Go to ttp://townhall.virginia.gov/L/GetFile.cfm?File=C:\TownHall\docroot\GuidanceDocs\222\GDoc_DPOR_4920_v1.pdf.   (cut and paste into your browser; add the "h" prior to ttp

-current Board guidance document discusses direct supervision and WHO is accountable for an unlicensed person's actions.  Under the current program, licensed professional is responsible for everyone that he/she is employing-training.

The new licensing scheme is going to create a special buffer for "management" or those responsible for training/supervising unsupervised persons and place blame on untrained persons?  

Did the Board consider what this will do to accountability?

   ttp://gdurl.com/P2aZ    (copy and paste to browser and add h prior to ttp:)

You are being requested to withdraw the proposed regulations due to less burdensome methods of regulation