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.