To the Board of Medicine:

I am writing to share my concerns regarding the proposed amendments to the occupational therapy regulations concerning Inactive Licensure (18 VAC 85-80-72) and Reinstatement (18 VAC 85-80-80). I respectfully urge the Board to engage in dialogue with the American Occupational Therapy Association and the Virginia Occupational Therapy Association to develop regulations that both safeguard the public and remain reasonable for occupational therapy practitioners. Requiring individuals whose licenses have lapsed for only two years to present a current NBCOT certification or retake the examination places an undue burden on those who may have been practicing in another state or managing personal challenges such as illness or family emergencies. Additionally this change may impact vulnerable residents throughout the Commonwealth who seek occupational therapy services. Thank you for your thoughtful consideration.

Sincerely,

Leslie Davidson