How Accreditation and Course Approval Could Be Much Better

Approval and Accreditation of Courses and Certifications Could Be MUCH Better!

by Dr. Brent Brookbush DPT, PT, MS, CPT, HMS, IMT

Updated October 2026.

Quick Answer

Accreditation and approval of continuing education and certification programs are far less developed than college and university accreditation programs, and processes borrowed from higher education don’t fit well with professional continuing education. The result is a system that costs educators far more in administrative burden than in fees, rejects good applications for subjective reasons, adjudicates applications unreliably, and has never tested whether its own requirements are valid (reliably discriminate between good and bad educators or improve the average quality of professional education). This article is a plea for accreditors and educators to work together, and it offers specific recommendations drawn from years of earning more than 20 approvals, including admit fallibility, reduce administrative burden, improve reviewer reliability, lower the financial burden with institutional review and random audits, and stop assuming that application items are valid before testing them.

What Is Accreditation?

What is accreditation? This question is likely best answered by describing the function of an accreditation program. Accreditation programs play an important role in setting standards for various educational institutions. This includes institutions like an accredited continuing education program, or an accredited program for certification, an accredited school, or an accredited higher education program like a college or university.

This article could likely be summarized as a plea to develop symbiotic relationships between a national accrediting agency or accrediting body and the education programs they intend to review. The hypothesis of this article is that this symbiotic relationship is the best path forward to ensure the highest standards of educational quality and the best student outcomes.

One issue that needs additional attention is the uneven allocation of resources toward accreditation for higher education (e.g., colleges and universities), and the relatively small amount of resources spent on the accreditation process for adult learning opportunities, continuing professional education, and certification programs (including specialized certifications). Several accrediting agencies have developed programmatic accreditation processes for continuing education and certification providers; however, these processes are relatively immature when compared to college/university accreditation. Or, accreditation processes are adopted from colleges/universities without the necessary modifications to develop an accrediting body with specific accreditation standards to match the unique challenges faced by a continuing education program and certification body. In summary, approval and accreditation of continuing education courses and certification providers have started to develop, but it could be much better.

Definitions

Accreditor refers to both accreditor and approver throughout this article.

Accreditation versus Approval: Throughout this article, we will use the words “accreditor” and “accreditation” to refer to organizations that award “accreditation” and to organizations that award “approval.” Although these terms would seem to imply different processes, the distinction is not clear when used by different organizations throughout the industry. For example, you may assume that NCCA accreditation is a higher standard than a state physical therapy board’s course approval, but that is not true. NCCA accreditation signifies that a certification program’s exam was developed and administered in a way that aligns with the NCCA’s standards, and a state board’s course approval may follow a review of lesson plans, content, references, and assessments. Alternatively, some organizations offer course approval with almost no quality assurance, and other organizations award accreditation following a thorough review of instructional design. In short, both terms imply review, and the distinctions between the terms are inconsistent. For the sake of readability, the words “accreditor” and “accreditation” will be substituted for both terms throughout the remainder of this article. For what the fitness industry means when the word is applied to a personal trainer certification, see What Is an Accredited Personal Trainer Certification?

“The best path forward is for educators and accreditors to work together to optimize processes that ensure minimum quality standards. If accreditors make regulations unnecessarily restrictive, complex, expensive, etc., they may cause the failure of great education companies. And, if education companies try to dismantle accreditors, they will be left fighting off low-cost, low-quality course creators, in a race to the bottom of quality and price.”

Why Should You Trust Us?

We have a vested interest in accreditation processes. We are an education company serving various movement professions (personal trainers, fitness instructors, physical therapists, athletic trainers, massage therapists, chiropractors, occupational therapists, etc.) in multiple countries. We started this company with the belief that our colleagues deserved higher-quality education, and those improvements could be evidence-directed and objectively measured. We believe that approval and accreditation are currently the best option to ensure that “quality” remains a determining factor in the success of education companies.

It could be asserted that as an education company we are biased, but several factors reduce the potential influence of this bias. Although it may appear that we would benefit from more lenient or fewer accreditors, those accreditors create barriers to entering the education space that reduce noise and competition from low-quality course creators (which aids in reducing marketing costs). The massive number of “gurus” on Instagram and TikTok peddling one-off courses on “their” training method or “unique” treatment methods is a great example of education without accreditation. It should also be mentioned that accreditation is exceedingly complicated (in many cases, unnecessarily complicated). It is hard to imagine any company that did not have a vested interest in education developing the knowledge that went into the creation of this article. In short, it is our current belief that the best path forward is for educators and accreditors to work together to optimize processes that ensure minimum quality standards. If accreditors make regulations unnecessarily restrictive, complex, expensive, etc., they may cause the failure of great education companies. And, if education companies try to dismantle accreditors, they will be left fighting off low-cost, low-quality course creators, in a race to the bottom of quality and price.

Most importantly, this article does not simply discuss what is “good” for the Brookbush Institute. Because we provide approved courses and certifications to so many different professions (in multiple countries), we have acquired more than 20 approvals, and our Certified Personal Trainer (CPT) Certification examination is accredited by the National Commission for Certifying Agencies (NCCA). The full list of continuing education credits we offer, by profession and country, is in our approvals directory. What this article suggests is several “earned insights” from years of developing courses and earning those approvals, and the best practices used by various accreditors to handle “sticky” problems inherent in the accreditation process.

How Accreditation Could Be Better: Summary of Recommendations

Accreditors Must Want to Improve

• Admit fallibility
• Eliminate subjectivity
• Include the input of established education companies
• Adopt continuous improvement practices

Reduce Administrative Inefficiency

• Reading accreditor documentation prior to attempting application should be unnecessary.
• Re-work for applications that do not pass the first attempt should be reduced.
• Web development changes that are required to accommodate accreditor requests should be minimized.
• Content development changes (that have nothing to do with the quality of content) should be eliminated.
• Meetings and additional communication should be treated like customer service inquiries.
• Protracted processing times by accreditors should be reduced.
• Filling out applications should be easier.
• Reduce similarities and redundancies.
• Post-accreditation fees should be eliminated.
• Accreditors, stay out of marketing, or really get into marketing.

Improve Reviewer Reliability

• The synonym problem
• Reduce sensitivity to increase reliability
• Weighting questions for higher specificity

Decrease the Financial Impact on Educators

• Attempt to reduce the number of accreditors
• Reduce (or eliminate) per-course fees
• Institutional review with random course audit following 3 years of course approvals without significant issue

Do Not Assume Validity

• The goal of every question or item on an accreditor’s application should be to differentiate between high- and low-quality educators.
• Every application question should inquire about an issue that has demonstrated a significant influence on student experience and outcomes.
• Are proctored exams or in-person practical exams better assessments than online randomized multiple-choice exams?

Accreditors Must Want to Improve

Unfortunately, accreditation seems to be dominated by companies that have developed bureaucratic institutions, governed by a board, that are slow to change, and seem to assume the role of tribunal rather than crusaders in the fight for better education. If accreditors truly want to improve continuing education for professionals, the first step is wanting to improve.

Admit Fallibility

The “air of infallibility” exhibited by many accreditors must be replaced by a desire for continuous improvement. No organization is infallible, and as complex as the accreditation process is, it is unlikely that a perfect process is attainable. Accreditors should adopt initiatives to work with educators to continuously improve application processes.

Eliminate Subjectivity

This suggestion is related to the “air of infallibility” and a perception that the reviewer is “always right.” Accreditors should remove as much subjectivity from applications as possible. There may be no greater frustration for educators than attempting to follow every documented guideline before submitting a course and failing for subjective reasons. Often the reason is based on a debatable rationale that seems to have been “created” by the reviewer at the moment. Any hint of this occurring should result in a dismissal of the reviewer’s comments (no impact on the application), and an attempt by the organization to define, document, and measure the concern.

Example of subjectivity: National Athletic Trainers’ Association, Board of Certification (NATA-BOC), Evidence-Based Practice (EBP) credits. EBP credits are discussed again below, under initiatives that call for research that does not exist, but this program also involved “board approval.” This resulted in a subjective rating of how closely a course aligned with PICO by a board that met quarterly. If an educator failed board approval, they received little feedback and were not permitted to re-apply until the board reconvened. It should seem fairly obvious why more courses were not approved for EBP credits. What education company would want to modify a course over and over, guessing what the board will actually approve, and then wait a full quarter between iterations?

Include the Input of Established Education Companies

The development of an “ideal accreditation” should include the input of education companies. Although most accrediting organizations employ an expert panel or a board of professionals, it is clear that many of these panels have perspectives that are not aligned with continuing education providers. For example, many of these boards are composed of college professors who no longer practice, and they have never built or marketed a continuing education course. Teaching a course that is a mandatory part of a curriculum is very different from building and delivering opt-in education for adult professionals.

If accreditors added the input of established education companies, they could significantly reduce their errors and irrelevant requests. And, the inclusion of input from educators could be done without concern for individual educators attempting to bias the application process to fit their model of education. A robust list of established education companies could be created, and each item on an application could be assessed by a randomly selected group of companies. The input of any individual education company could be limited to a small subset of items on the application. Below are a couple of examples of errors in applications. Unfortunately, errors like these are surprisingly common.

Argumentum ad novitatem (appeal to novelty):

• American Occupational Therapy Association (AOTA), application question: “Explain why you used research older than 5 years?”
• The Ohio Physical Therapy Association (OPTA) updated its Policies and Procedures for Continuing Education Approval: Section B, 2.4, bibliography must be published within the last seven (7) years (shortened from 10 years). The change was also made in Sections A, 5.2; G, 1.6; I, 3.2; and J, 4.3.

These questions imply that very new research is better research, which is the logical fallacy known as “appeal to novelty.” There is no evidence that research published in the last 5 - 7 years is superior to research published in the last 50 years. If anything, the proliferation of poorly performed and misinterpreted systematic reviews has made the overall quality of peer-reviewed publications worse in the last 10 years. Further, several topics have not benefited from additional research in the last 10 years (for example, it may be hard to find new research on some anatomy topics). These policies result in incomplete research reviews and support for what is trending over what is best supported.

Expecting research that does not exist:

• American Occupational Therapy Association (AOTA): “Please clarify only the references that support occupation-based assessment (tests).” What the AOTA reviewer was asking for in this critique was research demonstrating the effects of special tests on functional outcomes. That is, a course on assessment submitted to the AOTA is expected to cite research showing that performing special tests, by themselves, improves functional outcome measures. Imagine a researcher attempting to demonstrate that the Neer test improved someone’s DASH score. That research does not exist, and when we raised the issue, the requirement stood. The practical result is that a comprehensive set of continuing education courses on assessment for occupational therapists is very difficult to build under this standard.
• National Athletic Trainers’ Association, Board of Certification (NATA-BOC), Evidence-Based Practice (EBP) credits: Although this idea was great in theory, it suffered from two large flaws (the second flaw is discussed below). The program was based on a continuing medical education (CME) requirement for physicians. The program stipulated that athletic trainers (ATCs) had to attain a certain number of credits that had received an additional level of evaluation (the EBP credit process). This evaluation stipulated that a course had to be built with the PICO framework (population, intervention, comparison, outcome). This framework fits poorly with our field’s body of research, which suggests it was adopted without testing it against the breadth of studies actually available in our disciplines. Few topics in the research relevant to our fields have a sufficient breadth of studies to build a course on this framework. Physicians, in general, have a far larger body of research to draw from, which is why the PICO framework works well for physician CME. Additionally, the naming of these credits resulted in all other credits being referred to as non-EBP credits, as if all other education was not evidence-based, which is far from the truth. The lack of sufficient courses approved to fulfill these credits led the BOC to end the requirement in 2022, but it took several years.

Adopt Lean Management Strategies (Continuous Improvement)

Our next recommendation is that accreditors adopt lean management strategies (continuous improvement), and remove any barriers that would prevent immediate corrections. The individuals working at these accrediting organizations are undoubtedly intelligent, but it is unlikely that any process will perfectly match the demands placed on it prior to practical application. Further, the rate of innovation in the education industry will challenge any rigid process. Many accreditors have such complex review processes that errors in an application may linger for years.

Example: It is likely the standard practice for most accreditors to start application evaluation with a customer survey (survey of accredited educators), followed by a staff review that recommends which issues should be “elevated” to board review, followed by board review, followed by the creation of a presentation of “proposed changes,” followed by board review of the “proposed changes,” followed by addition to a project management schedule, to be added in the following year’s scheduled update. Meanwhile, in that same period, multiple errors could have been addressed, several potential solutions could have been tested, data from those solutions could have been gathered, and the best solutions could have been permanently adopted.

Improve Administrative Efficiency

The largest expense associated with accreditation is not the fees charged by accreditors; it is the administrative cost of successfully completing an application. This may be the most obvious example of accreditors forgetting who their customers are. Although accreditors serve the industry by enforcing a minimum standard of quality, it is education companies who pay for their services. It is common practice for accreditors to ignore the administrative costs associated with the successful completion of an application (for example, unnecessarily long and cumbersome applications). Further, many of the inefficiencies also increase the administrative costs for accreditors, suggesting their resolution is a potential win-win. At the very least, the following list is money spent on issues other than improving the quality of education.

Administrative Costs That Could Be Improved

Self-explanatory Application Items: Reading accreditor documentation prior to attempting an application should be unnecessary. A well-designed application should not require an educator to read additional documentation. If an accreditor’s application process requires that an organization read dozens or hundreds of pages of documentation, the application process is severely flawed. Accreditors need to ask themselves whether the application item requiring additional reading is actually testing an educator’s ability to deliver quality education, and/or is a valid measure of the education company’s quality assurance processes. Applications should not be an exam given to educators to test their ability to memorize an accreditor’s documentation.

Reduce Rework: Re-work for applications that do not pass the first attempt should be reduced. This issue is discussed in more detail below under reliability, but in short, every item on the application that passes following a second or third attempt should be considered a sign that an application item lacks clarity or congruence. In this case, we are not referencing items that highlight significant issues in the quality of content, delivery, or assessment. We are specifically referring to those items that require multiple attempts to determine the “wording” that reviewers have been trained to look for. Items that are most often failed and then passed on second or third attempts should be rigorously refined or removed from the application.

Reduce Web Development Requests: Web development changes that are required to accommodate accreditor requests should be minimized. We estimate that 70 - 90% of these requests result from accreditors having little knowledge of the actual costs of web development. There have been far too many instances where we have had to spend hundreds or thousands of dollars moving a button, repeating a disclaimer in multiple locations, creating certificates with dynamically generated ID numbers, switching oddly shaped and oversized logos, etc. These requests do not improve the quality of education in the industry. There is no need for educators to display an accreditor’s disclaimer on every course, ID numbers should be organization-specific, not course-specific, and if you are going to change a logo, at least try to keep it the same fairly industry standard shape.

Only Education Relevant Content Changes: Content development changes (that have nothing to do with the quality of content) should be eliminated. Although it is the primary function of accreditors to ensure a minimum standard of quality, often accreditors will ask for changes in content that have nothing to do with education. For example, accreditors may require that every course and/or module list behavioral objectives, mandate the location of disclaimers about the accreditor’s definition of approval, require instructions on how to take a multiple-choice test before every exam, or enforce the repetitive placement of a refund and cancellation policy.

Reduce Meetings: Meetings and additional communication should be treated like customer service inquiries. Much like documentation, this should rarely be necessary and most often arises from incongruencies in the application process. Accreditors should treat additional meetings and communication like customer service issues. Great companies try to eliminate or significantly reduce customer service by solving customer complaints. Great companies understand that customer service is an administrative expense. Note: We recommend that some of the more complex application processes consider developing a network of consultants to help educators with the application process.

Reduce Processing Time: Protracted processing times by accreditors should be reduced. The gross majority of time to achieve accreditation is spent waiting for replies. At this point, we complete most applications in a day, or maybe over the course of a week; however, we often wait months for responses. Often, responses result in additional changes or modifications that need to be made before applications are resubmitted, which we then complete in a day (or week), followed by several more weeks of waiting. Accreditors must keep in mind that the longer an application process takes, the longer a company is paying overhead expenses before it can begin to get a return on investment from accreditation. In short, time is money. Accreditors with a particularly long approval process should spend significant resources addressing the issues discussed in this section.

User Interface (UI) Improvements for Applications: Filling out applications should be easier. Accreditors should adopt a variety of customer-service-oriented website developments that greatly improve the efficiency of filling out long forms. This includes pass-through of information from form to form, autofill, checkboxes, drop-down menus, etc. Reducing redundancies and adding some relatively simple programming could significantly decrease administrative costs for the educator and the accreditor.

Reduce Redundancy: Reduce similarities and redundancies. The amount of redundancy in some applications is remarkable. Obviously, this results in a significant amount of wasted effort by educators and accreditors; however, the most significant issue may be that redundancy also creates opportunities for incongruency. Using many of the tools discussed in the previous point will help (pass-through of information from form to form, autofill, etc.); however, accreditors should also be looking to remove redundant or significantly similar questions and items.

Post-accreditation fees should be eliminated. This practice is enforced by only a couple of accreditors, but it is a bad one. The practice is charging educators for every certificate generated, every participant attending a course, or every time a course is facilitated. This creates a high and ongoing administrative cost and amounts to accreditors carving out a profit share from education companies. PACE, for chiropractors in the United States, is the most notable example, asking us to pay for every certificate generated, on a monthly basis. Although PACE has been a good organization to work with overall, every month we have to ask an employee to generate a report of the number of certificates awarded to chiropractors and then write a check for that number, which erodes some of our rapport. The National Strength and Conditioning Association charges a fee every time an approved course is facilitated, which is another example of an ongoing fee on courses that have already been approved.

Accreditors, Stay Out of Marketing. We should not have to say this, and perhaps this is simply unfamiliarity with digital marketing, but accreditors should have nothing to say about a company’s marketing. Accreditors do not seem to understand how a small word change (copy changes), a small image change (creative changes), and/or placement changes can have huge effects on the cost of acquisition. If the cost of acquisition goes up, marketing costs go up, and so does the cost of education. We have had the unfortunate experience of being asked to modify marketing materials by several organizations, including adding the accreditor’s disclaimer to an image ad, adding behavioral objectives to landing pages, prohibiting the use of an accreditor’s name in search engine marketing (e.g., “XYZA Approved Courses”), and adding a refund policy to organic social media posts about upcoming workshops. In all of these cases, the information was clearly available on the website, where there is plenty of room for additional information. The addition of these recommendations to ads and social media posts resulted in an initial increase of 5 - 10 times the cost of acquisition. Accreditors, stay out of marketing. If your goal is to improve education quality, try not to make marketing 10 times more expensive.

Or, Really Get Into Marketing. Some organizations have an opportunity to become marketing platforms. That is, many accrediting bodies are also representative membership organizations for a profession (e.g., the AOTA and the APTA). A couple of these organizations have attempted to create an opportunity for educators to market to their members. The APTA had a great idea in developing a “partner” program that started with additional vetting, establishing “partners” as the “cream of the crop.” However, no organization that has tried this has created an attractive marketing package with a large potential for return on investment, and the reason is embarrassingly simple. None of these organizations has hired professional digital marketers to lead the marketing opportunity or aid in its development. We do think the combination of additional vetting and a professionally developed marketing plan could be a win-win for accreditors and educators.

• Example: The AOTA requirement to place its logo and disclaimer (see below) on every course is an example of unnecessary administrative cost. The oddly shaped logo, with a disclaimer, with unique course information buried in the disclaimer (individual course identification number and number of credits), created design issues, affected mobile viewing and loading speeds, required separate code to accommodate the shape and size of the logo, and required significant time to write code that would dynamically pass the identification number and number of CEUs into the disclaimer itself. In our view, the disclaimer belongs on the accreditor’s website, credits are listed on every course and should not be part of a logo, and identification numbers should be company-specific rather than course-specific and are sufficient on certificates. Requirements like these inflate administrative costs for accreditors and educators alike.

Caption: Long disclaimers should not be mandated on certificates and on multiple web pages

Improve Reviewer Reliability

There is a relationship between congruence, sensitivity, and inter-rater reliability. If an accreditor has tasked reviewers with finding errors in applications, they will find errors. Further, if the accreditor has a policy that any error results in an application being denied (a one-strike policy), then it is unlikely that any course will pass the application process on a first attempt. It creates a scenario in which it becomes less likely that courses will pass with any incongruencies, any increase in the amount of narrative information requested from the educator, any increase in the length of the application, and any increase in the number of reviewers tasked with reviewing an application (or multiple applications from the same education company). However, several simple strategies can significantly increase inter-rater reliability, decrease the number of “false fails (false negatives),” and significantly reduce administrative costs by eliminating the re-work that comes from multiple attempts.

The Synonym Problem

For the review of applications, accreditors often hire subject matter experts who are capable of conceptualizing answers. However, the number of potential narrative answers to a short-answer question can be as numerous as the number of educators completing the application. This results in accreditors implying or explicitly requesting that reviewers search for “certain words” or “specific language.” Accreditors should not make educators guess which words the reviewers are looking for. Selectors (drop-down menus, list boxes, multiple-choice questions, true/false selectors, etc.) are an excellent way to ensure that options are limited to the accreditor’s preferred synonyms. This reduces the chance of misinterpreting the educator’s intent, and educators are not penalized for using different terminology. Additionally, if the wording required to answer an application item is in an external document, the content should either be in a PDF embedded next to the application question, or there should be a link to a bookmark next to the content the question refers to (not a link to the entire document).

Nothing asserts more disregard for educators than accreditors who refer educators with a specific question to a document that is dozens or hundreds of pages long. The phrase “it’s all in the guidelines” should be retired from every accreditor’s vocabulary. If an educator has a question about a specific item, they should be referred to the specific page, paragraph (or table), and/or lines in a document. After all, if an employee of the accreditor does not know the specific line to find the answer, what chance does the educator have? We cannot count the hours (and money) our company has spent, and presumably many others have spent, trying to find the single paragraph or sentence in a document dozens or hundreds of pages long to answer a single application question. Accreditors, if your goal is to make education better, do not waste time and money that could be spent creating and improving courses on a scavenger hunt for language.

• For example, the American Occupational Therapy Association (AOTA): The AOTA application requires that any practical application course include reference to the intended functional outcome improvement. We appreciate this standard, as many courses in the industry are “modality” driven and seem to downplay the importance of practice being outcome-driven. What took us several failed applications, re-applications, meetings with employees (and being told “everything is in the guidance document”), a statement from an OT consultant, a survey of OTs in our network, and eventually a meeting with a senior staff member was this: the AOTA uses a specific document with specific wording describing functional outcomes. Rather than reviewers accepting the standard language used by researchers and other physical rehabilitation professionals (e.g., physical therapists, chiropractors, athletic trainers, physicians), the AOTA expected the functional outcomes to match the exact wording found in the list of functional outcomes in table 2 of the OTPF-4. This was not documented anywhere in the application process.

Sensitivity Versus Reliability

Again, if an organization has tasked reviewers with finding errors in an application, they will find errors. And, if the organization has a policy that any error results in an application being denied (a one-strike policy), then it is likely that an exceedingly high percentage of applications will fail their first attempt. The goal of an accreditor should be to increase accuracy by ensuring that education companies that should pass do pass on the first attempt, and that education companies that should not pass do not pass without significant changes to their program (not just their application). The statistics of sensitivity and specificity are appropriate here. An education company that should have been approved but was not is a false negative, and an education company that should not have passed but did is a false positive. An application process that catches every error, but fails to determine which errors are valid reasons to deny approval, has high sensitivity but no specificity. These examples mirror the scenario most accrediting organizations are currently facing.

A large portion of this problem can be addressed by reducing sensitivity, and it may be possible to increase specificity concurrently. Rather than having reviewers tasked with identifying errors for immediate denial of an application, reviewers should be tasked with generating reports. These reports should treat applications more like exams; that is, they should replace the one-strike policy with a “passing score.” Even setting the passing score at 90% may still represent a 10-fold reduction in potential re-work. This change alone would not increase specificity, but treating applications like an exam is the necessary first step. Application specificity may be increased by weighting questions. Accreditors could even weight certain questions as “red flags,” implying that an application can only be approved if these questions are passed. To ensure that “red flags” do not result in the same sensitivity problem, they should always be objective (no room for subjectivity), make use of selectors, and the question itself should contain all of the information needed to provide an accurate answer.

ProCert (FSBPT): A Case Study

The APTA and FSBPT were built to support the physical therapy profession, and we want to believe in both organizations; however, their track record on continuing-education approval carries some serious scars. One of those scars is ProCert, by the FSBPT. ProCert was an attempt at a business that would provide national (rather than state-by-state) pre-approval for continuing education courses for PT and PTA license renewal. ProCert closed in 2019, after education companies across the industry had invested in applications, which we estimate at millions of dollars in aggregate. What is truly unfortunate is that the idea of replacing state-by-state accreditation with national accreditation was the right idea. In our experience, ProCert exhibited every problem discussed in this article: a culture of infallibility, little apparent interest in input from educators, an inflexible system incapable of efficiently addressing application issues, large narrative portions of the application that were rated subjectively, every administrative inefficiency discussed above, the lowest inter-reviewer reliability we have encountered, and a financial model that did not survive.

Here are a few facts from our own applications that illustrate the inter-reviewer reliability.

• The reliability was so low that we eventually hired a former ProCert employee to audit our applications before submission. Despite this being a turning point for us that eventually led to ProCert approval of more than 100 courses, she rarely, if ever, got an application passed on the first try. Not even a former employee could develop a system that resulted in reliable application approval. Most often, approvals came after she used her rapport and connections to get a representative on the phone and diplomatically demonstrate that the reviewer had made a mistake and that our application followed every published guideline.
• We submitted courses in batches, with each batch representing a category (e.g., Activation Exercises). We have a systematic approach to course development, and batching added a further layer of congruence, ensuring that instructional design, learning objectives, and content type were nearly identical. Our hope was to gain efficiency by identifying and addressing similar problems in batches. However, after any batch of submissions, we would routinely pass 1 - 2 courses and fail the other 6 - 10, and the failed courses most often failed for different reasons. For example, when we submitted our Activation Exercises courses, 2 courses passed, and the rest were returned to us in 2 batches of 3 courses. Each batch failed, but for different questions, with each batch passing the questions that failed in the other batch. This left us with no clear path forward.
• We had several meetings with reviewers to explain our systematic process for documenting reviewer critiques and applying them to every future application. After dozens of submissions, our first-submission pass rate was still about 20%. The reliability was low enough that it was impossible to find best practices with a high likelihood of being accepted by all reviewers.

ProCert should stand as a case study for educators and accreditors. ProCert collected application fees from education companies across the industry, subjected them to a review process with the reliability described above, and then closed its doors with no succession plan or service to aid educators in a transition to other accreditors, leaving education companies to invest tens of thousands of dollars in new accreditation strategies. Consider the money and time spent compensating for ProCert’s closure that could have been spent improving education. For more on these issues and our solution for continuing education approval for PTs and PTAs in the United States, see PT and PTA State by State Course Approval and Credit Requirements .

Decrease the Financial Impact on Educators

“Any program that is not profitable is not sustainable.” This little piece of “truth” is a quote I developed decades ago for a lecture. I still use this quote every day with our staff as a reminder that wanting to “do good” in the world will only occur if we figure out how to make what we are doing profitable. A company has to last long enough to accomplish its mission, and then remain profitable to continue offering services. So, I understand that most accreditors are trying to “do good” and that they must charge for their services. However, some accreditors treat educators as if they were cash-generating machines that need to be regulated, taxed, and punished when they step out of line. Many of these accreditors seem to forget that if they intend to improve the quality of education in the industry, they need to support educators, not punish them.

Our first recommendation is that accreditors audit or survey their customer segment (educators). They will quickly find that educators are facing more competition than ever before, that development costs (especially front-end development costs) for education companies are particularly high, and that profit margins are exceedingly small for all but a few companies. Once these metrics are confirmed, accreditors need to take a more creative approach to building financial models. There are several steps accreditors could take that would increase their profit margins while also decreasing the fees they charge educators.

Recommendations for a Better Business Model

Attempt to reduce the number of accreditors. Unfortunately, accreditation does not strictly follow the rules of capitalism. Adding accreditors to a field does not usually result in the type of competition that improves offerings and drives down costs. Instead, it generally results in educators having to achieve approval from all accreditors who have unintentionally splintered a market. Physical therapy in the United States is an example: ProCert’s closure resulted in a return to state-by-state accreditation, as well as the introduction of several accreditation services intended to replace ProCert, at per-course fees that are among the highest in the industry (CEU Locker, for example, charges per course, per year, with no differentiation between a one-hour online course and a multi-day workshop).

This issue implies its own solution. Accreditation companies should include initiatives in their business plans to reduce the number of accreditations an education company needs. They can do this through mergers and acquisitions, partnerships, reciprocity agreements, and potentially the accreditation of courses for multiple professions with similar scopes. For example, the accreditation processes for the better physical therapy course accreditors and the NATA-BOC are very similar. It would be exciting to see the CPTA (California) and TPTA (Texas) merge with the NATA-BOC and attempt to create a national accreditor for ATCs, PTs, and PTAs. They could then attempt to merge with PACE for chiropractors, and/or acquire a reciprocity agreement with the Australian Physiotherapy Association. It is a little surprising that more organizations have not attempted this strategy. In some cases, a competitive mindset will be necessary: accreditors putting profit before the health of the industry should be pushed out of the market. (Note that some consideration should be given to monopolies as well, although this could be addressed with an educators group that could bargain collectively).

Reduce per-course fees. Many accreditors still have a pricing model that reflects a time when most education companies were local providers of live workshops. An education company might have had 1 - 4 workshops in its portfolio, each 1 - 4 days long, approved for 1 - 3 professions, with the workshops most often available close to company headquarters. Things have changed drastically in the past decade. Technology has enabled educators to transition to online learning, become more student-centered and customer-service oriented, and significantly increase access, convenience, and affordability. The former education business model is collapsing, with a trend toward larger national and international online continuing education companies (which also provide live workshops). Many of these companies operate without a local presence. This trend is a huge win for education, with larger companies offering a wider variety of higher-quality courses, iterative improvement of courses based on feedback from larger groups of students, more flexible offerings (in-person, live-stream, and online), and often much lower prices. Companies like the Brookbush Institute make it possible to choose from a large library of short courses (200+ courses, 4 certifications including the Certified Personal Trainer (CPT) Certification , and growing) that can be completed on desktop or mobile devices, serving multiple professions in multiple countries, while reducing the upfront cost of education by orders of magnitude with a Netflix-like membership model. Our comparison of personal trainer certification cost shows the size of that difference. And we have competition; we are not the only company experimenting with this education model. However, some accreditors have not responded. When we last applied, CEU Locker, the Ohio State Board of Physical Therapy, and the National Strength and Conditioning Association charged $100 - 250 per course per year. They did not differentiate between online courses and live workshops, or between a 1-hour course and a 5-day certification. The result is accreditors asking educators to pay $16,000 - 40,000 per year for a single accreditation (not including administrative costs).

There are several ways to address this issue without significantly affecting profit margins. In fact, many of these suggestions have the potential to increase revenue and gross profit. It is our prediction that accreditors that do not accommodate the current trends in the industry will cease to exist. The Florida and Ohio physical therapy chapters have already adopted reciprocity guidelines with other state chapters. We suggest the best possible solution below; however, we understand that the “best possible solution” is nothing short of a business-model pivot and a large initiative for some older accreditors. So, here are a few solutions that may be easier to integrate into the current fee structure:

• Use the suggestions above to improve administrative efficiency and proportionally reduce the per-course application fee.
• Increase approval periods (5 years) and simplify renewal processes (abbreviated application). Although this does not change the upfront cost, it significantly reduces amortized costs.
• Offer discounts based on the number of courses or applications submitted (bulk pricing).
• Introduce pricing that considers the length of the course. For example, a 2-credit online course would be a fraction of the price of a 16-credit weekend-long workshop.
• Offer a steep discount on any additional course within a series. For example, $150 for the first application and $25 for each similar course.

Best Possible Model

In our continuous effort to build an approval portfolio, we have experienced 3 practices that have the potential to enforce the highest standards of education quality, significantly reduce the cost to educators, and massively decrease accreditors’ costs.

Institutional approval. The first step is a path toward “institutional accreditation.” Rather than accreditors attempting to approve each individual course, accreditors should develop reviews that assess the course-creation systems developed by the institution. This likely involves an application and review that is longer and more complex than a single course application, but it is unlikely to reach double the length or complexity of a single course application. The big advantage is infinite scale. Whether a company has 3 courses, 300 courses, or 3,000 courses, the application process would be similar. Institutional review is already used by the American College of Sports Medicine (ACSM), the NATA-BOC, the CPTA, the TPTA, and several others.

Yearly audit of a random course. Course quality can be ensured by a thorough review of a randomly selected course. Although it may be possible for an educator to assemble a passing application for institutional review with poor-quality courses, it would not be worth the effort knowing the accreditor is going to select a course at random for in-depth review (currently used by the NATA-BOC).

Institutional review with random course audit following 3 years of issue-free course approvals. This clever addition is already in use by the California Physical Therapy Association (CPTA) and the Texas Physical Therapy Association (TPTA). In this model, every education company is subjected to individual course reviews for at least 3 years. After 3 years of course approvals without significant issues, the company can apply for institutional approval. If the company is approved, all courses facilitated by the company are approved. If an education company has significant issues with course applications, eligibility for institutional review is delayed. This additional layer of review requires education companies to carefully develop courses for 3 years to avoid delaying the more efficient and affordable institutional approval. Three years is sufficient time for educators to develop and refine systems, and long enough to ensure that low-quality course creators trying to capitalize on market trends are sufficiently penalized by the larger per-course application fees. Most importantly, institutional approval (with random audit) is more cost-effective and profitable for educators and accreditors. Perhaps institutional review with one randomly audited course represents the administrative cost of 3 individual courses. Educators can then publish as many courses as they would like, in multiple formats, without an increase in relative cost, which allows accreditors to charge a premium for the service, perhaps 2 - 3 times what they would normally charge for 3 courses. Institutional renewal could be done with an abbreviated institutional application and one more audited course, perhaps representing 1.5 times the administrative effort of a single course application. The reduction in administrative cost could be split between a discount for the educator and an increase in profit for the accreditor. This creates a virtuous cycle of decreasing administrative costs and better relationships between empathic accreditors and the most established education companies. Within 5 - 10 years, the accreditor could be charging $1,000 - 1,200 for administrative work similar to a single course approval, and educators could be paying that amount for publishing dozens or hundreds of courses.

Do Not Assume Validity

This topic could be an article unto itself. Accreditors must consider which portions of an application are valid. In this context, we are referring to the scientific definition of “validity,” and in most cases, “construct validity.”

• Validity: how well a test measures what it is purported to measure.
• Construct validity: the ability of an instrument to measure an abstract concept.

For example, is the presence of a live proctor for an exam significantly correlated with less cheating and a higher-quality educational institution, and/or are high-quality educators using other valid methods to ensure assessment integrity?

The goal of every question or item on an accreditor’s application should be to differentiate between high- and low-quality educators. This implies that only questions that reliably “fail” low-quality educators and “pass” high-quality educators are “valid” questions. This concept has significant potential to drastically reduce costs and increase accreditor efficacy. Every question and item on an application should be reviewed, measured, and then modified or dismissed based on its ability to reliably and accurately differentiate between high-quality and low-quality educators. Examples of application questions with poor validity:

• A question that fails educators who are approved within 2 attempts suggests the question is likely producing a high rate of false negatives.
• A question that all educators pass, regardless of whether they eventually pass or fail the application, is failing to differentiate between high- and low-quality educators.

The advantage to accreditors: Our guess is that very few of the questions, items, and topics on an application are actually contributing to the successful differentiation of high-quality and low-quality educators. It is similar to the “special tests” problem in orthopedic sports medicine. Although there are dozens, or potentially hundreds, of special tests for the shoulder, the most reliable and accurate cluster available for all reliably assessable diagnoses is a group of approximately 10 tests. The addition of any more tests does not increase the accuracy of the special tests, and the 10 tests could probably be reduced to 6 with only a small reduction in accuracy (for more, see the course Shoulder Special Tests ). Application questions likely function similarly. It may be possible to have a 2-page application that is as effective at differentiating low-quality and high-quality educators as the 10 - 20 page applications currently used by many accreditors. Consider the administrative cost savings. A small group of items, such as citation guidelines, the presence of certain types of behavioral objectives, a lesson plan including a few key details, and randomization during assessments, may be as sensitive, specific, reliable, and valid as the combined accuracy of all of the items on a comprehensive application.

The advantage to educators: The same thought process should be applied to what is being asked of educators. Does the accreditor’s application question ask about an item that actually has a significant influence on student experience and outcomes? Should the educator be expected to develop content, assessments, or processes that have not demonstrated a statistically significant improvement in student outcomes? Educators may be able to significantly reduce waste and increase efficacy by focusing efforts on the portions of content development with the highest effect on student outcomes. Some topics that should be evaluated in the future:

• What is a valid learning objective?
• What aspects of a lesson plan are correlated with better student outcomes?
• What is the difference between online and in-person course efficacy?
• Are proctored exams or in-person practical exams better assessments than online randomized multiple-choice exams?

Validity Issues That Are Obstructing Better Education

“Are proctored exams or in-person practical exams better assessments than online randomized multiple-choice exams?” This question has far-reaching implications. It is our belief that technology can sufficiently protect the integrity of multiple-choice exams, that quality multiple-choice questions can be written that are as accurate at measuring practical application as subjectively graded in-person practical exams, and that the combination of technology and quality questions can make any additional protection gained from proctoring not worth the expense. In-person and proctored exams result in exponential increases in cost. These are relative costs that increase with the number of courses offered, the number of students, the amount of engagement by the student, and even the number of exam retakes. Alternatively, using technology to facilitate timed and randomized multiple-choice questions, with inherently unbiased automatic grading and automatic generation of certificates, results in infinitely scalable test administration. Once a learning management system is built, the only additional cost for education companies is the addition of more courses and exams. There is no increase in cost with the number of students, the number of exams taken, or the number of exam retakes. Further, technology can be used to administer surveys and gather data after every exam, and sophisticated psychometrics can be automated to determine the statistical relevance of each question. The advantages are immense. Completely automated exams also allow for iterative testing (small exams at the end of each module), occurring when it is convenient for the student, and on multiple platforms (desktop or mobile). In short, the advantage of automated online testing is improvements in affordability, access, flexibility, convenience, and potentially even test quality. And, there is no evidence that these exams are worse at assessing the knowledge, skills, and abilities of students, or that they result in a significant increase in cheating. (Consider that the licensing examinations for physicians and physical therapists in the United States, the USMLE and the NPTE, are computer-administered multiple-choice examinations - although, they are proctored)

The Online Course Penalty (and the Mergener Formula)

More than ever, accreditors, educators, current students, and the general public are weighing online education and conventional in-person education with equal weight and more objective critiques. Both have their advantages and disadvantages, but neither is inherently better than the other. For example, in-person education may allow a dialogue between an engaged professor and students, but online education has the distinct advantage of multiple viewings and readings. Unfortunately, accreditors do not give equal weight to in-person and online content. Accreditors give a 1:1 ratio of hours in class to hours of education earned, regardless of the amount of content actually covered in that class. However, online education, often being text-heavy, is given credit for what can only be called “read-through” time: not the amount of time it would take to study, comprehend, discuss, integrate, apply, and pass an exam, but the amount of time it would take to read through a document from beginning to end. This results in an “online course penalty.” Although online courses are often more convenient, a student often has to consume and be tested on far more content to receive the same amount of credit.

For example, using the Mergener formula, 10,000 words (about 30 textbook pages) and a 5-question exam, at level 4 difficulty (technical reading), earns approximately 1 contact hour. Now consider that accreditors consider 1 college credit to be 10 contact hours of education. That implies that earning 3 credits toward a degree, from online education alone would require 30 “contact hours.” So, a 3-credit class requires 300,000 words of text (approximately 800 textbook pages) and 150 test questions. That is the equivalent of roughly 2 textbooks, a solid midterm, and a tough final exam, for a single 3-credit class. Multiply that by 10 to achieve a 30-credit M.S. degree, and you have a requirement of 3,000,000 words of text, about 10,000 textbook pages (20 - 30 textbooks), and 1,500 exam questions. Compared with the average M.S. degree in human movement, we estimate this is nearly double the amount of work expected of students. Students should work hard, but they should not be punished for choosing online education.

The National Commission for Certifying Agencies (NCCA): A Process Whose Validity Has Not Been Studied

NCCA accreditation attests that a certification program developed and administers its certification exam in conformance with the NCCA’s standards. It does not include review of the accuracy or quality of the education behind the credential. The Brookbush Institute’s CPT Certification examination is NCCA-accredited, because employers require it, and we are still asking the question in this section. We are aware of no study demonstrating that the NCCA’s prescribed development process discriminates between competent and incompetent professionals any better than a conventional exam written by subject matter experts and reviewed by two or three peers, which would be closer to the standard used for high-stakes assessment in university settings. If the NCCA’s far more expensive and complex process does not outperform that conventional standard, it is difficult to identify what the additional expense purchases.

We would encourage the NCCA to perform or commission a validity study of its methodology, and we would be the first to applaud the initiative. Comparing NCCA-accredited certifications to non-accredited certifications would not be a fair test: the expense of the process is so high that only the largest and most well-established companies have achieved accreditation, so any difference between groups may reflect company size and resources rather than the process itself. Two study designs would be more informative:

• Compare the exams directly. Build two exams from the same test blueprint, one developed with the full NCCA-prescribed methodology and one written by subject matter experts and reviewed by two or three peers. Administer both to the same candidate pool and test for statistically significant differences in pass rates and score distributions. Candidates could also complete both exams and report any perceived differences (for example, difficulty or clarity).
• Analyze accreditation as a natural experiment. When an organization first achieves NCCA accreditation, it creates two comparable groups: professionals certified by the exam before accreditation, and professionals certified by the accredited exam after. Employer metrics for the two groups could then be compared. For example, did the addition of NCCA accreditation to a personal training certification result in an increase in the average income, or length of tenure with an employer, for the personal trainers certified after accreditation? Care would be needed in case selection: this analysis only works in markets where accreditation was not itself a barrier to entry during the study period.

Our guess is that no meaningful difference would be found. Further, we suspect that the type of online, randomized, multiple-choice assessment used by the Brookbush Institute (and others) for course exams is far easier for educators to implement, iteratively improve, and scale, and does not incur comparable costs. This is far more beneficial for students and would likely have a larger positive effect on the industry over time.

Help Us Help You!

We would love for this article to grow into a reference for movement professionals, educators, and accreditors. If you have any additional questions, comments, or ideas, please leave them in the comments below.

Caption: The Brookbush Institute offers an NCCA-accredited Certified Personal Trainer (CPT) Certification Exam, as well as their education-based BI-CPT Advanced Certificate program - https://brookbushinstitute.com/info/certified-personal-trainer

Additional Resources on Certification and Accreditation

• Certified Personal Trainer (CPT) Certification
• How Much Does a Personal Trainer Certification Cost in 2026? (Including Hidden Fees)
• What Is an Accredited Personal Trainer Certification? (And What “Fully Accredited” Means)
• Continuing Education Credits: Every Approval the Brookbush Institute Holds (2026)
• PT and PTA State by State Course Approval and Credit Requirements
• The Best Personal Training Certification?
• What is NCCA accreditation?
• Certification Cannot Change the Scope of Practice of a Movement Professional
• Building a Better Corrective Exercise Certification
• The “Real Cost” of Manual Therapy Certification

© 2026 Brent Brookbush (B2C Fitness, LLC d.b.a. Brookbush Institute)

Comments, critiques, and questions are welcome!