Virginia Regulatory Town Hall
Agency
Department of Behavioral Health and Developmental Services
 
Board
State Board of Behavioral Health and Developmental Services
 
chapter
Certification Requirements for Early Intervention Professionals and Early Intervention Specialists [12 VAC 35 ‑ 220]
Action Promulgate new regulations to provide certification requirements for early intervention practioners
Stage Fast-Track
Comment Period Ended on 3/17/2011
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2 comments

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3/17/11  12:01 pm
Commenter: Terri S. Ferrier, PT, President / Virginia Physical Therapy Association

Proposed Early Intervention Regulation
 

 

 

The VPTA (Virginia Physical Therapy Association) has strong concerns about the proposal to require Certification for Early Intervention Professionals and EI Specialists.  We are especially concerned about this proposed requirement being put on the Fast Track.   Detailed below are our concerns:

·         Physical Therapists are highly educated and currently the majority of new graduates in Physical Therapy have their Doctorate of Physical Therapy.  We are highly qualified to provide appropriate and effective treatment to people of all ages including the population represented by the “Early Intervention” program.  PTs are guided by licensure and DMAS does not need to mandate a certificate for people who are licensed and qualified to give therapy services to these children.

·         Currently due to various factors, there are already insufficient numbers of PTs that provide the services to these children.  Therefore, this “Certification” is not only onerous, but it also creates an unnecessary barrier to providing much needed therapy services for these precious children.

·         Therapists are trained to understand and comply with rules and unique requirements for working with clients regardless of either the work setting or the age group with which they work - such as early intervention patients. 

·         Finally, DMAS should not have the power to mandate limits to physical therapy practice as our governing Board of Physical Therapy provides qualified therapists full rights and privileges to practice physical therapy under the laws of the Commonwealth of Virginia.

 

Therefore, we respectfully oppose this proposed regulation and request that it not be passed.  The future of the special needs children is at stake and we sincerely hope that there is not a new barrier that prevents them from receiving the services needed to give them a chance in to succeed in this world – both physically and from a quality of life standpoint.

 

Respectfully Submitted,

 

Terri S. Ferrier, PT

VPTA President

Cell Phone:  540-521-4929

Email:  terri.ferrier@amedisys.com 

 

CommentID: 16249
 

3/17/11  12:17 pm
Commenter:  

Early Intervention Certification Regulation-12VAC35-220
 

As a Board Certified Pediatric Clinical Specialist, I find this certification requirement excessive and not necessary for me to evaluate and treat children whether they are in Early Intervention, Medicaid insured or utilizing my services under any insurance policy.  Because I also work with a pediatric service, I was "required" to do the modules and be certified if I wanted to continue to work with this group.  I am certified but am concerned that there were several errors in the modules that deal with development!  As a taxpayer, I am concerned that Medicaid funds are being used to update these modules, monitor who is certified and keep up with the everchanging personnel who will be servicing these children.  This regulation is not necessary!

Virginia May, PT, DPT, PCS

CommentID: 16250