June 8, 2017

Dear Ms Knachel and members of the VA BVM,

Regarding the proposed changes to the Virginia Board of Veterinary Medicine to amend subsection B of section 172 to allow unlicensed assistants to place IV catheters, excepting jugular catheters, under the immediate supervision of a veterinarian, the National Association of Veterinary Technicians in America (NAVTA) makes the following statement:

NAVTA understands that there are many areas of the country that are experiencing a lack of credentialed technicians and accommodations need to be made to ensure quality patient care. In theory, we could support a change to state rules to ensure this care.  However, in this instance there are several concerns that prevent us from supporting this amendment.

1. There is mention of the assistant placing an IV catheter being “properly trained” but this is not defined and leaves the definition up to the individual veterinarian.  With the argument for the need of this amendment being veterinarians are too busy, this leads to concern that training may not be able to be as comprehensive as intended.
2. “Immediate supervision” is also a concern. In the definitions section of the VA BVM’s Regulations, this is defined as a veterinarian being available “either electronically or in person”. When there is a complication of catheter placement, virtual supervision is simply not enough.  The VVMA makes the argument in their letter that LVTs are qualified supervisors for assistants placing IV catheters.  NAVTA agrees with that assessment, however, the wording of “immediate supervision” does not allow for that. Ultimately, the veterinarian is going to need to be the supervisor as the regulations are currently written.
3. NAVTA agrees with the Virginia Association of Licensed Veterinary Technicians (VALVT) that making this change is a slippery slope that puts the profession of licensed veterinary technicians at risk. NAVTA is working hard to advance the profession of veterinary technology. This amendment sets our profession back and sets the precedent to authorize non-credentialed individuals to perform the skills we have been formally trained to perform. NAVTA would much rather see an effort to promote the role of the licensed veterinary technician to bring more qualified individuals into the VA workforce.

In summary, NAVTA opposes this amendment as it stands and encourages the VA BVM to table the amendment to 1-perform research to provide concrete numbers to support or refute the claims that LVTs are not distributed adequately, 2-better address oversight and patient safety and 3-to work to promote the role of licensed veterinary technicians. Again, we do understand the current reality and see the possible need for a measure like this. We would encourage the VA BVM to research a way to preserve the role of the veterinary technician. Perhaps there is a process for giving this amendment an end date or for incorporating an additional change to establish new avenues for increasing LVTs in VA. In truth, the root of this change starts with veterinarians and practice owners– encouraging assistants to become LVTs, helping these individuals with school when able, and supporting the advancement of the profession by paying LVTs a wage commensurate with their education and training. 

Thank you for your time and consideration.

Sincerely,

The NAVTA Executive Board