I had planned to renew my OT license in September of 2024. I took the required CEU's and when I attempted to complete the renewal process, I saw that there was a requirement that I had worked a certain number of hours in the previous 2 years. Since I had closed my office in Northern Virginia during the pandemic and had moved to Richmond in June of 2023, I did not meet the requirement and was not able to renew. This was a big shock and disappointment.

I have heard that there is an effort underway to change that regulation. This is encouraging news as I would like the opportunity to resume my work. Since my understanding was that I only needed the Virginia OT license to practice in this state, I allowed my NBCOT certification to lapse last March. Now I have heard that national certification is necessary for licensure reinstatement. I am hoping that the board will be able to create a pathway for OT's in my situation. I am an experienced practitioner and have a lot to offer. I would like to have my license reinstated.

Thank you for your attention.

April 18, 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: Comments on proposed amendments to 18 VAC 85-80-72 and 18 VAC 85-80-80

Dear Ms. Barrett:

The American Occupational Therapy Association (AOTA) is the national professional association representing the interests of more than 213,000 occupational therapists, occupational therapy assistants, and students of occupational therapy, including 1417 members in Virginia. The practice of occupational therapy is science-driven, evidence-based, and enables people of all ages to live life to its fullest by promoting health and minimizing the functional effects of illness, injury, and disability. AOTA supports the Occupational Therapy Advisory Board of the Board of Medicine in its mission to protect the health, safety, and welfare of Virginia consumers and the authority of the Board to create regulations to achieve this mission.

On behalf of AOTA, I am writing to provide comment on the proposed changes to the Board’s inactive status, 18 VAC 85-80-72, and reinstatement requirements, 18 VAC 85-80-80. As you know, the proposed amendments remove the requirement for completion of a certain amount of supervised practice hours for individuals seeking to reactivate an inactive license or reinstate a lapsed license. Instead, an individual whose license has been inactive for six years or more and an individual whose license has been lapsed for 2 years or more would be required to either show evidence of current certification from the National Board for Certification in Occupational Therapy (NBCOT®) or retake and pass the NBCOT certification exam. This new requirement is problematic in several ways:

• First, if a licensee converts their Virginia license to inactive status or allows their license to lapse because they have accepted a job in another state, then showing evidence of current licensure in that other state should be sufficient to demonstrate competency to return to practice in Virginia. For example, many AOTA members live in Virginia but are employed and licensed as occupational therapy practitioners in the District of Columbia and Maryland.
• Second, licensees convert their license to inactive or let their license lapse for many reasons, including illness, family emergency, or loss of a job. It would be financially onerous to require someone who is seeking to reactivate a license or re-enter the profession after such an occurrence to then re-take and pass the NBCOT exam at a cost of several hundred dollars. There could also be a situation where a recent graduate of an OT or OTA academic program obtains a job in Virginia for a brief period of time, then takes a job in another state, only to have to resume practice in Virginia. The rules as proposed would require this individual to have to re-take the NBCOT exam when they passed it for the first time only several years before.
• Third, since Virginia does not require current NBCOT certification to renew a license, many licensees in the state might chose not to renew their NBCOT certification for this reason, in which case they would have to retake the exam if they need to reinstate their license. Furthermore, according to NBCOT’s website, “beginning January 1, 2027, any individual who has allowed their certification to lapse for 9+ years must submit a completed application and fee of $515 USD, undergo a background check, and pass the current entry-level NBCOT certification exam.”
• Fourth, AOTA’s official document Guidelines for Reentry Into the Field of Occupational Therapy  recommends that regulators require supervised hours of practice be completed if a license has been lapsed for at least three years, not two as is proposed in the Virginia regulation. See below:

4. For practitioners who have been out of practice for 3 or more years, complete a minimum of 10  hours of documented supervised service delivery in occupational therapy for each year out of practice, to a maximum of 80 hours.

• Fifth and last, in 2017, the Virginia legislature passed and the Governor signed H 1484 (Chapter 411) to prohibit the Board of Medicine from determining that current certification from NBCOT, AOTA, the Virginia Occupational Therapy Association, or any state or local government agency as “sufficient to fulfill continuing learning requirements for occupational therapists.” See below:

Be it enacted by the General Assembly of Virginia:

§ 2. That the Board of Medicine shall not deem maintenance of any certification provided by the Virginia Occupational Therapy Association; the American Occupational Therapy Association; the National Board for Certification in Occupational Therapy; a local, state, or federal government agency; a regionally accredited college or university; or a health care organization accredited by a national accrediting organization granted authority by the Centers for Medicare and Medicaid Services to assure compliance with Medicare conditions of participation as sufficient to fulfill continuing learning requirements for occupational therapists.

Since retaking the NBCOT exam or maintaining current certification with NBCOT is proposed to replace completion of supervised practice hours, and the supervised practice hours were intended to serve as continuing learning for individuals who have been out of the profession, we believe that the Board’s proposed regulation conflicts with the statute.

We propose that the Board delete the revision to 18 VAC 85-80-72 Inactive licensure that would require an occupational therapist or occupational therapy assistant to provide evidence of current certification with NBCOT and replace it with the following amendments:

B. An inactive licensee may reactivate his license upon submission of the following:3. If the license has been inactive for two to six years, documentation of having engaged in the active practice of occupational therapy or having completed a board-approved practice of 160 hours within 60 consecutive days under the supervision of a licensed occupational therapist; and

4. Documentation of completed continued competency hours equal to the requirement for the number of years, not to exceed four six years, in which the license has been inactive; or

4. Evidence of licensure in another state or jurisdiction during the inactive licensure period.

C. An occupational therapist or occupational therapy assistant who has had an inactive license for six years or more and who has not engaged in active practice, as defined in 18VAC85-80-10, shall  serve a board-approved practice of 320 hours to be completed in four consecutive months under the supervision of a licensed occupational therapist shall retake and pass the national exam.

We also propose that the Board delete the revision to 18 VAC 85-80-80 Reinstatement that would also require an occupational therapist or occupational therapy assistant to provide evidence of current certification with NBCOT and replace it with the following amendments:

B. An occupational therapist or occupational therapy assistant who has allowed his license to lapse for two years but less than six years, and who has not engaged in active practice as defined in 18VAC85-80-10, shall serve a board-approved practice of 160 hours to be completed in two consecutive months under the supervision of a licensed occupational therapist meet the continuing competency requirements of 18VAC85-80-71 for the number of years the license has been lapsed, not to exceed six years.

C. An occupational therapist or an occupational therapy assistant who has allowed his license to lapse for six years or more, and who has not engaged in active practice, shall serve a board- approved practice of 320 hours to be completed in four consecutive months under the supervision of a licensed occupational therapist shall retake and pass the national examination.

D. An applicant for reinstatement shall meet the continuing competency requirements of 18VAC85- 80-71 for the number of years the license has been lapsed, not to exceed four years who has engaged in active practice in another state or jurisdiction during the time period the license was lapsed shall provide evidence of licensure in the other state or jurisdiction for the same time period.

These amendments remove the previously required hours of supervised practice for reinstatement applicants, which the Board also proposed, and instead requires applicants who have practiced in another state while their Virginia license was lapsed or inactive to show proof of active licensure in the other state. If the licensee was not practicing in another state, then the licensee is required to complete the mandated continuing competency requirements for the number of years the license was lapsed or inactive to a maximum of 6 years. If the license is lapsed or inactive for longer than 6 years, then the applicant must retake and pass the NBCOT exam.

Thank you for the opportunity to comment on the proposed changes and if it would be helpful, we could be available at a future meeting to discuss our proposal. Please contact me at kneville@aota.org or 240-800-5981 if you have questions or need additional information about AOTA’s position.

Sincerely,

Kristen Neville

Manager, State Affairs, AOTA

cc: Savanah Howe, OTR/L, QMHP-A, President, Virginia Occupational Therapy Association President

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. Thank you for your consideration.

Sincerely,

Josh Adler

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 dialogue 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.  Since an NBCOT certification is not required to maintain a Virginia license, this requirement seems inappropriate.  I understand that we need to protect the public, however, there are other ways this can be accomplished, such as requiring additional continuing education hours. Thank you for your consideration.

Sincerely,

Lesley Winn Phillips, OTR/L

To the Board of Medicine:

I am writing to share my concerns regarding the proposed amendments to the occupational therapy regulations concerning Inactive Licensure (18 VAC 85-80-72) and Reinstatement (18 VAC 85-80-80). I respectfully urge the Board to engage in dialogue with the American Occupational Therapy Association and the Virginia Occupational Therapy Association to develop regulations that both safeguard the public and remain reasonable for occupational therapy practitioners. Requiring individuals whose licenses have lapsed for only two years to present a current NBCOT certification or retake the examination places an undue burden on those who may have been practicing in another state or managing personal challenges such as illness or family emergencies. Additionally this change may impact vulnerable residents throughout the Commonwealth who seek occupational therapy services. Thank you for your thoughtful consideration.

Sincerely,

Leslie Davidson 

To the Board of Medicine,

I am writing to express my concern about the proposal to amend the occupational therapy regulations related to inactive status: licensure (18 VAC 85-80-72) and reinstatement (18 VAC 85-80-80).  As a licensed COTA in the state of Virginia, I have experienced our Board as open minded and in tune with its members. I encourage the Board to open dialogue with AOTA and VOTA to learn what impact requiring an active NBCOT certification will be on OT practitioners whose license has lapsed only 2 years. Thank you for your service to our state and to the professionals you license. 

Respectfully,

Donna Strout, COTA/L

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.

This is especially impactful to women in the sandwich generation, those of us with elder parents and young children at the same time. Our field is one of the few science careers that is dominated by women who already face obstacles in terms of childcare disproportionately to our male colleagues in the healthcare field, and creating unnecessary, costly, time consuming barriers prevents equitable access and re-entry into a field where we have already earned our places.

Thank you for your consideration.

Sincerely,

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. Thank you for your consideration.

Sincerely

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. Thank you for your consideration.

Sincerely,

Teri Gilley

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. Thank you for your consideration.

Sincerely,

Sarah DiDomenico

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. Thank you for your consideration.

Sincerely,

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. Thank you for your consideration. 

Sincerely,

Melissa

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. Thank you for your consideration.

Sincerely,

Angela Geraci

I am writing to express my concerns. Regarding 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 dialogue with the American Occupational Therapy Association and the Virginia Occupational Therapy Association to put in place regulations that are not to 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.

Thank you for your consideration. 

To the Board of Medicine:

I am writing to express my concerns about the proposal to amend the OT 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 dialogue with the AOTA and the Virginia Occupational Therapy Association to establish regulations that are not too onerous for OT practitioners but also protect the public. Thank you.

Sincerely,

Stacy Navarre

To the Board of Medicine:

I am writing to express my deep 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 of pragmatic 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. Furthermore, it creates an additional barrier to re-entering the profession at a time when there is a huge need for skilled occupational therapy practitioners in the workforce. 

Thank you for your consideration.

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. Thank you for your consideration.

Sincerely,

Lydia Navarre 

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. Thank you for your consideration.

Sincerely,

Dr. Krista Poppe, PP-OTD, OTR/L

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 an excessive and unnecessary requirement of someone who might be switching jobs after working in another state, recovering from an illness, taking time away from active practice to raise children, or a family emergency. In addition, in VA it is not required to maintain national board certification through NBCOT in order to practice occupational therapy. Thank you for your consideration.

Sincerely,

Helen Cluff, OTR/L

To whom it may concern:

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. Thank you for your consideration.

Thank you for your attention and time. 

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. Thank you for your consideration.

Sincerely,

Paige Marie Johns, OTD, OTR/L, BCG, CDP

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 VAC85-80-80). 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. 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.

Sincerely,

Dawn Marie LaBree, OTR/L

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. Thank you for your consideration.

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 and OT licensed in Virginia, I feel this requirement may block potential OTs from seeking employment or re-employment in our state. Thank you for your consideration.

Sincerely,

Sarah Sidar, OTD, OTR/L

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 an OT student, graduating in May, I look forward to practicing in my home state. The proposed changes may encourage me to look at other states for employment to ensure that I will be able to meet the requirements to keep my license should it lapse for any reason. Thank you for your consideration

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). Considering that shortage of Occupational Therapists in VA, it doesn't make sense to make it more difficult to renew an OT license. 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. Thank you for your consideration.

Sincerely,

Marit Simenson

 Dear Virginia 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.

Having a therapist  shadow another therapist for 200 hours  was plenty enough when I started practicing after family illnesses again.I am doing quite well and training others.

Thank you for your consideration.

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. Thank you for your consideration.

Sincerely,

Ashley Robinson, MS, OTR/L

Dear Virginia Board of Medicine,

I write today to ask you to take pause and collaborate with the American Occupational Therapy Association (AOTA) and the Virginia Occupational Therapy Association (VOTA) prior to taking action to amend the occupational therapy regulations related to inactive licensure (18 VAC 85-80-72) and Reinstatement (18 VAC 85-80-90). The current proposal to require someone seeking to rejoin the profession who's license has lapsed for 2 or more years to show a current NBCOT certification or retake the exam is excessive and may discourage providers' who's Virginia OT license has lapsed from making the efforts to reinstate it. There are many reasons a provider may choose to go inactive or let their license lapse, from moving temporarily to another state, to experiencing a health crisis, to taking time away to raise a family. We of course want to protect the public and ensure all OT providers are qualified to practice, but I ask you to please reconsider the existing proposal and enter talks with organizational leaders at VOTA and AOTA to ensure our state code is in alignment with realistic and modern best practices. 

Thank you,

Caitlyn

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. Thank you for your consideration.

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. Thank you for your consideration.

Sincerely,

Laura Miear

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. Thank you for your consideration.

Sincerely,

Karen

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 am an OT who recently changed states and know it is a process to get settled in a new state and 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.

Thank you for your consideration. 

Sincerely,

Christine Brown, MS, OTR/L

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.

In 2005, I returned to the profession after a 5-year hiatus as a family caregiver.  I completed the required professional hours shadowing a licensed Occupational Therapist as well as the required continuing education hours.  That process enabled me to update my clinical skills and readied me to re-enter the profession with licensure in Virginia.  The proposed requirement of re-taking the NBCOT OT exam would have been a massive barrier and a strong deterrent to me in returning to this field.

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. Thank you for your consideration.

Sincerely,

Cynthia Webster OTR/L

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 find a solution that both ensures therapists seeking to reinstate licensure in Virginia meet the expected standards but does not include expensive and time-consuming measures for only a 2-year lapse

Sincerely,

Karen Vizaniaris OTD, OTR/L

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 dialogue 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.

Thank you for your consideration.

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. Thank you for your consideration.

Sincerely,

Callie Victor, PhD, OTR/L 

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. Thank you for your consideration.

To the Board of Medicine:

As an occupational therapist and professor of occupational therapy at a VA State University, 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 too much to ask of someone who might be switching jobs after working in another state,  recovering from an illness or family emergency, or serving a term in a public office or military service, especially considering high level of need for skilled practitioners in the Commonwealth. Thank you for your consideration.

Sincerely,

Sarah C. Garrison, DHSc, MOT, OTR/L

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 burdensome 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. Thank you for your consideration.

Sincerely,

Gretchen R. Ward, MS, OTR/L

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. Thank you for your consideration.

Sincerely,

Madison Biggs, OTD/S

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. Thank you for your consideration.

Sincerely,

Paige Moore, OTL

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

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. Thank you for your consideration.

Sincerely,

KERRI HEILMAN, MOT, OTR/L

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. Thank you for your consideration. 

Sincerely,

Rayna Isola, MOT, OTR/L

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. Thank you for your consideration.

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. Thank you for your consideration.

Sincerely,

Dr. Jenna Ruby Holdaway, OTR/L 

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 to 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.  Thank you for your consideration.

Sincerely,

Anne Weybright, MS, OTR/L

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 (18VAC 85-80-72) and Reinstatement (18VAC 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 from emergency. Thank you for your consideration .

Sincerely, 

Sally Walker-Cruden