Dear Regulatory Board,

I can understand that creating regulations is a difficult and arduous process and therefore, I commend you for your hard work on the PT Direct Access regulations thus far. 

However, I am concerned about the portion of the regulations that require additional continuing education (4 hours per biennium) directly related to practicing in the direct access setting.  To qualify to apply for "Direct Access Certification" initially a PT who does not have a DPT is required to complete 15 hours of continuing education/training in Medical Screening or Differential Diagnosis and they must pass a post-course examination.  I feel that this is sufficient.  Our current regulations for PT license renewal (regular license to practice) requires 30 hours of continuing education per biennium for PT's.   I do not feel that an additional 4 hours or requiring course work specifically related to Direct Access should be required to renew your DA Certification.  Most of the courses that I have attended in the past 2-3 years have been Evidence Based Practice courses.  In these courses there has been adequate time devoted to medical screening, red flags, etc., allowing me to remain current in practice that is safe, effective and backed by research.  It is my opinion (as well as the opinion of several colleague with whom I have spoken) that the additional 4 hours of continuing education that has to relate to practicing in the DA setting is unnecessary for clinicians to maintain best/safe practice, even when practicing under direct access legislation.  Therefore, I would request that this portion of the regulations be deleted.

Sincerely,

Terri S. Ferrier, PT

Terry, the first commentor has made excellent points.

Dr. Samuel Peters
Osteopathic Physician
"Good health is all in the mind"
 

I appreciate the explained purpose of the application fee - without it, I would be opposed to any fee at all. That said, I agree with the reduction in fee. I feel that it should be as minimal as possible. It would be a shame if the monetary issue acted to deter providers from obtaining direct access certification. 

Regulatory Board,

I feel the decrease in fee for Direct Access Certification is a good gesture, however, having to pay a fee just to be able to have the state say it's okay to see people without a prescription along with having to continue to pay a fee to keep it doesn't really feel like true direct access.  If I meet the requirements for it and cont to pay for the increased cont edu requirements, why can't my license be marked to show the difference and no increased fees be imposed or at least just a one time fee? 

The other fact that needs to be considered is right now this Direct Access designation gives me no real advantage in having it since insurance companies (inlcuding medicare) still won't reimburse without a doctor's prescription, so where is my ability to bring in more money to pay for this designation along with the cont edu, when I am still needing a doctor prescription.  Right now this designation is a good start, but until laws and reimbursement changes are made for direct access to truly be direct access, for some the cost of getting and maintaining this designation for nothing other than professional self-esteem won't be worth it.

I am in agreement with Terry.   The CE courses now available provide quality evidence based and practice skills within the DA environment and address our advancing professional needs.  It seems an additional, unnecessary requirement and another hoop to jump through in order to see direct access clients.  For those of us who hold other professional certifications also requiring CEUs, this  additional physical therapy CE requirement becomes a deterent for maintaining (or for that matter, obtaining) DA certification.  I encourage the board to reconsider this proposed requirement.   
 

VPTA appreciates the amount of time and effort already contributed to these regulations. At this time we only have one comment for change to the emergency regulations based on multiple comments from member review of the emergency regulations.

Section 18VAC 112-20-131 Continued competency requirements for renewal of an  active license – item I. that currently states:

I. Physical therapists holding certification to provide direct access without a referral shall include four contact hours related to carrying out direct access duties as part of the required 30 contact hours of continuing education. Courses for direct access continuing education shall relate to clinical practice in a direct access setting.

Our members have expressed concern that this statement as written will be overly burdensome to complete for renewal of the direct access certification. It will be confusing and challenging to track a specific number of hours related to areas such as medical screening and differential diagnosis within clinical courses. We would ask that the number of hours be removed and that the language be a statement that the PT must complete continuing education related to clinical practice in the direct access setting as part of the 30 contact hours. If audited, the licensee could then provide copies of the course objectives that would reflect that elements related to direct access had been included in these clinical courses.