Dear Virginia Board of Medicine,

I write today to ask you to take pause and collaborate with the American Occupational Therapy Association (AOTA) and the Virginia Occupational Therapy Association (VOTA) prior to taking action to amend the occupational therapy regulations related to inactive licensure (18 VAC 85-80-72) and Reinstatement (18 VAC 85-80-90). The current proposal to require someone seeking to rejoin the profession who's license has lapsed for 2 or more years to show a current NBCOT certification or retake the exam is excessive and may discourage providers' who's Virginia OT license has lapsed from making the efforts to reinstate it. There are many reasons a provider may choose to go inactive or let their license lapse, from moving temporarily to another state, to experiencing a health crisis, to taking time away to raise a family. We of course want to protect the public and ensure all OT providers are qualified to practice, but I ask you to please reconsider the existing proposal and enter talks with organizational leaders at VOTA and AOTA to ensure our state code is in alignment with realistic and modern best practices. 

Thank you,

Caitlyn