Draft Policy on Accepting Digital Credentials for Continuing Education by Licensing Authorities
(DRAFT 19 June 2014 by William G. Beazley)
<This is published as a public service for use by any Licensing Authority considering accepting digital credentials.>
DIGITAL CREDENTIALs, such as digital badges, are a growing format for documenting learning and skills. A Licensing Authority (AUTHORITY) may require continuing education (CE) by their Licensed Professionals (LPs) to renew their license. LP’s may wish to provide DIGITAL CREDENTIALs as attendance verification records with their log as evidence of meeting continuing education requirements. DIGITAL CREDENTIALs are issued by 3rd parties (ISSUER) and frequently displayed by separate 3rd parties (DISPLAYER). This policy explains what data DIGITAL CREDENTIALs must contain and how they are made available to AUTHORITY or their appointed auditor.
The definitions and requirements stated on AUTHORITY website (website, such as http://engineers.texas.gov/CEP_Info.htm) apply in full.
LICENSING AUTHORITY (AUTHORITY) – The organization licensing the LICENSED PROFESSIONAL (LP) and requiring CONTINUING EDUCATION (CE) to retain that license.
AUDITOR – A person designated by AUTHORITY to review the digital credential for acceptability to AUTHORITY.
CONTINUING EDUCATION (CE) – An activity designed to qualify for PDHs as defined by AUTHORITY.
PROFESSIONAL DEVELOPMENT HOUR (PDH) – A credit assigned to an activity according to the statutes and regulations of the AUTHORITY.
COLLECTION – One or more DIGITAL CREDENTIALs being presented to AUTHORITY or their AUDITOR as evidence of compliance. A COLLECTION is not a LOG.
LOG – A LOG is an interpretation of applicability of the DIGITAL CREDENTIAL to the AUTHORITY CE requirements for PDHs.
DIGITAL CREDENTIAL – A link or a secure copy of an electronic record submitted to AUTHORITY as evidence of compliance to Continuing Education requirements
LICENSED PROFESSIONAL (LP) – The registered or licenses professional subject to a CE requirements Audit
ISSUER – The third party organization conducting the CE activity and issuing the DIGITAL CREDENTIAL
DISPLAYER – The third party organization that displays the DIGITAL CREDENTIAL upon request of the AUDITOR.
There is growing interest in offering DIGITAL CREDENTIALs to AUTHORITY in satisfaction of statutorily mandated CE requirements. The purpose of this policy is to provide guidance to LPs, ISSUERs and DISPLAYERs as the format, data content, accessibility and other requirements to be suitable for such evidence. DIGITAL CREDENTIALs are no different than any other attendance verification record in this regard, except that the potential for incomplete, inauthentic or untraceable documentation is much greater. Although DIGITAL CREDENTIALs will not eliminate the need for a LP LOG, it will simplify its preparation by the LP and audit by AUTHORITY.
Responsibility of the LP
It is the sole responsibility of the LP to insure that DIGITAL CREDENTIALs meet the requirements of AUTHORITY. Neither AUTHORITY or any AUDITOR will take any action to solicit clarification, correction or additions to DIGITAL CREDENTIALs that are insufficient evidence of CE. In all cases AUTHORITY is the sole judge as to whether a DIGITAL CREDENTIAL is adequate evidence.
The LP is still required to present a LOG explaining the PDU claimed for each DIGITAL CREDENTIAL. The AUDITOR must be able to verify from the ISSUERs included data elements that the DIGITAL CREDENTIAL qualifies for the PDHs claimed.
Responsibility of the ISSUER
The ISSUER is responsible for authenticating the identity of the LP and verifying the actual attendance, participation or execution of the CE for which they issue the DIGITAL CREDENTIAL. If this is done through electronic means, a written procedure must be available to the AUDITOR upon request on how this means insures authentication and verification of participants in the CE.
The ISSUER must include the following data elements in the DIGITAL CREDENTIAL:
- The name of the person attending the activity,
- Type of activity certified,
- Sponsoring organization,
- Duration/Contact Hours/College Credit, and
- Instructor’s or speaker’s name
- Evidence collected that the named person completing the activity.
The ISSUER must include these data elements in a secure fashion that prevents tampering, alteration or change in any way. The ISSUER must certify that the DIGITAL CREDENTIAL is ONLY issued when the published conditions described in the data elements are met.
Responsibilities of the DISPLAYER
The DISPLAYER of the DIGITAL CREDENTIAL or a COLLECTION of DIGITAL CREDENTIALs must provide unencumbered access to them to AUTHORITY or AUDITOR during the time of audit. No special information or special procedures can be required from AUTHORITY or AUDITOR to gain access to the DIGITAL CREDENTIALs, other than using an internet link and/or login and password supplied by the LP. The DISPLAYER must show the data to AUTHORITY or AUDITOR exactly as encoded by the ISSUER with no possibility of alteration, change or corruption. A written procedure must be available to AUDITOR upon request on how the DISPLAYER insures security of content with traceability to ISSUER.
LP’s cannot display their own DIGITAL CREDENTIALs for audit. LP can create COLLECTIONS of their DIGITAL CREDENTIALs for audit purposes for presentation by the DISPLAYER.
Submission to AUTHORITY for Audit
AUTHORITY can audit the LP’s records for compliance with CE requirements. DIGITAL CREDENTIALs may be submitted as attendance verification record either individually or as a COLLECTION prepared for the Audit. (For example, only selected DIGITAL CREDENTIALs may actually apply to the time period in question. A LOG claiming PDHs for the DIGITAL CREDENTIALs must still be submitted. The log and links to DIGITAL CREDENTIALs or COLLECTION(s) can be submitted by email using the email on file with AUTHORITY.