In my opinion, B.1. of Section 18VAC90-20-225 and A. of Section 18VAC90-20-230 should be eliminated. Otherwise, it appears that a licensee could completely avoid Continued Competency requirements and still stay in technical compliance with the Regulations by allowing his/her license to lapse (or by inactivating the license) for a day and then applying for reinstatement (or reactivation).  The licensee would not be subject to Continued Competency requirements under 18VAC90-20-220 since he/she would not be renewing the license, and wouldn't be subject to Continued Competency requirements under 18VAC90-20-225 (or 230) since he/she would be within the one renewal "grace" period allowed in Sections 225B1 and 230A.  Therefore, in my opinion, the one renwewal "grace" period in both Sections 225 and 230 should be eliminated.

I gree with the other comments ... The one renwewal "grace" period in both Sections 225 and 230 should be eliminated.

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