This letter is in reference to the Board's proposed changes to 18VCA150-20-172 Delegation of Duties for the Board of Veterinary Medicine stopping the ability to use assistants to monitor intubated patients and require LVT's to be the primary responsible personnel to monitor these patients.   There are always reasons for the board to consider making these types of changes.  Perhaps there have been too many cases reported of compromised care of patients or perhaps the licensed veterinary technicians would like to have their profession recognized for the efforts in attaining their degrees. Changing the regulations might at first appear to be a quick way of fixing these types of situations however, making these types of changes would create a tremendous burden to the practice of veterinary medicine not to mention potentially reduce the quality of care to our patients.  

Many veterinary practices are in rural areas where they have trouble attracting licensed veterinary technicians.  Even those practices in more urban locations often have less than a 1:3 ratio of technicians to veterinarians. Unlike in human medicine where there are greater than five nurses licensed to number of doctors.  Changing the regulations in an attempt to give greater recognition to the technician field is not going to solve this shortage.  It will only cause the current technicians to work harder and perhaps lead to burn out in their profession.  

As far as safety issues regarding the use of assistants to monitor intubated patients many hospitals use in house training programs to teach these requirements to their staff. Perhaps the regulations could state that assistants performing these tasks can do so under the direct supervision of a licensed technician and/or veterinarian.  I would like to hope this is already the case.  

Ultimately, the doctor is fully responsible for a patients care.  If limitations to how we can use our staff continues we will be severely limited in our daily duties.  Many practices will suffer economically while others may even prosper from the referrals of these patients.  Many patients may get compromised care by using injectable anesthestics in place of gas anesthestics if they have no licensed technicians or worse yet doctors might compromise their care by trying to monitor and perform surgery at the same time.  

I ask that these regulations not be accepted for these reasons and that the reasons for considering these changes be pursued under a different agenda.