On behalf of the Virginia Chapter of the American Massage Therapy Association, I am writing to provide comment to the proposed revisions to the regulations governing the Certification of Massage Therapists.

Our association is supportive of the proposed revisions. Removing the categorical classification of types of continuing education courses required to maintain certification is consistent with our national nomenclature for continuing education for massage therapists. Regarding continuing education, we raise only one question and that is related to the numbers of continuing education hours that will be provided for completing a course in cardiopulmonary resuscitation (18VAC90-50-75 A 2 b). Do the regulations need to specify how many hours will be allocated for the course, or will CMTs calculate the number of hours themselves on a 1:1 ratio or another ratio established by the Board of Nursing?

Finally, we are supportive of the additional language in 18VAC90-50-90 1 d pertaining to boundary violations. Thank you for clarifying and standardizing this language.

If you have any questions, do not hesitate to contact me.

Yours In Health,

Lucia A Kaestner, CMT

AMTA VA President