In my opinion, B1 of Section 18VAC90-20-225 and A of Section 18VAC90-20-230 should be altered or eliminated. Otherwise, it appears that a licensee could let the license lapse (or inactivate the license) and then reinstate (or reactivate) the license in the one renewal period allowed in these sections, and avoid continued competency requirements.  Reinstatement (or reactivation) requirements start in the second renewal period. Because the license would not be active, the licensee would not be subject to renewal requiremets in 18VAC90-20-221. I don't know what other avenues or regulations are open to the Board to prevent reinstatement (or reactivation) in the first renewal period without demonstrating continued competence, but it appears from the way these regulations are written (at least from my reading) that the licensee could avoid continued competency requirements as stated above while still being in technical compliance with the continued competency regulations. Thank you for allowing me to express my opinion on this matter.