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.