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.