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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
IARP—International Association of Rehabilitation Professionals
1000 Westgate Drive, Suite 252 Phone: 888-427-7722
St. Paul, MN 55114 Fax: 651-290-2266 www.rehabpro.org
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,
This is a letter of support for VA 18 VAC 115-40-10 et seq.; the Regulations Governing The
Certification of Rehabilitation Providers (CRP) in the interest of public safety. The International
Association of Rehabilitation Professionals (IARP) was founded more than 30 years ago to promote the betterment of people with disabilities and the professionals who serve them. IARP represents more than 2,400 rehabilitation professionals worldwide. Our VA chapter and sent a separate letter of support for the above regulations and the national/international association also wanted to support these regulatory changes to protect the citizens of the Commonwealth of VA.
Our VA section members are seasoned rehabilitation professionals who have served the VA citizens with disabilities for decades practicing in small, mid-size and large companies across the
Commonwealth. IARP VA was active at the development of the WC regulations in the early 1990’s and several of our members were been appointed 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 of VA. Furthermore, the regulations establish education and supervision expectations that require rehabilitation professionals to hold nationally recognized designations in the field of rehabilitation or be eligible 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,
Amy Vercillo ScD, LRC (MA), CRC, CDMS
National Legislative Chair, IARP