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.

As someone who has had to take extended periods of time off in the past, the proposed amendments make me wary to continue working in this state. Adding an additional barrier to reentry into the field will disproportionately affect disabled practitioners - voices who are so direly needed in this profession. Some patients need a practitioner who has been in their shoes before. Our healthcare system is already stretched thin. Adding an additional barrier means fewer practitioners to meet the occupational therapy-related needs of Virginians.

Thank you for your consideration.

Sincerely,

Jamie H., OTR/L