I wish to concur with the comments offered by Mike Campbell and Karl Rudolph posted 2/12/09 regarding the interim licensure of VDH staff with multiple years of experience. 

As a side note, when the AOSE program first was implemented, experienced VDH onsite staff and private practitioners, who had been through the VDH training and testing regimen in place at that time, were allowed to submit application, references, and a fee to VDH and were granted AOSE status.  To my knowledge, there was no need for additional field or written testing at that time.  Many of these folks are still practicing AOSEs and have maintained their license without the requirement of additional written and field testing. 

 At that time many VDH onsite staff were not required to be licensed, and therefore did not feel it necessary to apply for certification.  Thoughtful regard should be given to those experienced VDH staff, who have remained practicing under the VDH umbrella, and granted interim licensure without the burden of additional testing.

Respectfully submitted,    Amy Pemberton, VDH