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.