Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Physical Therapy
 
chapter
Regulations Governing the Practice of Physical Therapy [18 VAC 112 ‑ 20]
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5/10/22  3:59 pm
Commenter: Andrea Crunkhorn

Strongly oppose
 

There are multiple problems with this petition. It seeks to impose blanket, punitively enforced sanctions on all physical therapy practices in Virginia; force the abandonment of all masks for any reason, "...including when following policies of insurers or organizations or when following guidance issued by the Centers for Disease Control, local health departments, or the Virginia Department of Health..."; and preemptively deny these practitioners the ability to check vaccination status, presumably in perpetuity.

  1. Physical therapists, their practices or facilities, and their insurers will face reimbursement, coverage and or malpractice issues by not following insurance company and public health guidelines.
  2. These facilities and clinics put their business practices at risk by
    1. exposing their staff to known and predictable occupational hazards (an OSHA complaint),
    2. likely increased staff absenteeism from illness, with associated lost revenue,
    3. exposing their practice to lawsuits from anyone who can presumptively trace their disabling infection or disease to the practice's lack of protections for staff, patients and others.

Other aspects of this petition suppose a problem that does not exist. Physical therapy services do not routinely query vaccination status for patients. However, in the event of a different pandemic, this should not be explicitly disallowed for all the reasons stated above. Denying physical therapy clinics a future ability to protect their staff, other patients, and the business is unwarranted.

The final issue with this petition is that it is punitive. It is known that not all patients can wear a mask. Most clinics recognize and work with patients to enable their access to care while not exposing all others to unneeded risk.

This petition is a missed opportunity. Rather than creating solutions such as asking practices to post their policies publicly, designating a therapist or space for those unable or unwilling to wear a mask, or creating a task force to determine the need for an expanded solution set, this petition is asking physical therapy clinics to expose their staffs, patients and businesses to a known health risk with punitive enforcement that will ultimately cost all Virginians in terms of access to effective and efficient healthcare.

 

CommentID: 121984