December 19, 2025

Erin Barrett

Director of Legislative and Regulatory Affairs

Board of Medicine

Perimeter Center

9960 Mayland Drive, Suite 300

Henrico, VA 23233

RE: Comments on proposed occupational therapy regulations 18VAC85-80-72 and 18VAC85-80-80

Dear Ms. Barrett:

The American Occupational Therapy Association (AOTA) is the national professional association representing the interests of more than 213,000 occupational therapists, occupational therapy assistants, and students of occupational therapy, including 1164 members in Virginia. The practice of occupational therapy is science-driven, evidence-based, and enables people of all ages to live life to its fullest by promoting health and minimizing the functional effects of illness, injury, and disability. AOTA supports the Board of Medicine and the Occupational Therapy Advisory Committee in its mission to protect the health, safety, and welfare of Virginia consumers and the authority of the Board to create regulations to achieve this mission.

On behalf of AOTA, I am writing to provide comment on the proposed changes to 18VAC85-80-72 and 18VAC85-80-80. AOTA supports the proposed changes as they offer licensees seeking to reactivate their license and former licensees seeking to reinstate their license multiple pathways to do so as well as multiple pathways to demonstrate competency. Providing multiple options to reactivate or reinstate a license respects the fact that individuals become inactive or let their license lapse for differing reasons, protects the public by ensuring access to occupational therapy services, and supports the Governor of Virginia’s priority of removing barriers to practice regulated professions.

Thank you for the opportunity to comment on the proposed changes and if it would be helpful, we could be available at a future meeting to discuss our proposal. Please contact me at kneville@aota.org or 240-800-5981 if you have questions or need additional information about AOTA’s position.

Sincerely,

Kristen Neville

Manager, State Affairs

cc: Savanah Howe, OTR/L, QMHP-A, President, Virginia Occupational Therapy Association