| 11/6/2018 1:16 pm Date / Time filed with the Register of Regulations | VA.R. Document Number: R____-______ |
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Virginia Register Publication Information
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Transmittal Sheet: Response to Petition for Rulemaking
Initial Agency Notice
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Agency Decision
| Promulgating Board: | Board of Veterinary Medicine |
| Regulatory Coordinator: | Elaine J. Yeatts (804)367-4688 elaine.yeatts@dhp.virginia.gov |
| Agency Contact: | Leslie L. Knachel Executive Director (804)367-4468 leslie.knachel@dhp.virginia.gov |
| Contact Address: | Department of Health Professions 9960 Mayland Drive Suite 300 Richmond, VA 23233 |
| Chapter Affected: | |
| 18 vac 150 - 20: | Regulations Governing the Practice of Veterinary Medicine |
| Statutory Authority: |
State: Chapter 38 of Title 54.1 Federal: |
| Date Petition Received | 06/01/2018 |
| Petitioner | Kelly Gottschalk, DVM |
To amend 18VAC150-20-170 to allow practice management courses to be approved for continuing
education credit.
Agency Plan
The petition will be published on June 25, 2018 in the Register of Regulations and
also posted on the Virginia Regulatory Townhall at www.townhall.virginia.gov to receive
public comment ending July 20, 2018.
Following receipt of all comments on the petition to amend regulations, the Board
will decide whether to make any changes to the regulatory language. This matter will
be on the Board's agenda for its first meeting after the comment period, which is
scheduled for July 23, 2018.
| Publication Date | 06/25/2018 (comment period will also begin on this date) |
| Comment End Date | 07/20/2018 |
Take no action
| Agency Response Date | 11/06/2018 |
The petition and the comments on the petition were considered by the Board at its
meeting today, November 6, 2018. Members of the Board voted to deny the petition for
a variety of reasons. First, the petitioner had requested that the Board interpret
its current regulations through a guidance document to allow hours of practice management
to meet requirements for continuing education. Such an interpretation is beyond the
scope of a guidance document, so the recognition of courses in practice management
would necessitate an amendment to rule.
Second, the Board was concerned that hours of practice management would dilute the
purpose of continuing education, which is to ensure that licensees remain minimally
competent to practice veterinary medicine. While practice management (and related)
courses may be extremely valuable in effectively operating a veterinary establishment
and managing employees, they are not essential to the mission of the Board to protect
patient health and safety. The Board considered the advisability of increasing the
hourly requirement and then recognizing practice management for the number of additional
hours, but that would increase the burden on all licensees.