As a concerned member of the veterinary community I am writing in regards to the 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.

As an LVT working in a busy GP/ER facility my concerns are mainly with the impact on the level of care that I and my fellow technicians will be able to provide to our patients if the board decides to pass this proposal. While there will also undoubtedly be resulting economic effects, my current focus lies in the ability to continue providing the highest standards of care for the patients in our hospitals.

Delegating anesthetic monitoring of intubated patients solely to a veterinarian or licensed technician will place additional levels of burden on teams that are already stretched thin by the lack of available LVT’s. The most current statistics indicate that in Virginia there are 0.48 licensed technicians for every veterinarian, not taking into consideration the uneven distribution between urban and rural practices. Given the high rate of burnout resulting in a large number of graduates leaving the field less than 5 years after graduating, the veterinary community is going to be hard pressed to employ enough staff to abide by regulations.

Following the institution of this new regulation there are a few different possible options that practices will be forced to employ. Hospitals that perform more than one procedure at a time are likely to end up having a single technician monitoring all the patients, or technicians that are required to simultaneously monitor anesthesia while performing dentals. Veterinarians may also be forced to monitor their patient during surgeries which puts patients at risk as one person cannot properly concentrate on both tasks. These solutions all carry higher levels of risk than having a trained assistant monitor each patient individually.

Other hospitals may choose to avoid intubating patients at all and move towards injectable anesthesia in order to comply with the law and utilize their available staff. As an industry, we have spent years educating clients on why proper anesthetic management is a benefit to their pets, only to see the potential for this to slow as practices are being forced to choose whether they break the law to provide proper anesthesia or provide substandard care that could result in increased patient risk.

While I appreciate the effort to emphasize the importance of licensed staff in practices, with a state-wide shortage of technicians I do not see this proposal resulting in the outcome that the board expects. Instead I truly believe it will result in a decline in patient safety and care, and may further result in more LVTs abandoning their careers as more responsibility is placed on their shoulders.

In my experience, there are assistants currently monitoring anesthesia in private practices that are highly trained and I ask the board to consider allowing those who have proven their competency through testing or training programs to continue monitoring intubated patients.

Thank you for your consideration,

Sarah McKinney