In the past couple of years, the Roanoke Valley has had three(one has since reopened) veterinary clinics close. In each of those cases, it has been difficult to impossible for clients and other veterinary clinics to obtain the patients' complete medical records After reading current regulations, it appears that a closing clinic is only required to notify clients if they sell or transfer all of the records to another facility. If they just close, they are not required to notify clients or transfer records.

In the past, this may not have been an issue as veterinary clinics rarely closed and patient records may have been limited to annual exams and vaccines. However, times have changed and economic situations have led to sudden closure of several clinics in our area alone. I am sure this situation is not limited to the Roanoke Valley. In addition, modern medicine and changing relationships with our pets have led medical records to be more complex. Most records include expensive lab tests and advanced diagnostics. Our patients and clients deserve to have access to these records.   

As we are modifying the current regulations, I would like us to develop a protocol for hospitals to follow that would better facilitate access to complete (not just vaccine) medical records for patients when a client closes but does not sell records to another entity.

In addition, I would like to concur with the numerous other comments regarding delegating monitoring anesthesia to a trained unlicensed assistant.  I believe that a trained unlicensed assistant should be able to monitor an ANESTHETIZED patient while under direct supervision of a veterinarian or LVT.  The use of the term anesthesia vs just sedation would be an important distinction in a court of law.  If needed, hospitals could submit a particular training protocol or possibly have assistants take a class or test to prove competence.  

Thank you.

Please feel free to contact me at my office 540-890-8500 if you would like more information.