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  10:11 pm
Commenter: Savanah Howe

Concern about active practice removal
 

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.

CommentID: 236219