To the Board of Medicine:

I am writing to express my concerns about the proposal to amend the occupational therapy regulations related to Inactive licensure (18 VAC 85-80-72) and Reinstatement (18 VAC 85-80-80). Considering that shortage of Occupational Therapists in VA, it doesn't make sense to make it more difficult to renew an OT license. I encourage the Board to engage in a dialog with the American Occupational Therapy Association and the Virginia Occupational Therapy Association to put in place regulations that are not too onerous for occupational therapy practitioners, but that also protect the public. Requiring someone seeking to rejoin the profession whose license has been lapsed for only 2 years to show a current NBCOT certification or retake the exam is a lot to ask of someone who might be switching jobs after working in another state or recovering from an illness or family emergency. Thank you for your consideration.

Sincerely,

Marit Simenson