The current regulations as they read at this time do not provide the dialysis providers any alternatives to hire new technicians and provide the training period required plus the period of time between completion of the training program and the successful passing of one of the approved certifications.

I am requesting reconsideration of 18 VAC 75-40-10 et seq.  According to the regulation, Dialysis Patient Care Technicians will be required to be certified by one of the following:

Nephrology Nursing Certification Commission (NNCC)

Board of Nephrology Examiners Nursing and Technology (BONENT)

National Nephrology Certification Organization (NNCO)

There are no provisions in the current regulation as to how provider will be allowed to hire, train, allowing a newly trained Patient Care Technician to gain the clinical experience needed to sit for these certification exams.

According to the above entities web sites, the following are the requirements/recommendations for applicant to take these certification exams:

Nephrology Nursing Certification Commission (NNCC) – Recommend 1000 hours of clinical experience, inclusive of the formal training program prior to taking exam. 

Board of Nephrology Examiners Nursing and Technology (BONENT) – Requires 1 year clinical experience prior to taking exam.

National Nephrology Certification Organization (NNCO) – Requires 1 year clinical experience prior to taking the exam.

While the Nephrology Nursing Certification Commission (NNCC) – Recommend 1000 hours of clinical experience, inclusive of the formal training program prior to taking exam, it does not require this and is the only examination that test for initial competency.  However, the process that is required for the candidate to apply to sit for this examination requires the following:  The candidate must have completed a formal dialysis training program (ours is 8 weeks) prior to submission to take this exam.  Also, the application must be received at a minimum of 6 weeks prior to the date of the examination.  The candidate will receive the results of their examination in 4-6 weeks.  This means that there is a minimum of  18-20 weeks before a new patient care technician can realistically become certified.  This is approximately 4-5 months!

The way the regulation reads at this time, there are no provisions allowing a newly trained Patient Care Technician to gain the required training and clinical experience or to continue employment with a provider in the interim.

I am requesting that the current regulation be rewritten in a manner that would allow the providers time to have newly hired dialysis technicians receive certification.  I would recommend a period of 6 months after their hire date.

The way that this regulation reads currently will cause increase cost to all the dialysis providers.  It has to potential to create many staffing issues, which can lead to poor patient care.

Certification is not the argument.  But the providers must have a realistic way in order to implement it.  The most important aspect of the competency of the dialysis patient care technician is not certification, but the education in which they receive the basic of how to do their jobs, handle patients, and perform dialysis.  This education has to be obtained through a formal training program that consist of didactics, clinical experience and testing, both formal written and skills checks testing.

Currently, the facilities in Virginia, owned and operated by Fresenius Medical Care attend a formal orientation program that includes both classroom and hands on instruction, followed by a dedicated preceptor period.  To prove initial competency, the orientee must pass the final written examination with a score of 85% or better and must have completed a Competency Skills Checklist prior to graduation from our Patient Care Technician training program.  Our training program last a total of 8 weeks.

Thank you in advance for not finalizing this regulation with out modification.

As a strong supporter of certification for Patient Care Technician, I am delighted to see this regulation on the verge of becoming a reality, however; I concur with Ms. Yoakum.  Provisions must be written into the regulation allowing a designated time period for newly trained Patient Care Technicians to gain the necessary clinical experience needed prior to sitting for the certification exam.

The current wording of the regulation leaves dialysis providers in a "Catch-22" situation.  New hires cannot ues the title "Dialysis Patient Care Technician or Dialysis Care Technician" unless they hold certification from an entity approved by the Board as described in18 VAC 75-40-30.  Yet restrictions and/or recommendations by the certifying agencies prohibit individuals who have completed the approved training progran from sitting for the exam for as much as six months to one year.  During this six month to one year period, pursuant to 18 VAC 75-40-20 D, which states, "Unregulated persons shall only perform services related to the technical element of dialysis, such a equipment maintenance and preparation of dialyzers for reuse by the same patient."  Persons who have completed the approved training will not be allowed to develop clinical skills.  Hands on clinical experience is absolutey necessary in order to prepare for the certification exam.

I urge revisiting this regulation and making modifications that will include a six month time frame as suggested by Ms. Yoakum.

Thank you for your consideration of this matter.

I would like to request reconsideration of Regulations Governing Certification of Dialysis Technicians (18 VAC 75-40-10).  This regulation as it is currently written does not allow the new Patient Care Technician the time it takes to gain the clinical experience needed to prepare for the certification exam.  As Ms. Yoakum pointed out, the Nephrology Nursing Certification Commission (NNCC) is the only examination that tests for initial competency and they recommend 1000 hours of clinical experience, inclusive of the formal training program prior to taking the exam.

I am requesting that this regualtion be amended to provide newly hired Dialysis Technicians with the 6 month time frame as suggested by Ms. Yoakum.  I believe this will allow them the opportunity to gain the knowledge and expertise required to successfully complete the certification exam rather than setting them up for failure.

Thank you for your consideration in this matter.