I am writing in response to ‘18VAC150-20-172. Delegation of duties’ proposed changes on the Virginia Regulatory Town Hall website. 

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.

- I do not think that the word anesthetic should be taken out as I do think only LVTs or veterinarians should be giving anesthetic injections. However, assistants should be able to monitor patients that are sedated/anesthetized even if they are still intubated. Not every facility has enough LVTs on hand to monitor each sedated patient that is intubated. By limiting this job to only licensed personnel, then will have to find more LVTs which is hard to do in rural Virginia.  The delegation of monitoring sedated/anesthetized patients that are intubated should be given by the veterinarian to either an LVT or assistant that has adequate training to safely monitor an intubated patient. 

C. The following tasks that may be delegated by a licensed veterinarian to a properly trained assistant include but are not limited to the following:

1. Grooming;

2. Feeding;

3. Cleaning;

4. Restraining;

5. Assisting in radiology;

6. Setting up diagnostic tests;

7. Prepping for surgery Clipping and scrubbing in preparation for surgery;

8. Dental polishing and scaling of teeth above the gum line (supragingival);

9. Drawing blood samples; or

10. Filling of Schedule VI prescriptions under the direction of a veterinarian licensed in Virginia.

- The phrase ‘include but are not limited to the following’ should not be removed from the regulations as assistants are trained to do several other tasks and have both the talent and ability to do more than what is listed above. With removal of the phrase, it makes it seem like assistants will only be able to do 1-10 on the list and nothing more. 

Sincerely, 

Hillary Rader, DVM 

King's Mountain Animal Clinic - Collinsville, VA