Action | General Review 2014 |
Stage | Proposed |
Comment Period | Ended on 2/12/2016 |
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EXHIBIT G
"If you recall, when the VDH representatives spoke at our very first work group meeting they then vaguely spoke of the plan for the SHIFT. VDH basically said that they would be unwilling to provide much input to our WWWOOSOP Work Group meeting until after the SHIFT meeting started and some progress was made. If you recall, I actually point blank asked Allan Knapp, “So you are telling DPOR that they should just wait until VDH gets back to them?” In fact that is exactly what they were saying. The DPOR Administrative staff said we could not do much more at that point. I was shocked and quite honestly embarrassed how the whole thing was handled. So please don’t tell me that I am “acting in a manner that leaves you without representation” or that “I should begin to speak for my peers”. My friend, I have spoken many times and it appears that my voice has fallen on deaf ears sometimes. I have more than once conveyed my frustration to the DPOR Administrative staff. [emphasis added] -Brook Philpy March 1, 2014 correspondence
"I just recently asked the DPOR Admin Staff if there is any way possible to proceed with developing standards of practice without VDH. I have not received an answer yet. My guess is they will respond by saying that DPOR cannot regulate another agency out of business. In case you have not figured it out yet, this has become a very complicated process with no clear resolution in sight. But, I have not given up. -Brook Philpy March 1, 2014 Correspondence" [emphasis added] -Brook Philpy March 1, 2014 correspondence
Does this board regulate individuals or agencies?
The largest design firm in the state will not allow DPOR to maintain oversight over licensed professionals? This is why you can not have an executive branch agency being an active market participant while regulating the work of it's competitors. In essence, the VDH influenced the Board under Commerce and Trade to not have consistant standards of practice. This is classic behavior of Bainian Market power exhibited by a monopolist.
I applaud the board for incorporating 18VAC160-40-470. Prohibited acts into the proposed regualtions.