I respectfully submit this comment in support of the Certification & Licensing Division (CLD)’s proposed amendments to the Arizona Code of Judicial Administration, which authorize the use of secure online certification exams with virtual proctoring. This update represents a necessary and equitable moderation of the Division’s examination process for licensed Fiduciaries, Confidential Intermediaries, Private Process Servers, Defensive Driving Instructors, Certified Reporters, and Certified Community Legal Advocates.

The addition of an online exam option, administered by a contracted vendor and supported by secure remote proctoring, offers significant benefits - most notably expanded access for examinees living in rural areas, those facing transportation or mobility challenges, and individuals scheduling flexibility. Despite the end of the COVID-19 pandemic—which initially compelled many testing programs to shift online, as documented by leading testing organizations such as the Educational Testing Service and the Association of Test Publishers [1]—the Division’s decision to retain a traditional, in-person paper exam option reflects a thoughtful commitment to inclusivity. This ensures candidates without reliable technology or those who prefer traditional testing environments are not disadvantaged—a concern affecting approximately 13% of Arizona households, according to the U.S. Census Bureau. The digital divide is especially pronounced in rural and low-income communities.

The proposal includes a $25 service charge for online exam administration is a reasonable measure to cover vendor-related administrative costs. This fee is in addition to the $100 applicants pay for Initial Certification and Reexamination. Compared to fees for professional licensure exams in other regulated fields - such as social work exams through the Association of Social Work Boards ($230 to $260), CPA exam sections (~$200 each), and Praxis exam for educators (often exceeding $150) - the combined cost remains highly affordable while providing a secure and modern testing alternative [2].

Program data further supports the need for flexible exam options. Since its inception in 2021, the legal paraprofessional licensing program, for example, has grown steadily, with licensed practitioners increasing from 10 in 2021 to 79 by the end of 2024, spanning multiple practice areas including family, civil, and criminal law [3]. In 2024, the Board approved 25 applications, demonstrating active demand and ongoing licensure growth. This trend underscores the importance of maintaining accessible and diverse exam modalities to accommodate an expanding and varied candidate population.

To ensure the dual exam format remains equitable and effective, I recommend the Division add a question to the annual program report completed by credentialed professionals—such as Legal Paraprofessionals, Legal Document Preparers, and Certified Community Legal Advocates—inquiring whether the required exam setting (online or in-person) created any access barriers. Regular collection and review of this data will enable timely identification and remediation of unintended disparities, particularly in underserved or technologically limited communities.

With all this being said, while remote proctoring introduces convenience and safety, the Division should continue to monitor concerns related to privacy, technological reliability, and exam security to uphold fairness and candidate confidence. Transparent communication about these safeguards will further enhance trust in the online testing option. It is for this reason why I believe these amendments modernize Arizona’s certification process in a balanced and thoughtful manner. It expands access, preserves exam integrity, and maintains affordability. By offering both online and in-person options with a reasonable service fee and recommending ongoing monitoring of access barriers, the CLD demonstrates leadership and responsiveness to evolving candidate needs, which is why I fully support the proposed amendments and commend the Division’s commitment to improving accessibility in legal service certification.



[1] Educational Testing Service, “Responding to COVID-19,” ETS.org, 2020; Association of Test Publishers, “COVID-19 Impact Report,” 2021.
[2] Association of Social Work Boards, “ASWB Exam Fees,” aswb.org; American Institute of CPAs, “CPA Exam Fees,” aicpa.org; ETS, “Praxis Test Fees,” ets.org.
[3] Arizona Certification & Licensing Division Annual Report 2024.