I support this regulatory action. I believe it will support practitioner's ability to reenter the workforce who may be hesitant to do put forth the effort to get the supervisory hours that are currently required to be eligible for acquiring a new license if it were to lapse. 

Removing these regulations would make it easier to reenter the workforce, simplify across state licensure and potentially support the licensure compact, and address provider shortages. However, active practice requirements do allow for prioritization of competency and safety of the clients/patients served. These regulations ensure skill maintenance and clinical competence, public protection, and professional accountability and rigor. An alternative to completely removing this regulation could be adopting a middle path in VA such as removing practice hour requirements, but requiring targeted continuing education or reentry programs for long absences to maintain clinical competence and rigor. 

Pros:

I appreciate that this proposed regulatory change would make it easier for occupational therapists to keep their licenses active, especially for those who have taken time away from work for important personal reasons such as parental, family, or medical leave. Allowing for a break of up to two years without losing active license status supports work-life balance and makes it easier for qualified practitioners to return to the field.

Cons/Considerations:

However, I have some concerns about the lack of a requirement for recent active practice when renewing a license. Without any limit on how long someone can be away from practice and still maintain an active license, there’s a risk that individuals may return to work after many years without recent experience or oversight. Given how quickly healthcare practices can change, I encourage the inclusion of additional safeguards, such as reentry requirements or updated competency checks, to help ensure all returning practitioners are well-prepared to provide safe, effective care.

My concern is for the well being of clients if someone maintains an active license, but doesn’t actively practice for more than 2 years.  If there is no safe guard or supervision to return to practice then all we have is to hope that the company hiring these practitioners provide mentoring and competency validations.

I would appreciate consideration of a finite number of years you can maintain a active license, but not active practice.

Thank you.

Hello. I agree that requiring active practice for each renewal cycle can create unnecessary challenges for practitioners who step away from caregiving. My concern is that with no active practice requirement, a practitioner could maintain an active license with an unlimited number of years away from practice and have no additional competency requirements compared to someone who has been actively practicing every year. In the rapidly changing landscape of healthcare, many years without active practice could impact a practitioner's ability to provide high quality OT services upon their return.  I object to the use of fast track for this regulatory action as I believe it requires more consideration.

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.