.
- Provisions for adequate monitoring of attendance, and satisfactory assurances that the course is generally available to all Optometrists.
- The name and curriculum vitae of any speakers who participate in the presentation of the course, including any co-speakers. A co-speaker is any individual who, in conjunction with a primary speaker, assists and participates in the presentation of a course, but also has the necessary qualifications to give the course independently of the primary speaker should the primary speaker be unavailable. Sponsors must file for independent Board approval for a course that may be, or is desired to be, presented separately by both the primary and co-speaker.
- The names and curriculum vitae of any adjunct/assistant speakers who participate in the presentation of the course. An adjunct speaker is an individual whose main function is to support the primary speaker with the presentation or preparation of a course. An adjunct speaker may or may not be present to assist with the presentation of a course, however, an adjunct speaker is not approved, under any circumstance, to present a course in place, or in the absence of, the primary speaker.
- The title, adequately describing the course, as it will appear in all future programs.
- The total continuing education hours of the course. To be qualified, a course must have at least 1 continuing education hour but not be more than four hours in length. One continuing education hour is equivalent to a minimum of 50 minutes of instructional time; two continuing education hours are equivalent to a minimum of 1 hour and 40 minutes of instructional time.
- Course Description to be supplied by the Course or Program Sponsor
A brief course description, in addition to the detailed outline required under 246 CMR 2.01(4)(d)(1)(c)(ii), that summarizes in 35 words or less what the speaker(s) intends to present. Such description must be suitable for publishing.
- Disclosure of Financial / Proprietary Interests
The sponsor must disclose on the application any direct financial or proprietary interests he or she may have in any of the companies, products, pharmaceuticals or services intended to be mentioned in the presentation. The Board will assess whether such an interest inappropriately influences the course material.
Examples of the influence of proprietary interests include but are not limited to: (1) the absence of unbiased evidence equally assessing similar products or services; (2) the exclusion of other products or services that might reasonably be expected to produce equivalent or similar results; or (3) the inference of the superiority of the proprietary product or service over others.
The sponsor must also disclose if he or she has provided for-profit support of any kind, are a paid consultant to, an employee of, or serve as an officer on the board of companies mentioned in their presentation. Sponsors must certify on their applications that this information will be disclosed at the beginning of the presentation to the audience in a clear and unambiguous manner, verbally and in writing in the course outline.
- Course Categories to be supplied by the Course or Program Sponsor
While a course or program may pertain to several course categories, there is usually one major topic which will cover most of the time and discussion and which will best match one of the categories. The speaker should identify one of the following categories which best describes the educational experience provided by the course or program:
- Clinical Optometry
- Ocular Disease
- Related Systemic Disease
- Optometric Business Management
- Course Presentation to be supplied by the Course or Program Sponsor
The sponsor must disclose how the course material will be presented. Courses may be presented by more than one method but must be conducted in person within the state of Massachusetts. Indicate the amount of time that will be allotted for each method during the course. The time allotments for all methods should total the entire number of hours in the course.
Discussion: The Massachusetts Board of Registration in Optometry (Board) approves continuing education courses and programs pursuant to Board regulations promulgated at 246 CMR 2.01(4). Continuing education courses and programs are automatically approved by the Board in two instances: (1) the course or program is offered by a continuing education entity approved by the Board under 246 CMR 2.01(4)(e); or (2) the course or program has received COPE approval. The standards of review outlined in this policy are applicable only to courses and programs that are not eligible for automatic approval and therefore require independent Board review. The purpose of this policy is to follow, to the extent permitted by Board regulations, standards of review that are uniform with the COPE standards to establish sound measures for continuing education course evaluation and consistency for all providers.
Avoidance of Potential Insurance Fraud
It has come to the attention of the Massachusetts Board of Registration in Optometry that some practitioners have considered signing, or have in fact signed, examination records of another optometrist in their practice (as if they themselves had performed the examination) . The Board has further been informed that often, when this happens, an insurer is billed for the examination even if the optometrist who performed the examination is not a provider under that insurer. The Board recently was asked whether an optometrist may sign the examination records of another optometrist.
- The Board wishes to remind all licensed optometrists that all patient records, and any associated billing, should clearly identify the person who actually performed the examination wherever such identity is required. Misrepresenting who actually performed the examination is prohibited. Indeed, to bill an insurer, by portraying an examination as having been performed by someone else, is likely fraudulent and, may constitute grounds for discipline under 246 CMR 3.16(c) and 16(n). A licensed optometrist who knowingly allows another optometrist to misrepresent who performed optometry services may also be subject to disciplinary action by the Board.
- Board regulation 246 CMR 3.14 provides that "an Optometrist shall be responsible for all Optometry services provided to persons being served by him or her, or by any of his or her agents or employees." The Board recognizes that a credentialed Optometrist can serve in a supervisory role to another O.D. or Optometry student, and can also use an Optometric technician to gather data to be used by the Optometrist to complete an examination. In this instance the supervising Optometrist would need to be present in the offices during any of these encounters.
Clarification of Reciprocity Requirements
The Board may grant a license via reciprocity under the following conditions:
- The applicant provides documentation of a current, unrestricted license from another state.
- That license was issued after an examination and has been in good standing for at least 3 years.
- In the opinion of the Board, the requirements for licensure (at the time the license was granted) were equivalent to those in the Commonwealth.
- The applicant provides documentation that the other state accords a similar privilege to Commonwealth-licensed optometrists.
Inter-pupillary Distance on Prescriptions
The Board requires that - upon patient request - the inter-pupillary distance be entered on any prescription. No additional fee may be charged for providing the binocular PD.
Obtaining Certification for the Use of Therapeutic Pharmaceutical Agents (TPA License)
- Optometrists who have received degrees from an accredited program after January 1, 1994, shall automatically receive TPA certification.
- Optometrists seeking TPA certification whose degree was awarded prior to January 1, 1994, should first consult the Board's regulation (i.e., 246 CMR 2.03), then review the application materials. Contact the Board if questions remain.
Regarding Applicants with Criminal Convictions or Pending Criminal Charges
Contact Lens Prescription Release
Since the methods of procurement of contact lenses have changed in recent years, the Board of Registration in Optometry has decided to comment on the guidelines for the release of contact lens prescriptions.
The current rules and regulations concerning Contact Lens Prescription-Content [246 CMR 3.02 (6)(c)] state the following:
A "prescription for contact lenses" shall not be considered complete until such time as the optometrist caring for the patient in question, in the reasonable exercise of his or her sound professional judgement, determines that the power, fit and other characteristics of the lenses are properly tailored to the documented clinical needs of the patient.
In many cases, it can take from 15 to 60 days or more to know if the contact lenses are properly tailored to the documented clinical needs of the patient. Since several appointments might be necessary to observe and modify contact lenses, we feel that the doctor must have access to any lens materials used, so that the final written prescription given to the patient meets the requirements above. This may involve the doctor having arrangements with contact lens manufacturers to get trial lenses that can be fit and modified prior to finalizing the prescription. The fitting of contact lens materials that do not fall within these parameters may need to be limited by the practitioner.
Following these guidelines will ensure that the Optometrist has evaluated the contact lenses on the patient's eyes prior to writing the final prescription.
Handling Consumer Complaints Involving Independent Optometrists Working with Independent Opticians
- The Board believes that a patient's complaints should ensure that a reasonably thorough inquiry is made into the facts and circumstances.
- The Board further feels that patients should be confident that their concerns will be taken seriously and dealt with in an objective fashion.
- When a patient brings a concern to the Optician who dispensed his prescription, that optician should attempt to resolve the patient's concerns by checking the prescription, making the necessary adjustments, and explaining the proper use of the prescription to the patient.
- When this method fails to solve the patient's problems, the patient should be referred back to the prescribing Optometrist, who should perform the necessary diagnostic procedures to determine the cause of the problem.
- The Board suggests that an RX Check form be developed by the Optometrist and Optician and used to track the progress of all complaints.
- The use of systematic tracking will avoid unnecessary complaints against Optometrists by consumers who feel both their Optometrists and Opticians are unresponsive to their individual needs.
- Attached is a sample Rx Check form that you may want to modify to better suit your exact practice needs.
Continuing Education Guidelines
Board regulations require that an optometrist must complete 18 hours of Board-approved continuing education as a condition of annual license renewal. Credit toward renewal of an Optometrist's License in a particular renewal period shall be given only for Continuing Education Hours which were completed during the 12 months immediately preceding January 1st of the licensure year for which renewal of that License is sought. Newly-graduated licensees are waived from this requirement for the remainder of year in which they graduate. Individuals with hardship situations should contact the Board before renewing their license.
All licensees are required to comply with Board audits of continuing education. Failure to comply with the Board's instructions or failure to complete the requisite education shall be grounds for disciplinary action. The Board strongly encourages licensees to retain continuing education records permanently; however, for the purposes of audits, the Board will review records for no more than 3 years.
For a continuing education program to be acceptable for the purposes of license renewal, the following conditions apply:
- "Live" continuing education (CE) programs offered outside of Massachusetts must be approved by the Council on Optometric Continuing Education (C.O.P.E.)
- "Live" CE programs offered within Massachusetts and that exceed four (4) hours must be C.O.P.E. approved or offered by a Board-approved entity.
1. The Board approved entities are:
- New England College of Optometry (expires on December 31, 2022)
- Harvard Medical School (expires on December 31, 2022)
- "Live" CE courses or programs that are four (4) hours or less, and that are not C.O.P.E. approved may be submitted to the Board for approval (To view approved courses, see the On-Line Lookup System: Continuing Education Courses Approved for (CE) credit in Massachusetts)
- A written application for Board approval must be submitted at least 60 days prior to the course date
- The application must include the name of the sponsor; a detailed outline of the course material; the speaker's curriculum vitae; the course time and location; provisions for adequate monitoring of attendance; and satisfactory assurances that the course is generally available to all optometrists
Prescription of Latisse by Optometrists
The Board of Registration in Optometry voted on March 16, 2011, to adopt the following policy guidelines on the prescription of Latisse by licensed optometrists with TPA prescriptive authority.
Policy No. : 11-009
Purpose: To provide guidance to TPA-certified optometrists who seek to utilize Latisse in their optometric practice.
Policy: It is within the scope of practice of a TPA-certified optometrist to prescribe Latisse, provided that it is properly prescribed as a "therapeutic pharmaceutical agent" as defined in G.L. c. 112, s. 66B. Prescription of Latisse for cosmetic reasons or for the treatment of glaucoma is prohibited.
Discussion: Recently, the Board has been asked whether the prescription of Latisse is within the scope of practice of a TPA-certified Massachusetts optometrist. General Laws, Chapter 112, section 66B provides that:
"Any registered optometrist, qualified by examination for practice under the provisions of section 68 subsequent to January 1, 1994, duly certified in accordance with the provisions of section 68B and duly registered to issue written prescriptions in accordance with the provisions of paragraph (h) of section 7 of chapter 94C may, for the purpose of preventing, correcting, managing or treating ocular diseases or abnormalities, utilize and prescribe therapeutic pharmaceutical agents; provided, however, that nothing in this section shall be construed to permit optometric use of therapeutic pharmaceutical agents which are: (a) controlled substances as described by Title 21 U.S.C. Section 812 or in chapter 94C, except for those listed in schedule VI; (b) pharmaceutical agents administered by subdermal injection, intramuscular injection, intravenous injection, subcutaneous injection or retrobulbar injection; (c) pharmaceutical agents for the specific treatment of systemic disease; and (d) invasive surgical procedures."
G.L. c. 112, s. 66B (emphasis supplied).
The statute goes on to define "therapeutic pharmaceutical agents" as "those topical pharmaceutical agents in schedule VI required for the diagnosis, prevention, management or treatment of abnormal ocular conditions or diseases as defined in section 66, except glaucoma."
Latisse is a bimatoprost opthalmic solution 0.03% manufactured by Allergan, Inc. Information concerning the U.S. Food and Drug Administration's ("FDA") approval of Latisse can be found at the FDA's website at www.fda.gov. In Massachusetts, Latisse falls within the list of scheduled VI controlled substances. As such, pursuant to the above-cited statute, Latisse may be prescribed by TPA-certified optometrists if it is required for the "diagnosis, prevention, management or treatment of abnormal ocular conditions or diseases as defined in section 66, except glaucoma." No Massachusetts optometrist may prescribe Latisse for purely cosmetic reasons or for the treatment of glaucoma.
POLICY/NOTICE: Topical and Oral Therapeutic Pharmaceutical Agents and Glaucoma Certification (TPA+GC)
RE: POLICY/NOTICE: Topical and Oral Therapeutic Pharmaceutical Agents and Glaucoma Certification (TPA+GC)
In response to the expanded scope of practice for optometrists licensed in Massachusetts, the
Board of Registration for Optometry (“Board”) issues the following policy/notice:
(1) Topical and Oral Therapeutic Pharmaceutical Agents and Glaucoma Certification (TPA+GC):
Pursuant to M.G.L. c. 112, § 66C (a), A registered optometrist who is qualified by an examination
for practice under section 68, certified under section 68C, and registered to issue written
prescriptions pursuant to subsection (h) of section 7 of chapter 94C may:
(i) use and prescribe topical and oral therapeutic pharmaceutical agents as defined in section
66B that are used in the practice of optometry, including those placed in schedules III, IV, V and
VI pursuant to section 2 of said chapter 94C, for the purpose of diagnosing, preventing,
correcting, managing or treating glaucoma and other ocular abnormalities of the human eye and
adjacent tissue; and
(ii) prescribe all necessary eye-related medications, including oral anti- infective
medications; provided, however, that a registered optometrist shall not use or prescribe: (A)
therapeutic pharmaceutical agents for the treatment of systemic diseases; (B) invasive surgical
procedures; (C) pharmaceutical agents administered by subdermal injection, intramuscular injection,
intravenous injection, subcutaneous injection, intraocular injection or retrobulbar injection; or
(D) an opioid substance or drug product.
(2) Methods of Obtaining Certification:
Licensed Massachusetts Optometrists seeking certification, shall submit to the Board evidence of
the completion of the education and examination requirement under M.G.L.
c. 112, § 68C(b), as satisfactory evidence of this section.
New Applicants for licensure (initial licensure) shall fall under M.G.L. c. 112, § 68C(a). The
Board will accept proof of graduation from an accredited school or college of optometry and
completion of the national board examination requirements, as satisfactory
evidence of this section.
(3) Postgraduate Residency Program:
Pursuant to M.G.L. c. 112, § 68C, A licensed optometrist who has completed a postgraduate residency
program approved by the Accreditation Council on Optometric Education (ACOE) of the American
Optometric Association may submit an affidavit to the board of registration in optometry from the
licensed optometrist’s residency supervisor or the director of residencies at the affiliated
college of optometry attesting that the optometrist has completed an equivalent level of
instruction and supervision, and the board may accept the evidence in order to satisfy any of the
requirements of Section 68C. The Board will accept a completion certificate as satisfactory
evidence of the requirements under Section 68C, if the licensee:
1) completed the postgraduate residency program in ocular disease; and,
2) completed the program on or after June 30, 2011.
Those completing the residency program before June 30, 2011, or did not complete the residency
program in ocular disease, will be reviewed on a case-by-case basis by the Board.
Applicants seeking licensure through endorsement shall fall under 246 CMR 2.01(2)(b). Additionally,
pursuant to M.G.L. c 112, § 68C(c), an optometrist licensed in another jurisdiction to utilize and
prescribe therapeutic pharmaceutical agents for treating glaucoma and other ocular abnormalities of
the human eye and adjacent tissue may submit evidence to the Board of Registration in Optometry of
equivalent didactic and supervised clinical education, and the Board may accept the evidence in
order to satisfy any of the requirements of this section. The Board may accept a letter of good
standing from an optometrist licensed in another jurisdiction with an equivalent scope of practice
in both glaucoma and oral therapeutic agents to those of the Commonwealth, and the licensee must
show that they contain such licensing authority in that jurisdiction.
Licensees with a Massachusetts license and another U.S. jurisdiction may qualify for certification
under a dual licensure. The Board will review these applications on a case- by-case basis. The
Massachusetts licensee must have the following:
1. current and continuous licensure in another U.S. jurisdiction; and,
2. could demonstrate a substantially equivalent scope of practice in that jurisdiction
(5) Continuing Education:
Pursuant to M.G.L. c. 112, § 68C(e), licensees under this section whose expiration dates from
January 31, 2022, and forward, must complete three hours of continuing education, which must be
specific to glaucoma diagnosis, management or treatment. The three hours are inclusive of the 18
hours of continuing education requirement, pursuant to 246 CMR 2.01(3). The course must be an
approved Council on Optometric Practitioner Education (C.O.P.E.) continuing education course,
specifically approved by the Board under 246 CMR 2.01(3)(d), or offered by a continuing education
entity under 246 CMR 2.01(3)(e).
(6) Mandatory Referral of Patients to Physicians or Other Qualified Providers:
(a) Pursuant to M.G.L. c. 112, § 66C, if, while examining or treating a patient with the aid of a
diagnostic or therapeutic pharmaceutical agent and exercising professional
judgment and the degree of expertise, care and knowledge ordinarily possessed and
exercised by optometrists under like circumstances, encounters a sign of a previously unevaluated
disease that would require treatment not included in the scope of the practice of optometry, the
optometrist shall refer the patient to a licensed physician or other qualified health care
(b) If an optometrist diagnoses a patient with congenital glaucoma or if, during the course of
examining, managing or treating a patient with glaucoma, the optometrist
determines that surgical treatment is indicated, the optometrist
Click here to view a PDF copy of this policy.
Interpretation of Continuing Education Requirements for Massachusetts Optometrists
Interpretation of Continuing Education Requirements for Massachusetts Optometrists
December 15, 2021
Pursuant to 246 CMR 2.01(3)(a)(2), "[n]o more than six Continuing Education Hours per renewal period will be credited for distance based learning Continuing Education Courses."
It is the interpretation of the Board that for purposes of 246 CMR, "distance based" means a separation between an instructor and student, this separation being physical AND temporal (aka time). Accordingly, a "distance based learning Continuing Education Course" is an online or correspondence course in which students receive instruction in an asynchronous manner, such as by reading content, observing pre-recorded presentations, or otherwise interacting with ondemand multimedia. Conversely, a course that utilizes a live interaction between an instructor and students, even if the instructor and students are not physically in the same location, is NOT "distance based" for purposes of 246 CMR. Such courses are thus not subject to the limitations of 246 CMR 2.01(3)(a)(2). The Board notes that this requirement does not prohibit an otherwise "live" continuing education class from utilizing videos or other multimedia presentations as part of the course so long as the majority of the class is a real-time collaboration between instructor and students.