Even if the proposed regulations were adopted as-is, the WWWOOSSP Board failed to address the following topics: (i) whether adequate and enforceable standards exist equivalent to 12VAC-615, including the ability of the Virginia Department of Health (VDH) as dominant market participants to enforce by policy technical and procedural requirements, roles and responsibilities, standards of practice, and other work product from licensees of the Department of Professional and Occupational Regulation (DPOR); (ii) whether certain portions of 12VAC5-615 should be retained in other regulations administered by VDH or DPOR before repealing 18VAC160-20, including ethical requirements, certain definitions (e.g., backlogs), and application requirements; and (iii) whether VDH could implement a consistent, predictable, and enforceable program while acting as market participants; for example, does VDH have different requirements between public and private sector licensees? 

How was this false dichotomy ever allowed to perpetuate under the WWOOSSP Board?  There were even documents obtained under FOIA which prove VDH was meeting in private while lobbying DPOR's Executive Staff for stakeholder priviledges.