I have spent many years as a clinical instructor to third year physical therapy students.  Although I do agree that most have been academically bright, some more than others, I do not believe they have the experience level to practice in the direct access environment.  In my opinion the present requirement of three years clinical experience should be required even for physical therapists with their Doctor of Physical Therapy.  If at the very least this could be reduced to two years.  I do think they would benefit from treating patients with referral first to gain necessary experience. 

I have been licensed to practice Physical Therapy in the Commonwealth of Virginia for over twenty years, and I welcome the ability to utilize my professional knowledge and skills for physical therapy evaluation and treatment of the citizens of Virginia under the newly passed direct access regulations.  I am confident that the DPT requirement or the passage of relevant medical screening coursework for experienced PT's (3+ yrs) will ensure adequate recognition of appropriate medical conditions from an academic standpoint.  I believe that entry-level DPT graduates should also have an experiential component to their certification to perform direct access treatment, and suggest at least one year of licensed practice in the Commonwealth as a requisite.  I also do not believe that recertification is appropriate or necessary if one met the crteria for the initial certification. I further believe the addition of a requirement of four hours of coursework for such recertifictaion is also arbitrary and is not needed if the physical therapist is qualified enough to meet criteria for initial certification.

I have been in private practice as a PT in VA for over 20 years and have worked in various settings from out patient to extended care.  My experience of 32 years has allowed me to work and practice in neighboring states which have no such requirement regarding DPT or education ispecifically in the area of differential diagnosis and there is nothing that suggest these states (or VA) are experiencing an increase in complaints of less than desirable or safe care.

I am an advocate for education and believe PT's are some of the best educated professionals in the state when it comes to healtcare.  I do not believe it is necessary to require PT's to take specific course material to practice in direct access manner.  There is nothing anywhere that would support this issue that it is safer when done this way.  At the same time, having to have 4 hours of education specific to direct access every time a license is renewed is also folly.  This requires more time and energy spent by the PT Board which can be best spent in other areas.  It is a waste of time, money and energy.

I am not against education or bettering the profession as well as healthcare.  There is nothing here or that has been shown that anyone can sink their teeth into that shows this will do just that, improve healthcare or the profession.  It will increase costs to the public and will have a tendency to decrease access for patients that already have a limited opportunity of seeing a professional right now.

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

I have been a PT since 1979, first in California, then 12 years in Virginia.  I am happy for the opportunity to be involved n this process, in spite of frustrations with the content. 

I am deeply concerned about the many separations of practice the new legislation is creating within our license. Historically, I sought one of the early Master's programs when there were about 5 or 6 in the country. My program in Texas required a formal thesis with presentation and defense. We were taught to be consumers of research and encouraged to participate. We were taught to respect all licenses equally. After graduation, we were quite cautious to avoid asking higher salaries or priveleges than the experienced bachelors or certificate level therapists. It was primarily a distinction in the academic realm. The natural evolution of change was all that was needed.

At this juncture, there is a dangerous precident which places a new grad years ahead on the judgement scale than experienced PT's. No matter what MD's or  legislators ask, we need to stand firm as a team. It is one thing to require proof of advanced medical screening coursework. A different issue is that of experience.
 If 3 years is the mark, then ALL should be required to have experience. Otherwise, the communtiy of consumers: patients, med practitioners, and other therapists are given a clear message that a new DPT grad has superior skills to experienced therapists.This is confusing and simply false.

Finally, I am opposed to the additional layer of recertification and the inflated fee structure. 
Would a DPT grad need to complete the screening coursework if it has been 2 years since they graduated, before they can obtain an initial certificate?? There is nothing magical about the coursework, and repeating equates to beaurocracy. I believe our time and money will be better spent on other endeavers.

Respectfully,
Pat Salin Huston