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). 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.

This is especially impactful to women in the sandwich generation, those of us with elder parents and young children at the same time. Our field is one of the few science careers that is dominated by women who already face obstacles in terms of childcare disproportionately to our male colleagues in the healthcare field, and creating unnecessary, costly, time consuming barriers prevents equitable access and re-entry into a field where we have already earned our places.

Thank you for your consideration.

Sincerely,