Dear Director Barrett:

On behalf of the National Board for Certification in Occupational Therapy (NBCOT), we respectfully oppose the proposed amendments to 18 VAC 85-80-72 and VAC 85-80-80. 

NBCOT's mission is to protect the public through the validation of essential competencies for effective and safe occupational therapy practice which directly aligns with the Board's objective of protecting public health and safety.

NBCOT certification provides a rigorous, standardized assessment of practitioner competence, including passage of the national examination, adherence to a professional code of conduct, and completion of 36 units of professional development per renewal cycle. For practitioners seeking to reinstate a lapsed license, maintaining NBCOT certification support public protection by ensure they demonstrate appropriate knowledge and skills before returning to practice.

Maintaining NBCOT certification is both accessible and affordable. The renewal fee is $65 for a three-year-renewal cycle. This modest cost helps ensure the requirement is not financially prohibitive for those seeking to return to practice. 

Multiple states recognize the value of maintaining NBCOT certification and accept evidence of current certification as a means of meeting licensure requirements for professional development. For example, South Carolina requires all licensees to maintain their NBCOT certification throughout their professional careers, and D.C. has instituted statues/regulations that require NBCOT certification after a lapsed license.

Requiring NBCOT certification for reinstatement after an extended absence aligns with growing national trends for practitioners who have been working in other states. For those returning after personal circumstances such as family emergencies or illness, the certification requirement aids in ensuring they are prepared to provide safe, competent care upon their return while remaining financially accessible.

While the proposed amendments introduce alternative pathways for reactivation or reinstatement, these proposals do not uniformly ensure the same level of standardized, objective assessment as NBCOT certification.

We welcome collaboration with the Occupational Therapy Advisory Board to support licensure frameworks that protect the public and sustain a competent, qualified occupational therapy workforce. Please contact us by phone (301-990-7979) or email (am@nbcot.org or bwilliams@nbcot.org) if you require further information.

Sincerely,

Angela Macauley, President and CEO                                Barbara Williams, Vice President of 

                                                                                            External and Regulatory Affairs