February 7, 2017

Dear Virginia Board of Veterinary Medicine,

I am writing to urge that the Board reconsider implementing the proposed changes to 18 VAC 150-20-172 as currently written.   Specifically, I am concerned that limiting anesthesia monitoring of intubated animals to DVMs and LVTs will have the unintended effect of reducing the overall quality of veterinary care in Virginia.

As other commenters have pointed out, Virginia, like many other states, has a shortage of LVTs.  Despite our concerted efforts to recruit LVTs, including a tuition reimbursement program, Banfield’s ratio of LVTs to DVMs is approximately 1:12.  Banfield currently employs 118 DVMs in the state of Virginia and only 16 LVTs.  In contrast, Banfield Hospitals employ 291 veterinary assistants in Virginia.  In those hospitals which do not currently have an LVT, the proposed changes would drastically limit that hospital’s ability to perform surgery and pose an unacceptable compromise to patient care by forcing the DVM to simultaneously perform surgery and monitor anesthesia.

All veterinary assistants at Banfield undergo rigorous training, including training in anesthesia monitoring.  Further, all veterinary assistants who assist with anesthesia monitoring at Banfield do so under the direct supervision of an LVT or DVM.  Prohibiting veterinary assistants from performing a task which they have been performing safely for years under LVT and DVM supervision is unnecessary and will adversely impact the quality of veterinary care in Virginia.  On behalf of Banfield and the veterinary industry I implore the Board to reconsider the proposed changes to 18 VAC 150-20-172.

Sincerely,

Daniel Aja, DVM

Chief Medical Officer

Banfield Pet Hospital

18101 SE 6th Way

Vancouver, Washington 98683

www.banfield.com