I concur with the proposed change in requirement for the unlicensed graduate seeking a traineeship that the traineeship not be approved until the graduate is scheduled to take the exam - this limits the traineeship to a maximum of 60 days. I do think there needs to be regulation that clearly states how many traineeships can be approved and for how long a period. The graduate can now only take the NPTE 3 times in a calendar year -and then they have to wait. If they have failed 3 times do we really want them still practicing under a traineeship? I don't. I think it should be a maximum of 1 year on a new grad granting multiple traineeships for initial licensure. They will have to petition the board after failing 3 times and provide a remediation plan at that point anyway.

Section 140 - I am in favor of limiting traineeship supervisors to 2 and for the designation and documentation language suggested.

Sectoin 50-D I support the option of a part time traineeship for the foreign educated, with a 2 year window.

Item 6 in the list - PTA traineeships - I support a 320 hour traineeship for the PTA in keeping with their reduced course work and clinical hours.

Item 7 - I am in favor of eliminating the face-to-face requirement for Type I hours - we have many good quality online and home study options now available and it increases the ease of getting Type I and will also likely increase overall quality of learning since fewer hours will be in Type II which is hard to track for quality. This will also make it consistent with the requirements for the direct access certification continuing competency which does not require face to face.

Item 8 - I support using the PRT as some form of granting credit for someone to determine competence. I think this should be in combination with some hours of clinical practice as determined by the Board based on all the factors to consider. I do think if you put this element in place the PT who reside on the Board need to be the ones determining this competence and the specifics of a plan for the individual PT using this option...this assessment should not be done by staff who are not PT's.

    Thank you.

Having read the NOIRA on the PT Regulations, I would like to offer the following comments:                

• Section 70: I agree with the proposed changes for unlicensed/graduate PT's and PTA's.  By limiting traineeships to graduates that have already scheduled their licensure exam, you reduce the length of the traineeship to a 60 day period.  This encourages recent graduates to complete the exam in a timely period and reduces the exposure of the employers.  I agree with the comments by Ms. Shoaf, that since a graduate can only take the licensure exam 3 times in 1 year, we do not need to regulate the number of allowable traineeships. 
• Section 140:  I am in favor of limiting the number of traineeship supervisors to 2 to facilitate continuity of training and continued education during the traineeship period.   It is also favorable to require a PT supervisor's co-signature on all documentation.
• Section 50D:  I concur with the change to allow for a part-time traineeship with the 2 year limitation in attaining the required number of traineeship hours.  I also agree with reducing the traineeship for a PTA from 480 hours to 320 hours.
• Item #7:  I am in favor of eliminating the "face to face" restriction for continuing education courses for Type I hours.  As stated previously by Ms. Shoaf, there are numerous high quality CE courses that are taught via electronic means that would provide an excellent means of learning and enhancing the skills/knowledge level of the practitioner.  For a PT to get re-licensed they need face to face CEU's; however, to become re-certified as a Direct Access Provider of PT, the face to face requirement is not there.  Therefore, this proposed change in the definition of Type I CEU's would place the re-licensure requirements "in line" with the direct access re-certification process.  Also, this proposed change in the definition of Type I CEU's would reduce the financial burden on PT's and PTA's in the commonwealth while continuing to ensure the safety of the public.   Many therapists in Virginia live and practice in rural areas that are not easily accesible to "face to face" CE courses and thus are faced with the high cost of travel expenses as well as the high cost of the course.  On-line courses would offer the same high quality with a lower cost.  This is very important - especially when many employers are reducing "continuing education benefits" for their employees.   This reduction in cost and time would also encourage participation in CEU's from PT's and PTA's that would potentially exceed the required number of hours, creating a workforce that is even better equipped to practice in our ever changing field. 
• Additionally, it is my opinion that courses (no matter what the medium/mode of presentation) should be reviewed and approved by an appropriate delegation such as is currently done by the Continuing Education Approval Committee of the VPTA.  This would ensure that the courses that would "count" as Type I would be high quality courses that would achieve the goal of "continued education" of the practitioner.  
• Thank you for considering these comments for the proposed changes.