I am a recently retired OT who is planning on maintaining my license.  However, OT/OTA applicants let their license lapse for many different reasons.  They may be caring for a elderly parent or young child, etc.  Two years is a very short period of lapse in practice and licensure renewal. After such a short period as 2 years for non-renewal, or 6 years inactive, it does not make sense to require an OT or OTA to take the practice exam again.  It would be prohibitive to many OTs and OTAs seeking to renew their license if  they had to maintain NBCOT certification or to have to take the exam again.  It may prevent many from being able to return to the field of occupational therapy.  This is would not be helpful due to the current shortage of OTs and OTAs.  In addition, NBCOT certification is not a requirement for OT /OTA licensure in Virginia . Therefore it should not be required for renewal of lapsed licenses.  I request that the VA Board of Medicine review and reject this proposal. AOTA and VOTA are also against this proposal.