IARP—International Association of Rehabilitation Professionals

1000 Westgate Drive, Suite 252                                            Phone: 888-427-7722
St. Paul, MN 55114                                                                Fax:      651-290-2266                                                                                              www.rehabpro.org                                                                                              

August 13, 2018

Board of Health Professionals

C/o Ms. Elaine J. Yeatts

9960 Mayland Drive, Suite 300

Richmond, VA 23233

Dear Board of Health Professionals,

This is a letter of support for VA 18 VAC 115-40-10 et seq.; the Regulations Governing The

Certification of Rehabilitation Providers (CRP) in the interest of public safety. The International

Association of Rehabilitation Professionals (IARP) was founded more than 30 years ago to promote the betterment of people with disabilities and the professionals who serve them. IARP represents more than 2,400 rehabilitation professionals worldwide. Our VA chapter and sent a separate letter of support for the above regulations and the national/international association also wanted to support these regulatory changes to protect the citizens of the Commonwealth of VA.

Our VA section members are seasoned rehabilitation professionals who have served the VA citizens with disabilities for decades practicing in small, mid-size and large companies across the

Commonwealth.  IARP VA was active at the development of the WC regulations in the early 1990’s and several of our members were been appointed to revise the Vocational Rehabilitation Guidelines of the Virginia Workers’ Compensation Commission (VWC) effective in October 2015.

The regulations were originally conceived in the early 1990’s following a Joint Legislative Audit & Review Commission study ordered by Lieutenant Governor Don Beyer concerning the Virginia Workers’ Compensation Commission. At that time the citizens of the Commonwealth were endangered by rehabilitation professionals practicing without the appropriate skill set and/or experience. The Regulations Governing the CRP set forth Standards of Practice in 18 VAC 115-40-40. The Standards of Practice were drafted with the primary purpose of promoting the safety and welfare of the Citizens of the Commonwealth of VA. Furthermore, the regulations establish education and supervision expectations that require rehabilitation professionals to hold nationally recognized designations in the field of rehabilitation or be eligible by virtue of education and experience to test for such designations. These national certification designations

also have a Code of Ethics which expand on the protections offered by the Standards of

Practice outlined in the regulations.

The regulations are also concurrent with the statutory guidelines outlined in §§ 54.1-2400

and Chapter 35 of Title 54.1 of the Code of Virginia. They ensure that the Citizens of the

Commonwealth receive assistance from experienced professionals to advocate for their

rehabilitation needs. The Citizens requiring these services are already vulnerable by virtue

of their impairments and without skillful assistance would be at risk to be further

disenfranchised by the rehabilitation process.

Thank you for your careful consideration of our comments and concerns. We believe our

Citizens deserve the best possible opportunity to overcome the challenges of disability.

Respectfully,

Amy Vercillo ScD, LRC (MA), CRC, CDMS

National Legislative Chair, IARP