I.         In reference to section 18VAC112-20-10 the proposed change related to discharge     VPTA would propose the following language:

“Discharge” means the discontinuation of interventions in an episode of care which has been provided in an unbroken sequence in a single practice setting and related to the physical therapy interventions for a given condition or problem.

The rationale for this change is that the term ‘episode of care’ as used in the Guide to Physical Therapy Practice from the APTA actually crosses care settings – i.e. a hip fracture episode of care includes acute, inpatient rehab and outpatient.  The Board either needs to define ‘episode of care’ differently in this document or clarify that the discharge is related to a given practice setting.

II. In reference to this same section the term “Evaluation” we would propose the following change:

"Evaluation" means the process in which the physical therapist makes clinical judgments based on data gathered during an examination or screening in order to plan and implement a treatment intervention, provide preventive care, reduce risks of injury and impairment, or provide for consultation.

The rationale for this language rather than what has been proposed was that in the previous changes to the Rules and Regulations the Board specifically inserted the terms examination and screening in the definition to assist licensees in understanding that it is the role of the PT, not the PTA, to perform examination and screening on a patient. The addition of the language clinical judgment is good as an addition – we believe this modification maintains the intent of the previous PT Board action and adds to the definition.

III. In reference to 18VAC112-20-40 there is a paragraph that reads as follows:

B. If an applicant is a graduate of an approved program located outside of the United States or Canada, he shall provide proof of proficiency in the English language by passing TOEFL and TSE  or the TOEFL iBT, the Internet Based tests of listening, reading, speaking and writing by a score determined by the board or an equivalent examination approved by the board. TOEFL iBT or TOEFL and TSE may be waived upon evidence of English proficiency that the applicant’s physical therapist assistant program was taught in English or that the native tongue of the applicant’s nationality is English.

VPTA poses the question relative to the last three lines of this paragraph -

 It appears that is should read “physical therapy education or program” to encompass both PT and PTA programs.

This same language that reference PTA education is used again in section 18VAC112-20-50 item C -1.

IV. In reference to section 18VAC 112-20-50 item C-3. states the following:

 Verification of the equivalency of the applicant's education to the educational requirements of an approved program for physical therapist assistants from a scholastic credentials service approved by the board.

FYI - Based on conversation with Mark Lane at FSBPT and Sue Lindblad there is currently    only one agency, IERS of California that will credential PTA education.  FCCPT does not at this time but will be initiating this process in 2009 and may be available to review these individuals for Virginia at that time.

V. 18VAC112-20-50 item D addressed the traineeship and following proposed language:

D. An applicant for initial licensure as a physical therapist or a physical therapist assistant who is not a graduate of an approved program shall also submit verification of having successfully completed a ful ltime1000-hour traineeship as a "foreign educated trainee" under the direct supervision of a licensed physical therapist.

We would ask that you delete the words“full time” as many individuals may not have the option or opportunity to work full time in a traineeship – the individuals should be able to complete the required number of hours in a part time format if needed.

VPTA would like the Board to consider changing this to a 480 hour traineeship with an option for an extension to a greater number of hours, or an additional traineeship for 480 hours, if deemed necessary by the supervising physical therapist. This would potentially make the traineeship less burdensome for individuals whose performance in the 480 hours had been satisfactory and demonstrated entry-level competency.

Also, consider allowing the PTA traineeship to be a fewer number of hours than the PT traineeship.  Our rationale is that PTA education programs are shorter than PT education programs, and the scope of services provided by the PTA is less than that provided by a PT.

VI. 18VAC 112-20-70 entitled traineeship for unlicensed graduate scheduled to sit for the national examination

Although this may on initial look cause some employers to be anxious, VPTA supports removing the traineeship for unlicensed graduates completely at this time. There are several reasons for this recommendation. This option was available to graduates who in the past had to wait several months to find out the results of their scores on the national examination. This is no longer the case – the graduate gets results in 3-5 business days upon sitting for the exam. In addition, the national examination is now more difficult requiring more new graduate preparation before sitting for the exam. This becomes difficult to do once the new graduate has started working and has expectations from his/her new employer. The current new graduate trainee is not considered licensed in Virginia making them unable to provide care to individuals under Medicare and other providers due to this status. Also, VPTA is aware that there have been challenges with graduates who have had difficulty passing the exam on multiple attempts and have extended traineeships for long periods of time, often making it difficult for the PT Board to track them over time. Given all of this rationale, and if one believes that the national examination is the gatekeeper for competence to practice, it would seem prudent at this time to eliminate the new graduate traineeship and require that new graduates study for and pass the national exam before being granted a license to practice in Virginia – if you don’t pass you don’t practice.

VII. In reference to 18VAC112-20-90 item A-3 VPTA proposes the following language rather than what has been proposed:

 3. The documented status of the patient, including the response to therapeutic intervention, at the time of discharge. 

We propose changing the word after documented from “discharge” to “status” because the proposed language would make it virtually impossible for PT’s in the acute care setting to comply. In cases where the patient is unexpectedly discharged, the final treatment note needs to serve as the documented discharge status. We believe this language change would address this issue and maintain the intent of the sentence.

VIII. Section 18VAC112-20-131 related to Continuing Competency Requirements maintained the following language in the proposed regulations:

 1. A minimum of 15 of the contact hours required for physical therapists and 10 of the contact hours required for physical therapist assistants shall be in Type 1 face-to-face courses. For the purpose of this section, "course" means an organized program of study, classroom experience or similar educational experience that is directly related to the clinical practice of physical therapy and approved or provided by one of the following organizations or any of its components:

It was the understanding from previous PT Board meetings that the requirements for face to face were going to be changed to be less stringent given the increase in quality on-line education since the original regulations was created. We would request that this be changed to include home study courses from APTA, and online or audio courses offered by the organizations already  listed later in that section as approving organizations for Type I  courses.

IX. In reference to sections 18VAC112-20-135 Inactive License and 112-20 136 Reinstatement Requirements it appears to VPTA upon review that the requirements to reinstate for a license lapsed less than two years seem to be less restrictive than those who have chosen to make their license inactive. This did not make sense to us. You might only have let your license lapse for a year but would have to do more than someone whose license has been inactive for possibly a much longer period of time.  We would encourage you to review this language carefully to ensure that those two categories are equitable in what would be required for reinstatement.  

X. In reference to section 118VAC112-20-140 Traineeship Requirements VPTA is supportive of pursuing further the recent discussion at the PT Board meeting about utilizing the new FSBPT competency testing as a mechanism for determining competence of the inactive licensee who wishes to return to practice. We would be supportive of that type of option in lieu of a traineeship if competency could be determined in another format. This would support the concern from our recent survey of those previously licensed who wished to return to practice but found the requirement for the traineeship to be a barrier. If this is not possible at this time we also provide the following language change for item 1 in this section as a consideratin:

1.      The physical therapist supervising the trainee shall submit a report to the board at the end of the 480 required number of hours on forms supplied by the board.   The report shall include an assessment indicating the trainee’s ability to demonstrate entry level competencies and a recommendation indicating either successful completion, suggestion to continue for an additional period of time, or unsuccessful completion.

This would provide an assessment mechanism for the supervising PT to provide input to the Board about the performance of the trainee in the clinical setting. The current APTA CPI performance instrument could be utilized for this purpose. This could also be utilized to determine if an additional traineeship was necessary if you chose to reduce the hours noted in the previous section from 1000 to 480.