As a Licensed Veterinary Technician for 43 years, I am disheartened and discouraged by the petition currently open for public comment requesting An amendment to subsection B of section 172 to replace the restriction on insertion of IV catheters by unlicensed assistants with a restriction on placement of jugular catheters, and an amendment to subsection C to allow delegation of peripheral intravenous catheters under immediate supervision of a veterinarian.

In 1972, the Commonwealth of Virginia and the Board of Veterinary Medicine enacted laws and regulations allowing for certification of animal technicians, now referred to as Licensed Veterinary Technicians.  This action was taken to elevate the practice of veterinary medicine in the Commonwealth by providing individuals with advanced training and skills to work alongside veterinarians in a professional capacity to ensure the best possible care for animals and to protect the interests of the pet owning public.  Initially, individuals who had a specific number of years of clinical experience were permitted to sit for the State Board Exam for Veterinary Technicians.  In 1996, the Board of Veterinary Medicine adopted the Veterinary Technician National Exam which is now owned by the American Association of Veterinary State Boards and administered at Prometrics Test Centers across the country.  The national success rate of first time takers of the VTNE is reported to be 64.4%. Almost every year since 1996, the two Veterinary Technology Programs in Virginia have had a 100% success rate on the VTNE, reflecting the quality of the education veterinary technicians are receiving at both Blue Ridge Community College (established in 1972) and Northern Virginia Community College (established in 1976).  Each year, approximately 100 veterinary technicians graduate from these two programs, become licensed and enter the workforce.

In the 45 years since the profession of veterinary technology became recognized in Virginia, the scope of practice and body of knowledge in veterinary medicine has increased dramatically.  Veterinary technicians have maintained the pace of growth and in some cases led the way.  A 2010 study in JAVMA looked at whether a relationship existed between veterinary practice revenue and characteristics of veterinary technicians, including education level and qualifications. Results showed that the typical veterinarian’s gross income increased by $93,311 for each additional credentialed veterinarian technician per veterinarian in the practice (J Am Vet Med 2010;236:846). This same phenomenon was not seen with noncredentialed technicians; rather, there was no meaningful revenue increase with noncredentialed technicians. While many people who support the current petition to allow veterinary assistants to perform tasks previously held as requiring licensure (veterinarian or technician) site the “shortage” of LVTs as a reason to change regulations.  I propose that this petition, if approved, would result in a greater shortage of licensed veterinary technicians.  According to the NAVTA 2016 Demographics Survey, the top 6 most significant problems that face individuals as credentialed VTs include low income, burnout, lack of recognition and career advancement, the underutilization of skills, and the competition with on the job trained technicians.  If the specifically designated duties of LVTs continue to erode, the desire to enter the profession will decrease.  In fact, it is a major reason why veterinary technicians continue to leave the profession at an alarming rate, within 5 years of graduation. While I agree that LVTs are far more than this single task, I do believe that this petition, if approved,  undoubtedly will have a negative impact on current and future veterinary technicians.

One of the reasons credentialing of veterinary technicians even exists is the assurance the credential provides that the individual received adequate, repeatable and documented training on over 200 tasks (including the placement of IV catheters) specified by the Committee on Veterinary Technician Education (CVTEA) of the American Veterinary Medical Association.  Without a credential, there is no such assurance.  AVMA accredited programs must provide documentation of training for invasive tasks such as Intravenous Catheter Placement that includes the steps for training, the criteria for assessment and documentation of the successful completion of the task.  Students in vet tech programs may practice the procedure well over 100 times on models/simulators prior to their first attempt on a live patient.  This level of training is not possible in a veterinary practice situation.  I am confused by the supporters of this petition who on one hand state that having an assistant be able to place an IVC will be life-saving for patients, when the veterinarian is too busy to do it themselves, yet state that they are qualified and able to provide adequate training in placing an IVC.  I wonder, if the vet is too busy to place the IVC, who is making the assessment that the patient even needs an IVC that would be life-saving for that patient?  What is the vet doing that is more important than that critical patient?  If the practice is so busy that the vets are constantly tied up with critical patients, when are they going to have the time to provide training?  Will their training be consistent with the training provided to veterinary technology students?  While there are certainly standards of practice in Virginia, we all know that there is a vast difference amongst practices regarding the level and quality of veterinary medicine practiced. I would suggest that the level of training of veterinary assistants is equally variable.  Many supporters of the petition ask the Board of Veterinary Medicine to provide training guidelines for the placement of IV catheters.  That is not a function of the Board and the Board cannot make or enforce regulations of activities performed by those they do not regulate (veterinary assistants).

But this issue is not one of protecting the role of veterinary technicians.  The primary reason this is a bad idea is the patients that will be impacted by having non-licensed and regulated personnel performing invasive tasks on patients, some who may be in critical situations.  While the mechanics of the procedure may be eventually mastered by some, having a clear understanding of the technical aspects of IVC placement, the risks involved (excessive bleeding, sepsis, thrombophlebitis, and thrombosis or air emboli) and the effects of disease and stress on the animal must also be part of the equation.  Just because a procedure is routine, does not mean that it is not important, that protocols may not be followed, or that the patient does not deserve the highest standard of care.

Pet owners in Virginia place their trust in their veterinarians and most consider their pets as family members. Recent conversations I have personally had with a variety of pet owners, some who I know personally and others I do not know, revealed that most owners believe that their veterinarian only hires trained, licensed personnel to provide care for their animals.   They honestly place that level of trust in their vets and EXPECT that the people who are doing procedures on their pets have a credential that helps insure their competence, training and accountability.  They often do not even know to ask or be concerned that a practice has or has not hired credentialed employees.  They just trust that the doctor who they have established a relationship with would never allow someone without a credential to perform invasive procedures on their pet. Clearly the practices that have or would allow unlicensed personnel to place IV catheters would betray that trust in an era when perception of the profession is in constant question.  When asked specifically if they would allow someone without a credential to perform an invasive procedure on their pet, especially in an emergency situation, they answered with a resounding “no”.  I suggest that most people would be horrified to discover that is the situation in practices all over the Commonwealth.  They are accustomed to the standard established in human medicine, where the professional boundaries are more clearly defined, and simply expect that the same exists in veterinary practices.

Rather than lower the standards to accommodate practices that do not or cannot employ credentialed personnel, I implore the Board of Veterinary Medicine to strive to earn and preserve the trust of the public by maintaining a high standard of practice and aid the veterinary profession in improving, growing and embracing the changes and challenges the future holds.

Respectfully submitted,

                                                                                          Lucretia (Kris) M. Keane, BAS, LVT