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ISP Files New Emergency Rules for Instructors - April 16, 2014


Molly B.
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The ISP filed new emergency rules for instructors on April 16, 2014 which were posted in the Illinois Register on May 2, 2014. The new rules will be in effect for 150 days, at which time they become permanent unless changes are made.

 

The new rules do not address scoring of the target therefore the requirement in the FCCA for 70% of the hits to be on a B-27 target shall mean hits in the silhouette area.

 

There is some vagueness in the records keeping portion of the new rules but in discussion with the ISP we have somewhat of an understanding of what they are wanting and are working on clearer language. It is a work in progress.

 

 

Can't upload doc but here is the link.

http://www.cyberdriveillinois.com/departments/index/register/register_volume38_issue18.pdf

 

page 9703 - Proposed new rules for FCCA and instructors -

 

1) To facilitate an adequate audit trail, instructors shall maintain all records to support any training certification as required by Section 75(f) of the Act, which shall include:

A) copies of training certificates currently accepted to satisfy the prior training credit submitted by students;
B] training rosters;
C) written performance scores (written - or electronic roster that can be printed out - of successful completion of requirements: classroom/range*)
D) Live fire qualification scores (pass/fail listed on roster*)
E) Proof of overall completion of training (successful or unsuccessful) (listed on roster that student attended all required hours and whether or not they were issued a certificate of training*)

2) Forms of proof of training, provided by students requesting credit for the prior training, shall be treated as confidential. For example, forms of proof such as a DD214 for previous military service will contain personal identifying information that should be protected. Instructors may encourage students to redact certain personal identifiers prior to providing a copy, and shall ensure this information is secured in a location that is not accessible to unauthorized persons

 

* Our understanding according to conversations with ISP.

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Molly,

 

Thanks for the update.

 

Sure would be nice to have a website ( or forum here) we instructors could use as reference point to stay current since the ISP does not notify us of changes.

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Lets see if this attachment works...

Emergency Rules Filed 5-2-2014.pdf

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So now we do have to keep dd214s. Boy i have a lot of phone calls to make

I would say that's a going forward thing right?

 

fingers crossed

Edited by wtr100
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There is nothing wrong with copying DD-214's. It is military id's you can't copy.

And even that's a stretch forging an ID is the real no-no

 

Still it's a royal PITA to keep the certificates

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I remember at one time early on in all this the ISP wanted the DD-214 loaded to the application . This is rubbish, if the ISP want a copy retained have it loaded to them. Jim.

And they are going back to submitting prior training certificates with the FCCL application.

 

Read page 9711 Section 1231. Appendix B paragraph c).

 

It states "Instructors should inform applicants how much credit they wil receive for their prior training and remind them the prior training certificates must be submitted with the FCCL Training Certificate when they apply."

 

Now if the application process let's the applicants upload those certificates or not is another issue entirely !!

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The King:

 

I believe having the instructor remind student to upload training doc is a holdover from original rules that the ISP legal team did not realize they left in the new rules.

 

THey do not intend to upload proof of prior training docs.

 

Molly:

 

I'm at a loss for words. How is that the legal team is able to put these "Emergency Rules" together but they either don't read what they write or someone doesn't proof read them for accuracy and content. And they probably wonder why we complain !!

 

If these people did this type of work in the private sector, they would be in the unemployment line.

 

Sorry for the rant, but I get frustrated at incompetency.

 

KING

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The King:

 

I believe having the instructor remind student to upload training doc is a holdover from original rules that the ISP legal team did not realize they left in the new rules.

 

THey do not intend to upload proof of prior training docs.

 

Molly:

 

I'm at a loss for words. How is that the legal team is able to put these "Emergency Rules" together but they either don't read what they write or someone doesn't proof read them for accuracy and content. And they probably wonder why we complain !!

 

If these people did this type of work in the private sector, they would be in the unemployment line.

 

Sorry for the rant, but I get frustrated at incompetency.

 

KING

 

 

 

A point we made to the folks we met with at the State Capitol today.

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The emergency rules do not include these items from the prior instructor packet emailed out to instructors:

 

no limiting shots to inside the 7 - ring

no must keep copy of certificate issued

no must score after every 10 rounds

no requiring instructors to enter a business name on training certificate that is not their business name.

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I teach NRA BP on day one. I wonder how picky they'll get if I don't keep copies of those certificates, but maintain a copy of the course report sent to NRA (which I already do)?

If you teach NRA BP as day one, you will have provided 16 hours of instruction at the end of day two, NOT certifying 8 hours (NRA BP) and then providing 8 hours of instruction, no need to keep a BP certificate. If you ACCEPT NRA BP (that you did not teach), then you are certifying 8 hours and providing 8 hours, and need the BP certificate.

Edited by Indigo
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I teach NRA BP on day one. I wonder how picky they'll get if I don't keep copies of those certificates, but maintain a copy of the course report sent to NRA (which I already do)?

 

 

If you teach NRA BP as day one, you will have provided 16 hours of instruction at the end of day two, NOT certifying 8 hours (NRA BP) and then providing 8 hours of instruction, no need to keep a BP certificate. If you ACCEPT NRA BP (that you did not teach), then you are certifying 8 hours and providing 8 hours, and need the BP certificate.

 

I believe NRA T&E would disagree with your assessment. If prior credit is bring claimed, it doesn't matter when it was completed or who taught it. It's 8 hours prior verified and 8 CCL hours taught.

 

NRA Basic Pistol is not concealed carry curriculum. It is an approved replacement for part of the 16 hrs requirement.

 

Sent from my SAMSUNG-SGH-I747 using Tapatalk

 

Edited by bobapunk
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I teach NRA BP on day one. I wonder how picky they'll get if I don't keep copies of those certificates, but maintain a copy of the course report sent to NRA (which I already do)?

 

 

If you teach NRA BP as day one, you will have provided 16 hours of instruction at the end of day two, NOT certifying 8 hours (NRA BP) and then providing 8 hours of instruction, no need to keep a BP certificate. If you ACCEPT NRA BP (that you did not teach), then you are certifying 8 hours and providing 8 hours, and need the BP certificate.

I believe NRA T&E would disagree with your assessment. If prior credit is bring claimed, it doesn't matter when it was completed or who taught it. It's 8 hours prior verified and 8 CCL hours taught.

 

NRA Basic Pistol is not concealed carry curriculum. It is an approved replacement for part of the 16 hrs requirement.

 

Sent from my SAMSUNG-SGH-I747 using Tapatalk

 

+1

 

I see CLIC as a second 8 hour curriculum. I do not recall BP being part of CLIC, nor do I recall seeing a curriculum ID issued to Basic Pistol.

Edited by gangrel
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I teach NRA BP on day one. I wonder how picky they'll get if I don't keep copies of those certificates, but maintain a copy of the course report sent to NRA (which I already do)?

 

 

If you teach NRA BP as day one, you will have provided 16 hours of instruction at the end of day two, NOT certifying 8 hours (NRA BP) and then providing 8 hours of instruction, no need to keep a BP certificate. If you ACCEPT NRA BP (that you did not teach), then you are certifying 8 hours and providing 8 hours, and need the BP certificate.

I believe NRA T&E would disagree with your assessment. If prior credit is bring claimed, it doesn't matter when it was completed or who taught it. It's 8 hours prior verified and 8 CCL hours taught.

 

NRA Basic Pistol is not concealed carry curriculum. It is an approved replacement for part of the 16 hrs requirement.

 

Sent from my SAMSUNG-SGH-I747 using Tapatalk

 

+1

 

I see CLIC as a second 8 hour curriculum. I do not recall BP being part of CLIC, nor do I recall seeing a curriculum ID issued to Basic Pistol.

 

I see the problem. I made the assumption that you had your own curriculum! If you do not have your own curriculum #, then you are stuck with VERIFYING 8 hours for Basic Pistol (even though you provided the instruction) because you don't have a number that includes it (you are right, there is no number for BP on it's own, and there could not be. It doesn't include everything you need to meet the state requirements). Then you have to add another curriculum (like CLIC) for the second 8 hours. If you have your own curriculum number, you can include BP as the first day of that curriculum, removing the need for keeping the BP cert for state purposes.

Edited by Indigo
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