April 23, 2025

Erin Barrett

Director of Legislative and Regulatory Affairs

Virginia Department of Health Professions

Perimeter Center

9960 Maryland Drive, Suite 300

Henrico, VA 23233

RE: Support for Proposed Amendments to 18 VAC 85-80-72 and 18 VAC 85-80-80

Dear Director Barrett:

I am writing on behalf of the National Board for Certification in Occupational Therapy (NBCOT) to express our strong support for the proposed amendments to the occupational therapy regulations related to Inactive licensure (18 VAC 85-80-72) and Reinstatement (18 VAC 85-80-80).

NBCOT's mission is to protect the public through the validation of essential competencies for effective and safe occupational therapy practice. This mission directly aligns with the regulatory board's objective of protecting public health and safety. 

Public protection is valued by the over 275,000 certified occupational therapy practitioners we represent, the occupational therapists that lead our association, and certainly by the millions of healthcare clients they serve, as a matter of public safety. We believe the Virginia Board of Medicine shares this fundamental value and commitment to public protection.

The proposed requirement that practitioners seeking reinstatement after a two-year lapse demonstrate current NBCOT certification or retake the exam serves a vital public protection function. This standard ensures that returning practitioners possess up-to-date knowledge and skills in a profession where evidence-based practices, therapeutic techniques, and safety protocols continue to evolve rapidly.  

Maintaining NBCOT certification is both accessible and affordable for practitioners. The renewal fee is only $65 for a full three-year certification cycle, making it a reasonable investment in one's professional standing. This modest cost helps ensure that the requirement is not financially prohibitive for those seeking to return to practice.

Multiple states already recognize the value of maintaining NBCOT certification and accept evidence of current certification as a means of meeting licensure requirements for continued professional development. South Carolina, for example, requires all licensees to maintain their NBCOT certification throughout their professional careers, demonstrating that this approach is both practical and beneficial to public protection.

Beyond meeting regulatory requirements, NBCOT certification provides practitioners with numerous benefits, including:

• Access to continuing education resources and professional development tools
• Recognition of meeting national standards of practice
• Enhanced professional credibility with employers and clients
• Inclusion in the NBCOT certification verification database, which is publicly accessible
• Opportunities for professional networking and engagement with the broader OT community

While we understand concerns about requirements for practitioners returning after absence, we believe this requirement strikes an appropriate balance between professional accessibility and public safety. The NBCOT certification process is specifically designed to verify that practitioners meet the established standards of practice necessary for safe and effective care.

This requirement aligns with growing national trends for practitioners who have been working in other states. For those returning after personal circumstances like illness or family emergencies, the certification requirement ensures they are fully prepared to provide safe, high-quality care upon their return while remaining financially accessible.

We believe this requirement represents a reasonable safeguard that benefits both the public and the profession by maintaining high standards of practice. The NBCOT remains committed to working with the Virginia Board of Medicine, practitioners, and professional associations to support the successful implementation of these amendments.

Thank you for considering our perspective on this important matter. Of course, we will make ourselves available for any future meeting to discuss the language or NBCOT’s position. Please contact me at bprice@nbcot.org or 240-658-0285. 

Sincerely, 

Ben Price, CAE, ICE-CCP

President and CEO

National Board for Certification in Occupational Therapy