Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Medicine
 
chapter
Regulations Governing the Practice of Occupational Therapists [18 VAC 85 ‑ 80]
Action Elimination of active practice requirement for renewal
Stage Fast-Track
Comment Period Ended on 5/21/2025
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Previous Comment     Back to List of Comments
5/21/25  10:12 pm
Commenter: Dana Larson

Removal on active practice requirement
 

While meeting requirements for active practice may be inconvenient in certain scenarios, we  are talking about an active skillset that requires active maintenance. While knowledge and ability of practice skills and strategies can be maintained in a number of ways, clinical licensure is not symbolic and should not be afforded to those who aren’t in good standing with best practice- which requires clinical engagement. Therefore, the board of medicine is not obligated to make licensure easy- in fact it is mandated to protect patients through monitoring clinician ability.  While I don’t necessarily oppose identification of solutions to outlier needs, fast tracking this decision neglects due deliberation for alternate methods to prove clinical competence. 

CommentID: 236222