CLIA Close This Loophole

It was just brought to my attention that CLIA has a gaping loophole in their new requirements for the identification card.  This is the policy for 2009 and the bold emphasis is mine:

Please remember, prior to submitting your application for a 2009 CLIA photo ID card, the following qualification requirements must be met:

1. The individual agent or agency management must be affiliated with an active CLIA travel agency holding 2009 membership. Please encourage your travel agency to join or renew their CLIA membership early to avoid any delays in your application processing.

2. ID Card applicants will be required to complete and pass the exam for at least one annual recurrent CLIA live training seminar or CLIA online training program not previously submitted prior to applying for their 2009 cards.

3. 2009 ID Card applicants are required to be enrolled in, or to have achieved a designation (ACC, MCC, ECC, ECCS) in CLIA’s Cruise Counselor Certification Program.

4. In recognition of the owners and managers of CLIA member travel agencies who manage the agency business but are not necessarily front-line sellers of travel, each CLIA Travel Agency is entitled to a management allocation of no more than four CLIA ID Cards for which the above Certification qualification is not required although annual CLIA recurrent training is necessary. Promotional codes to facilitate this management allotment are available to CLIA travel agency management via e-mail confirmation with online membership renewals and within the 2009 CLIA membership kit sent to the agency upon membership renewal.

As this relates to YTB, they have "upwards of 117,000" independent business owners that would qualify according to point 4 above. So for $399, any RTA can join CLIA as an "agency" and receive 4 identification cards.

Since YTB claims that $149 will get you CLIA Application APPROVAL, I wonder if they are not indeed subsidizing this.** As they have lost the ability to market the perks (IATAN, production requirements, and the new CLIA requirements), perhaps they made a business decision to move the training online behind a firewall, charge $149 for it (although once production costs have been recovered there is no real cost), and then subsidize the balance of a CLIA membership (not an ID card) for the RTAs that take the class.

** YTB Corporate is not subsidizing this, but I do know for a fact that some resourceful Reps are indeed doing it. From the HBTA show this week, a Rep was holding a "recruitment session" outside the Einstein Bagels kiosk at the Convention Center--he was not recruiting on the floor or approaching anyone, but like a 3 Card Monte game on the street corner there was enough buzz to generate a crowd. Well sure enough, he was offering to pay anyone "full CLIA dues" to get the ID card if they signed up with him before the end of the show. More details on the show to come!