To be consistent with licensure, I would recommend taking requirements for reinstatement/reactivation of licenses from the recently promulgated regulations for renewal of licenses, 18VAC90-20-221 (and 222 for documentation). Specifically, I would recommend any one of the activities in 18VAC90-20-221 A2 (college courses), A3 (refresher courses), or A9 (thirty contact hours).  I would request the Board strongly consider eliminating reinstatement or reactivation of a license based solely on passing the National Council Licensing Examination.

The Board should also consider eliminating the "grace period" allowed for reactivation/reinstatement of inactive or lapsed licenses  (no continuing competency requirements within one renewal period).  

Thank you for the opportunity to express my views on this matter.