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.