Ms. Knachel,
We, the membership and Executive Board of the Virginia Association of Licensed Veterinary Technicians (VALVT), do oppose the proposed changes to the regulations to “allow delegation of peripheral intravenous catheters under immediate supervision of a veterinarian.” We believe this would be an unwise alteration due to the following concerns:
Public perception – The general assumption and expectation of the public in regards to their pet's care during hospitalization and/or surgical procedures is that their pets will be cared for by licensed staff when it comes to any invasive procedures. IV catheter placement is indeed an invasive procedure and should therefore, not be delegated to unlicensed assistants. To deregulate the placement of IV catheters, creates a slippery slope of decreased standards in our profession and a loss of confidence by our clients. Clients should see the worth and value they receive in veterinary medicine and not have to question the standard of care their pet receives.
Animal safety – The safety of our patients should always be paramount in our profession. Infiltration, thrombus formation, phlebitis, and infection are all potential complications from improperly placed or cared for IV catheters. Allowing unlicensed assistants to place IV catheters would jeopardize the safety of our patients. Often the catheter is being placed in an already compromised patient, making the task even more critical.
Training standards – The current regulations state that a veterinarian may delegate certain duties to a “properly trained assistant” but makes no attempt to define “proper training.” Licensed technicians in Virginia do have extensive training on IV catheter placement. It is a required task on the CVTEA's “The Essential and Recommended Skills List (Skills List)” list that every technician student in Virginia must demonstrate proficiency at before graduating their program. This includes training in aseptic preparation, placement, and maintenance of IV catheters. If unlicensed assistants are allowed to place IV catheters, there is no regulation or standard of training that they must receive before they can be considered “properly trained” by a Veterinarian. Using licensed and trained technicians for this task should be a standard of care that protects our patients, our clients, our veterinarians, and our profession.
Definition of “immediate supervision” - The final reason that the VALVT opposes this change is due to the definition of “immediate supervision” in Part I, section 10 of the BVM regulations. Currently “Immediate and Direct Supervision” is defined as “the licensed veterinarian is immediately available to the licensed veterinary technician or assistant, either electronically or in person, and provides a specific order based on observation and diagnosis of the patient within the last 36 hours.” Therefore, a Veterinarian or Veterinary Technician does not even need to be on the premises when delegated duties are performed, as long as they can be reached on the phone. Again, this compromises the public's trust in our profession and the safety of our patients if unlicensed personnel are allowed to place IV catheters when a doctor may not have even seen the patient for over a day. This risk is increased with compromised and sick patients when their health or status may change quickly.
For these reasons, the membership and Executive Board of the VALVT believe that IV catheter placement and care must rely on licensed personnel only. Some objections have been raised as to the availability of Licensed Veterinary Technicians, however; the AVMA issued the following statement:
"With the increasing number of accredited veterinary technology programs in the United States, both in traditional settings and as distance-learning modalities, it can no longer be stated that an individual wishing to become a veterinary technician or technologist does not have access to an accredited educational program".
We request that the Board honor the long-standing trust our clients have placed in us, the exceptional standards of care that Virginia is known for, and the importance of education by declining this proposal and strengthening the current regulations.