Although this is not a “hot button” issue as evidenced by the lack of comments, it is still an important one. 

Although I do not have a lot of knowledge in regulatory matters, what little research I was able to do indicated that other states and our Boards for other licensees have comparable requirements (at least to a point) for reactivation/reinstatement of licenses and renewal of licenses.  For example,

·        North Carolina regulations for Continuing Competence for Nurses (21 NCAC 36.0232), which are comparable to Virginia’s new regulations, cover both renewal and reinstatement of licenses; and,

·        the Virginia Board of Medicine the Virginia Board of Physical Therapy both require continued competency hours equal to the requirement for the number of years (not to exceed four years) in which the license has been inactive along with practice requirements (18VAC85-20-240 and 18VAC112-20-135), or in the absence of clinical practice, passing various exams (18VAC85-20-240) or completing a traineeship (18VAC112-20-135).

I do hope that the Board of Nursing will strongly consider promulgating regulations in this matter so that requirements for reactivation/reinstatement of licenses will be comparable to renewal of licenses. 

Thank you.