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 an excessive and unnecessary requirement of someone who might be switching jobs after working in another state, recovering from an illness, taking time away from active practice to raise children, or a family emergency. In addition, in VA it is not required to maintain national board certification through NBCOT in order to practice occupational therapy. Thank you for your consideration.

Sincerely,

Helen Cluff, OTR/L