Jay Douglas, R.N.

Department of Health Professionals 

Executive Director 

9960 Maryland Drive 

Suite 200

Richmond, VA  23233

Re:  Public Comment Regulations Governing the Licensure of Massage Therapists [18 VAC 90  50]

Dear Mr. Douglas.

Thank you for reviewing open comments during the period for the review of the regulations.

My comment is regarding this section of the code:   

18VAC90-50-70 Renewal of certification

Clarify that if a license is lapsed, one may not use the title of massage therapist and may not practice massage therapy.

The delay in submitting the renewal or the lapse in the submission does not negate the practitioner’s competence to practice massage therapy nor does it demote them back to a massage practitioner.  

The notification for renewal is sent to the therapists two months in advance of the expiration date. It is our professional responsibility to remain in compliance with the code.  However if circumstances do arise, then the renewal submission may be delayed. Please consider 1. To scratch the second clause “and may not practice massage therapy”  and 2. Add a graduated lapse period for the application to be submitted to include a fee.  

Proposed fee for lapse:

7 days no fee

30 days $25.00 late fee

Thank you for your time and attention.

Bernadette Binns Blount

LMT