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August 13, 2018

 

 

 

Board of Health Professionals

c/o Ms. Elaine J. Yeatts

9960 Mayland Drive, Suite 300

Richmond, VA 23233

 

 

Dear Board of Health Professionals,

 

Please allow us to introduce ourselves.  We represent the interests of the International Association of Rehabilitation Professionals (IARP) Virginia Chapter and the IARP VA Legislative Special Committee.  We are seasoned professionals who have served Citizens with disabilities for decades practicing in small, mid-size and large companies across the Commonwealth.  We would like to show our support for the Regulations Governing The Certification of Rehabilitation Providers (CRP) 18 VAC 115-40-10 et seq. in the interest of public safety.  We are made up of professionals that were active at the inception of the regulations in the early 1990’s and professionals appointed in recent years to revise the Vocational Rehabilitation Guidelines of the Virginia Workers’ Compensation Commission (VWC) effective in October 2015.

 

The regulations were originally conceived in the early 1990’s following a Joint Legislative Audit & Review Commission study ordered by Lieutenant Governor Don Beyer concerning the Virginia Workers’ Compensation Commission.  At that time the Citizens of the Commonwealth were endangered by rehabilitation professionals practicing without the appropriate skill set and/or experience.  The Regulations Governing the CRP set forth Standards of Practice in 18 VAC 115-40-40.  The Standards of Practice were drafted with the primary purpose of promoting the safety and welfare of the Citizens of the Commonwealth.  Furthermore, the regulations establish education and supervision expectations that require rehabilitation professionals to hold nationally recognized designations in the field of rehabilitation or be eligibile by virtue of education and experience to test for such designations.  These national certification designations also have a Code of Ethics which expand on the protections offered by the Standards of Practice outlined in the regulations.

 

The regulations are also concurrent with the statutory guidelines outlined in §§  54.1-2400 and Chapter 35 of Title 54.1 of the Code of Virginia. They ensure that the Citizens of the Commonwealth receive assistance from experienced professionals to advocate for their rehabilitation needs.  The Citizens requiring these services are already vulnerable by virtue of their impairments and without skillful assistance would be at risk to be further disenfranchised by the rehabilitation process.

 

Thank you for your careful consideration of our comments and concerns.  We believe our Citizens deserve the best possible opportunity to overcome the challenges of disability.

 

Respectfully,

 

Phyllis Carmichael

Phyllis Carmichael RN, MSN

IARP VA President

 

 

Linda F. Augins

Linda Augins, MA, CRP, CCM, CDMS, CRC

IARP VA Past President

 

 

Barbara Byers, MA, CRC, CVE, CCM, LPC

IARP VA President Elect

Legislative Special Committee Member

 

Patricia S. Eby

Patricia S. Eby, MS, RN, CNS, CRC, CDMS

IARP VA Secretary

Former Committee Member Appointed by The Honorable Commissioner Roger Williams

 

George Moore

George Moore, MA, CRC, LPC

IARP Treasurer

Legislative Special Committee Member

 

 

Adolfo Arsuaga

Adolfo Arsuaga, MS, CRC

Northern Virginia Representative to IARP VA

 

 

 

 

Robin T. Allen

Robin T. Allen, BS, CDMS, CRP

Richmond Virginia Representative to IARP VA

 

Dawn Bell

Dawn Bell, MRC,CRC,CRP

Southwest Virginia Representative to IARP VA

 

Gretta Waugh

Gretta Waugh, MS, CRP, CRC

Tidewater Regional Representative to IARP VA

 

 

Lori A. Cowan

Lori A. Cowan, MS, LPC, LMFT, CRC, CLCP, ABDA

IARP VA Legislative Chairperson

Former Chairperson of Committee Appointed by The Honorable Commissioner Roger Williams

 

 

Eleanor Fukushima

Eleanor Fukushima M. Ed, CRC

Legislative Special Committee Member

Former Committee Member Appointed by The Honorable Commissioner Roger Williams

 

Patricia H. Bulifant

Patricia H. Bulifant, RN, CRRN, CCM, CLCP, CRP

Legislative Special Committee Member

Former Committee Member Appointed by The Honorable Commissioner Larry Tarr

 

Cc:     The Honorable Robert A. Rapaport, VWC