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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5/21/25  12:45 pm
Commenter: Sarah DiDomenico

Concerns about removal of regulations
 
Active Practice Regulations 18VAC85-80-10
 

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. 

CommentID: 236105