I have concern about the adjustment in ratio of supervision hours per hours. With the elimination of ancillary or indirect hours, which I support, I believe this can adversely impact the developmental needs of residents, as well as extend their residency unnecessarily. 

Under what is proposed in 18VAC115-20-52 Resident license and residency requirements section B3a, it says, "Supervision shall occur at a minimum of one hour and a maximum of four hours per 40 hours of work experience during the period of the residency." This would indicate that the maximum ratio of 4:40 (supervision hours to direct hours, since indirect hours will no longer be counted). Or, more simply, the maximum ratio is 1:10. 

As stated in Dr. David Mikkelson's comment, one concern that I share is that if a resident falls behind in supervision, it seems that there is no viable way to "catch up," on supervision hours if direct hours completed exceed that 1:10 ratio. Furthermore, especially in the first quarter or half of residency, having an "extra" amount of supervision hours can often be essential for appropriately addressing the developmental needs of the resident. 

As a supervisor who plans to supervise residents, I greatly value having the appropriate amount of supervision for residents at the appropriate times in their development, and I would not want them to unnecessarily have insufficient hours early on, or have unnecessary hours to complete once they near the end of residency. As such, I also recommend changing the supervision ratios to 1:7 maximum and 1:25 minimum in order to provide the flexibility to best meet the supervision needs of residents.

Thank you for your consideration on this matter.