Regarding 18 VAC85-110-80 -- Obtaining Diplomate status from NCCAOM now requires a variety of exams, somewhat dependent on the type of certification sought. It is unclear from the current language which exams would count as the comprehensive written examination. I believe the language should be revised to clarify which exam modules must be passed.
Regarding 18 VAC85-110-150 -- Requiring current active NCCAOM status adds both a financial and time burden to ongoing practice in Virginia. Only one other profession requires ongoing approval by a third party, outside of state control, to maintain licensure. It would ease the regulatory and financial burden to replace this requirement with a simple requirement for continuing education, the amount and type of which could be set by the board. This would bring these regulations in line with other professions.