As a concerned Virginia veterinarian, who has spent over a decade involved in private clinical practice both as an assistant and a veterinarian, I wish to add my name to the list of my colleagues requesting the Board reconsider the wording and implementation of the underlined passage in the proposed regulation:

18VAC150-20-172. Delegation of duties.

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 has been amply researched and argued by my colleagues, the supply of Licensed Veterinary Technicians (LVTs) in Virginia is currently woefully inadequate to implement the policy as worded, without having a severe deleterious effect on patient care and the economics of practice.  I can testify firsthand that assistants properly trained in the monitoring of patients under anesthesia (in this case, specifically referring to intubated patients) only enhance efficiency and quality of care.  This is of vital importance in large, busy practices in urban/suburban areas, and can be absolutely essential for practices in rural areas or underserved communities, where LVTs can be few and far between.  Again, as my colleagues have pointed out, to deny practitioners this option would be to unnecessarily divide the attention of veterinarians and licensed technicians away from the immediate care of individual patients, and take away their flexibility to intervene with other patients when required.

Furthermore, implementing this policy now would necessarily require practices to make economic decisions about cutting back on the number of patients served, while simultaneously causing them to cut back on the quality of care provided to avoid being in non-compliance with the proposed rule (the classic example would be using more general anesthesia without intubation).  It seems to me responsible governance would be about promoting both the economic growth of the industry and the value of high-quality care to the public it serves.

Nothing we are counter-proposing is intended to somehow absolve veterinarians and licensed technicians of ensuring the well-being of their patients under general anesthesia.  In fact, we know from experience that well-trained anesthetic assistants only make the quality of medicine and surgery provided better.  We are only stating that, while we appreciate the Board’s intent to recognize the value of LVTs, we find the proposed rule incredibly impractical at this time, given the shortage of licensed technicians and relatively high burn-out rate.

We would suggest amending the proposed rule to read:  “…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….”

While I am no longer in private practice, I feel I have plenty of expertise to offer in this argument, and it is a matter near and dear to my heart.  Thank you very much for your consideration.

Jeremy Dubin, DVM

Supervisory Public Health Veterinarian

USDA-Food Safety Inspection Service (Landover, MD Circuit)