Dear Board Members,

I am a veterinarian who has practiced small animal medicine for 15 years, all in the state of Virginia.  Please consider the following comments regarding proposed changes to Article 18VAC150-20-172, Delegation of Duties, of the Virginia Register of Regulations, Volume 33, Issue 9, pages 952-953:

 B. Injections involving anesthetic or chemotherapy drugs, subgingival scaling, or the placement of intravenous catheters shall not be delegated to an assistant.  An assistant shall also not be delegated the induction of sedation or anesthesia by any means.  The monitoring of a sedated or anesthetized patient may be delegated to an assistant, provided the patient is no longer intubated and provided a veterinarian or licensed veterinary technician remains on premises until the patient is fully recovered.

The new provision in the above regulation that specifically prohibits a veterinarian from delegating anesthetic monitoring of an intubated patient to an unlicensed, trained assistant concerns me.

The proposed regulatory change, intended to protect patients and promote the LVT profession, will instead have negative consequences on the quality, availability, and cost of veterinary care in Virginia, due to the severe shortage of LVTs in the state.

Other solutions can still protect veterinary patients.  Detailed training for anesthetic assistants could be developed, and demonstrated by practices, or a standardized curriculum developed by the Board or professional organization such as AAHA. Prior to veterinary school, while working as a technician assistant, I received extremely thorough training in anesthetic monitoring, always under the supervision of an LVT and veterinarian. During anesthetic rotations in veterinary school, I found that the training I received as an assistant was more complete than that of certain classmates who had worked as LVTs. A rigorous training program would allow unlicensed technician assistants to responsibly monitor intubated anesthetized patients under appropriate supervision of Licensed Veterinarians or LVTs. 

Thank you for taking the time to review and consider the above comments.

Respectfully,

Shannon Talbott, DVM

VA License # 0301200547

Associate Veterinarian, VCA-Alexandria Animal Hospital

2660 Duke Street

Alexandria, VA 22306

703-751-2022