As a physical therapist practicing in this state I have been closely following the recent changes occurring with our practice act and regulations.  I am especially concerned with the current emergency regulations proposed by the Board of Physical Therapy and would like to voice these concerns to you. 

The section on continued competency requirements related to carrying out direct access duties goes beyond the current law in several ways.  As I understand it, I am required to provide evidence of continuing education related to carrying out direct access duties in order to be initially certified.  Nowhere in the law do I see it stipulated that we need to be recertified.  Why is the PT Board introducing the concept of recertification-  Beyond simply imposing the burden of recertification on us, the Board is also getting even more specific about the type of continuing education that will be required as part of the recertification process.  By specifying that “four contact hours related to carrying out direct access duties” shall be part of the process, the Board has moved even further into regulating a process that is not even mentioned in the law.  I am questioning your reasoning in implying that four hours of such education every two years will truly make any substantial difference in my competence or consumer safety.  Is there a precedence after which you are modeling this concept-  Have you considered the difficulty I will most likely encounter in finding such a course-  I have enough agencies and organizations imposing senseless and burdensome requirements on me without my own PT board adding to them.

Lastly, I am somewhat dumbfounded with the proposed fees associated with certification and recertification.  I would have never expected such a large sum be proposed as I would not imagine this process could possibly cost that much to administer.  Eliminating the recertification process for reasons mentioned earlier would resolve that fee.  That aside, I do not understand how you can justify charging someone such an exorbitant fee for simply reviewing a document:  DPT, TDPT, or suitable continuing education.  I realize there is an advisory committee involved in all this which ads to expense, but I would submit that it cannot possibly cost that much.  It seems that you are setting yourselves up to return money to licensees with fee reductions, as you have in the past, when a profit is realized.  The only problem with that in this situation is that not all licensees will have contributed to a direct access certification windfall, making it unfair to allow a discount to all. 

I appreciate the work of all the Board members on this as well as other issues.  I also appreciate your consideration of these items, and would ask that you not make this already burdensome and convoluted legislation even more problematic for licensees in this state. 

Respectfully,

Colleen Whiteford, PT, OCS