When this change was first proposed it was clear from vet student comments that they are not getting what they need from the program at VA Tech.  I strongly support improving veterinary education, but I do not believe that this change will accomplish that goal.

My first objection is that this change would permit students to practice as early as their first year of vet school.  This is much too early.  Practice before the start of the third year should be limited to observation only.

Second, I cannot support any expansion of student practice in an off-campus setting until the Board takes steps to assure that those veterinary practices are at the upper end of the continuum relative to clinical competence, professional ethics, and teaching ability.  25% of the vet school’s list of approved practices in Virginia have one or more veterinarians who have been fined and/or reprimanded, some more than once, for infractions ranging from the “minor” issue of failing to obtain required continuing education to problems as major as permitting an unlicensed individual to perform surgery.  This does not provide the quality of education which the students need, and their future clients and patients deserve.

Last but definitely not least, I strongly object to this statement found at http://townhall.virginia.gov/L/GetFile.cfm?File=C:\TownHall\docroot\33\4277\7088\AgencyStatement_DHP_7088_v1.pdf: “The purpose of the regulatory action is to eliminate a burdensome restriction on the preceptorships for veterinary students in which they gain practical experience under the direct supervision of a licensed veterinarian. Currently, students are not allowed to be engaged in a preceptorship until their final year in veterinary college.”

This implies that students have some right to have access to patients prior to their fourth year, and that this right is being improperly denied.  THERE IS NO SUCH RIGHT.  Student access to patients is a privilege, and one which should only be granted by the patient’s owner.   Yet the owner's right to give or withhold consent is currently being violated because regulations permit veterinarians to use patients as teaching material without even informing the owner – much less obtaining their consent – unless they intend to go to the extreme of letting the student perform surgery unassisted.  This is the true burden relative to student practice, and it is being borne by the patient and the owner, not the student.  This absolutely must change, and as it applies to both veterinary medicine and veterinary technology students, before any other changes are made to student practice regulations.

Support an owner's right to be notified and required to give or withhold their consent for a student to practice on their pet.

I am not opposed to veterinary students having the ability to obtain practical experience by providing care to pets in a verterinary clinic. However, I strongly believe the pet's owner should be notified and must be given the opportuntity to deny or give consent prior to a student practicing on their pet.

In addition, veterinary students should be limited to observation only during the first two years of vet school.

I believe that veterinary students have not right to  practice on anyone's beloved pet without that caregiver's consent.  Furthermore, I feel it would be a wise practice for them to observe until the start of their third year.

A few years ago, I was set to have my cat get a radioactive thyroid procedure done at Virginia Tech, but I had a bad feeling about it and cancelled.  I ended up making the long trip to and from to Radio Cats in Richmond.  That proved to be the right decision, as the Virginia Tech tech told me my cat would stay isolated in the facility basement for one full week, which was entirely unnecessary and unimaginable.

Virginia Tech must not put the lives of these innocent creatures in jeopardy for the sake of furthering the education (which is questionable) of the the vet students.

I believe veterinary medical students should not be allowed to perform medical diagnosis or proceedures, especially surgery, on animals without faculty supervision until the fourth year of schooling.  I also believe the pet owner, under the present policy of the VT medical school, must be informed if a medical student who is not in his/her fourth year is to perform a diagnosis or proceedure without faculty supervision.

Please heed the sugestions of Lee Henkel. They are most Scientific, Proper, and Humane for the students and the Research subjects.

Please obtain permission from the animal's owner when allowing a student to perform any procedure. It would be an ethical and responsible decision and would put owners minds at ease. Thank you.

I support veterinary students having the ability to obtain practical experience at vet schools and in veterinary hospitals. However, I support the pet owner's right to be notified and given the choice to deny or give consent prior to student practice on their pet. In addition, veterinary students should be limited to observation  during the first two years of vet school and practice under supervision throughout their education. Student preceptorship must only be allowed at licensed hospitals/clinics that have a recognized standard of excellence by the Vetinary Board. Lee Henkels recommendations should be instituted. 

I am writing regarding the upcoming proposal to allow veterinary students access to patients without the owners consent or knowledge.  I do not deny the positive aspects of hands-on experience veterinary students can obtain while working in an animal hospital, but the right of the animal's owner to either approve or deny this practice with their own pet should be present.  This will allow the animal and it's caretaker to make an informed decision regarding all health care for their families.  Thank you for taking the time to consider my comments. 

I can neither understand nor accept the Board and Virginia Tech's position on this matter. It is unthinkable to me that anyone other than a fully qualified veterinarian would provide medical care to my pets! It seems such a no-brainer: if a veterinary student is to be involved in animal patient care, simply notify the owner and gain their permission.

When this change was first proposed it was clear from vet student comments that they are not getting what they need from the program at VA Tech. I strongly support improving veterinary education, but I do not believe that this change will accomplish that goal.

My first objection is that this change would permit students to practice as early as their first year of vet school. This is much too early. Practice before the start of the third year should be limited to observation only.

Second, I cannot support any expansion of student practice in an off-campus setting until the Board takes steps to assure that those veterinary practices are at the upper end of the continuum relative to clinical competence, professional ethics, and teaching ability. 25% of the vet school’s list of approved practices in Virginia have one or more veterinarians who have been fined and/or reprimanded, some more than once, for infractions ranging from the “minor” issue of failing to obtain required continuing education to problems as major as permitting an unlicensed individual to perform surgery. This does not provide the quality of education which the students need, and their future clients and patients deserve.

Last but definitely not least, I strongly object to this statement found at http://townhall.virginia.gov/L/GetFile.cfm?File=C:\TownHall\docroot\33\4277\7088\AgencyStatement_DHP_7088_v1.pdf: “The purpose of the regulatory action is to eliminate a burdensome restriction on the preceptorships for veterinary students in which they gain practical experience under the direct supervision of a licensed veterinarian. Currently, students are not allowed to be engaged in a preceptorship until their final year in veterinary college.”

This implies that students have some right to have access to patients prior to their fourth year, and that this right is being improperly denied. THERE IS NO SUCH RIGHT. Student access to patients is a privilege, and one which should only be granted by the patient’s owner. Yet the owner's right to give or withhold consent is currently being violated because regulations permit veterinarians to use patients as teaching material without even informing the owner – much less obtaining their consent – unless they intend to go to the extreme of letting the student perform surgery unassisted. This is the true burden relative to student practice, and it is being borne by the patient and the owner, not the student. This absolutely must change, and as it applies to both veterinary medicine and veterinary technology students, before any other changes are made to student practice regulations.

Require owner consent for all veterinary care when students are involved.

Please require owner consent. Thank You.

Always, always, always owners should be asked to consent to student practice on their pets who cannot speak for themselves.  I simply cannot understand why any other practice is acceptable.  We would not allow such a thing with our children, why should allow it with our very vulnearble, sometimes quite ill, precious pets.

The AVMA policy on Informed Consent states

“Informed consent better protects the public by ensuring that veterinarians provide sufficient information in a manner so that clients may reach appropriate decisions regarding the care of their animals.”

Veterinarians per the policy should inform the client in a manner that would be understood by a reasonable person…risk assessment, and prognosis.

“The client or authorized agent should indicate that the information is understood and consents to the recommended treatment or procedure.”

One must ask would a reasonable person want to be told that a student would be working with their furry family member.  Most of the public comment here would support that the reasonable person would want to know about any care that a student is providing to their pet.

Part of the client’s decision making for informed consent involves knowing what the risks are to their animal.  The AVMA position includes providing a risk assessment to the client.  Does is increase the risks if a non-licensed student is working on my pet?  Yes, maybe only minimally in some case or maybe significantly in other cases.  But that is valuable information that I as a pet owner need.

“Documentation of verbal or written informed consent and the client’s understanding is recommended.”

I would think as a minimal to protect the public, who pay the vet’s bills, and to protect our pets, this board should follow the policy of their own professional organization.

The remaining question is why the board, the vet school, vets and vet students oppose such a simple requirement of informing the pet owner and obtaining the consent from for services that a student provide to our pets beyond simple observation. What is wrong with being completely open and transparent with the client, not to mention honest?

Respectfully submitted

Molly Mittens Mom

I have three comments on this proposal. First, practice before the start of the third year should be limited to observation only.

Second, I cannot support any expansion of student practice in an off-campus setting until the Board takes steps to assure that those veterinary practices are safe in terms of professional examples. 25% of the vet school’s list of approved practices in Virginia have one or more veterinarians who have been fined and/or reprimanded, some more than once, for infractions ranging from the “minor” issue of failing to obtain required continuing education to problems as major as permitting an unlicensed individual to perform surgery. These clinics having serious infractions should not be teaching students. Any new clinics need to be reviewed for professional ethics before being approved.

Third, student access to patients/pets is a privilege, and one which should only be granted by the patient’s owner. Yet currently regulations permit veterinarians to use patients as teaching material without even informing the owner – much less obtaining their consent – unless they intend to go to the extreme of letting the student perform surgery unassisted. This has to change. Thank you, Edna Whittier, Floyd, VA

a student veterinarian should get experience before operating on any animal.

Hello, I opposed the proposed regulatory action which would allow Vet students to practice before their fourth year of residency
By removing this restriction I believe that animals will be harmed and misdiagnoised
As an addenum the proposal still does not address in the circumstances and scenarios in which direct supervision of students in the act of treating animals is applied
The application of such a method is not good in keeping up with standars of any vet school or any regulatory board of medicine
In order to be brought up to standard such things as owners content must be required
http://register.dls.virginia.gov/details.aspx?id=4940

I have noticed several comments pertaining to requiring owner consent in order to approve this regulation change.  To clarify, the original regulation as it is written requires informed owner consent.  This change would not alter that requirement, no student would be permitted to examine or perform any medical procedure on a client-owned animal without their informed consent.  Additionally, the requirements for direct supervision by a licensed veterinarian would still apply. 

Access to quality hands-on experience for first through third year DVM students can lead to more highly-trained and competent doctors upon graduation.  Of course, the current program produces competent and excellent new veterinarians.  However, improving practical training for pre-clinical students can help make them even better which is beneficial to both students and the public.

I am almost certain that the general public is confused and misunderstood about the intent of this legislation. There is no circumstance where any student, be it a fourth, third, second, or first year, is the SOLE person examining and performing procedures on a client-owned animal.  Every single case is overseen by a state licensed veterinarian, who the client has agreed to see.  Even 4th year students who perform physical exams have their findings rechecked by a licensed veterinarian to assess the student's accuracy.  Furthermore, any person who brings their beloved pet to a teaching hospital must be operating under the expectation that there is animal is going to be used for teaching purposes.  All clients are required to sign a form agreeing to said stipulations.  Should we pass legislation that permits students earlier in their education to perform procedures, a similar form and signature would be required.  Another misunderstanding that I believe the public has about veterinary students concern their level of proficiency in terms of their progress in veterinary school.  While veterinary students become more knowledgable through the years, it is not as if they will be magically more capable at performing physical procedures when the third or the fourth year begins (versus first or second year). Whether students start learning procedures and physical exam techniques on a day 1 or day 1000, their level of proficiency will be similar, assuming they are being guided under the the presence of licensed veterinarians and specialists.  

The veterinary profession, much like the medical profession, has an extremely high learning curve.  The more experience they are given in a safe environment under the guidance of experienced professionals, the more likely Virginia Tech will be able to produce quality, well-prepared veteriarians for day 1 of their careers.  It is impossible for a veterinary student to gain enough practical experience in veterinary school, even if they were permitted full access for the full four years. Limiting them to a single year of full immersion is simply inadequate.  This is why so many veterinary students seek internships after they complete their schooling; they want to feel better prepared.  

Practical experience is the only way to gain confidence.  Books, papers, cadavers, and knowledge are great tools to have and to work with, but they are simply not substitutes for cinical experience in a field that is constantly evolving,  Please consider this legislation very carefully before voicing your opinion.  Personally, I believe the entire veterinary education field needs to be redesigned and revamped.  This is not going to happen anytime soon, so our legislature must recognize this and do the next best thing:  provide vet students with the opportunity to learn earlier on in their educations.

I am fully in support of this amendment. As restrictions are already in place to limit students to practicing information they have already been taught and only under the direct supervision of a licensed veterinarian, there should be no additional risk of harm to patients by allowing first through third year students to practice what they know. As the curriculum currently stands, first and second year students only learn some very basic procedures which inherently carry little to no risk of injury to the patient seeking care, but which require a great deal of practice to attain proficiency.

To illustrate, first year vet students learn the procedure of a routine physical exam. This should not injure a patient especially when performed under supervision of a DVM, but in order to conduct an expert-level exam (which can be necessary in order to recognize the minute changes associated with various illnesses) veterinarians must first be familiar with a wide range of patients and their varying physical forms, such as the vet school is unable to provide to its students except in the form of patients. As it stands now, students have only their fourth year to perform exams on as many animals as possible (while also trying to familiarize themselves with all the other aspects of clinical medicine) and then are expected to have that expertise by the time they graduate a year later. In reality, it takes at least several years of practicing exams before veterinarians can truly call themselves experts. Adding two summers of examination practice before graduation would surely improve graduating veterinarians' abilities in this area.

At this time, worry about students performing unauthorized complicated operations on sick pets, unbeknownst to their owners, is irrelevant. Students do not learn any surgery until their third year anyway, and by the time this semester is over (and therefore they have learned the information and would be allowed to practice it) they qualify as fourth year students and are already covered under the existing law. The concern over owner consent, though important, is a separate concern and has no place in this current discussion.

Practice makes perfect is an old saying that applies just as much to the veterinary proffession as it does to all other fields, if not more so due to the innevitable variability of our patients. As professionals,BSE often rely on our experience in performing physical exams and various other simple procedures such as drawing blood to obtain an accurate diagnosis that can make all the difference for both the quality of life of our patients, and our clients. However, we are not born with the skills we need to make such a diagnosis, so practice is essential for us to nurture our abilities so we can provide the best care possible. I firmly believe that the ability to practice under the watchful eye of a licensed professional is key for developing the skills we need as vets.

It is essential for my veterinary schooling to be able to practice technical skills such as performing a physical exam on a patient in order to better serve my clients and patients in the future. There is no better way to prepare future veterinarians! 

This amendment is key to providing students with access to the practical training we need to be competent veterinarians when we graduate school. As others have mentioned, practice does make perfect. The more students can practice skills, the better we will be at those skills. This amendment gives students a safe, secure way to practice our skills and minimize the learning curve when we become veterinarians.  

18VAC150-20-130. Requirements for practical training in a preceptorship or externship.

A. The practical training and employment of qualified students of veterinary medicine or veterinary technology shall be governed and controlled as follows:

1. A veterinary student who is duly enrolled and in good standing in a veterinary college or school accredited or approved by the AVMA and in the final year of his training or after completion of an equivalent number of hours as approved by the board may be engaged in a preceptorship or externship. A veterinary preceptee or extern may perform duties that constitute the practice of veterinary medicine for which he has received adequate instruction by the college or school and only under the on-premises supervision of a licensed veterinarian.

2. A veterinary technician student who is duly enrolled and in good standing in a veterinary technology program accredited or approved by the AVMA may be engaged in a preceptorship or externship. A veterinary technician preceptee or extern may perform duties that constitute the practice of veterinary technology for which he has received adequate instruction by the program and only under the on-premises supervision of a licensed veterinarian or licensed veterinary technician.

B. Prior to allowing a preceptee or extern in veterinary medicine to perform surgery on a patient unassisted by a licensed veterinarian, a licensed veterinarian shall receive written approval from the client.

I have serious concerns about the proposed change to the current requirement that only " students in the final year of his training or after completion of an equivalent number of hours as approved by the board" be qualified to receive practical training. (Although I do believe it is time for the Board to come into the 20th - at least - century and change that misnomer to his/her.) With this change, ANY student who is "duly enrolled and in good standing in a veterinary college or school accredited or approved by the AVMA" may "practice" on an animal. Had I not been privy to instances where animals were unnecessarily harmed due to interventions by students who were not correctly supervised, my concern would be lessened. However, not all "supervising vets" are equally congizant of and attentive to their responsibilities, and until such time as all veterinarians who supervise students are able to correctly and completely provide adequate, safe supervision, I cannot support this proposed change. My pets are my family. I would no sooner allow a student to "practice" on my pet than I would let an intern practice on my grandmother! We clearly have developed far superior regulations relative to practicing on our human patients. Until such time as the veterinary field establishes similar guidelines and oversight, let our less-experienced students stick to observation and simulation. Computers can do amazing things these days. Most vet and medical schools have done away with learning on animals. I'm sure Virginia's veterinary schools have the wherewithall  to provide these first-rate experiences to their students. In the meantime, I will "vote" with my feet, and only work with veterinarians who are in continuous, direct contact with my pets during diagnosis and treatment. I am fortunate that should my pet need advanced diagnosis or treatment, I have the ability to provide out-of-state treatment at facilities that only allow graduated veterinarian to treat them. My wish is for that to be the case for all Virginians.

There is absolutely no susbtitite for hands-on experience during our veterinary training. New graduates would be nowhere near as competent as they need to be if they were not able to practice the technical skills the profession demands. This would all continue to take place under the direct supervision of a licensed, experienced veterinarian, so there should be no fear that students are left on their own.

Hands-on experience is essential to our mastery of medicine. Under the current regulations, vet students get one year of hands-on experience under the direct supervision of a licensed veterinarian before we are released to practice medicine on our own. It seems evident that increasing that to four years of supervised hands-on experience will benefit not only vet students, but our patients as well. 

A pet owner needs to be notified, and required to give or withhold their consent for a student to practice on their pet. Thanks for providing this forum.

A pet owner needs to be notified, and required to give or withhold their consent for a student to practice on their pet. Thanks for providing this forum.

It seems to me just good common sense that owners should know who is treating their sick pets. This policy change that makes it possible for students to work in offices earlier in their training means that pets are definitely not receiving treatment from qualified, licensed vets as they may expect is happening. I am opposed to this policy change and still believe that owner consent is essential.

I have lost two dogs due to the inexperience of unsupervised students.  Owner consent must be mandatory.

Rather than avoiding clinics that have students, I would highly recommend SEEKING OUT these hospitals for family pet care! Well-run hospitals attract students who want to learn from good doctors with good equipment and ethics. Doctors who routinely work with students are up-to-date on procedures and protocols because they are always teaching. The proposed change to allow veterinary students at any point in the veterinary curriculum to perform routine procedures under the direct supervision of a veterinarian is a positive one. In my experience, owners have always been asked first before a doctor and student perform a procedure together. The doctor knows which procedures are appropriate learning opportunities for first, second, third, and fourth year students. Talk to your veterinarian if you are uncomfortable with anyone assisting with your pet.

As a rising second year veterinary student, I acknowledge my perspective is biased. However, previous to entering vet school I worked at a medical school and took (and continue to take) my pets to clinics where students are working. I have always believed that students practicing under careful supervision is by far the best way for ALL students to learn - medical, veterinary, dental, physical therapy, etc. Changing the current legislation to allow vet students to interact with patients before fourth year would be a huge improvement in training our future veterinarians. As the current law stands, even a third-year student who can competantly perform surgery in class cannot take the temperature or pulse of a client's pet. I absolutely agree that informed client consent is necessary when students are working with patients; this has always been the case AND will continue to be. Likewise careful supervision by attending veterinarians is key; I know this is already the case for practicing fourth-years and will continue to be moving forward. By giving students a chance to aclimate to a clinical environment earlier in their training, we can improve the effciency of the more advanced training they recieve in their 4th year. Even if it's just taking temperature, pulse, respiration rates and a history by a second year, this kind of hands-on clinical experience is unique and invaluable. For individuals concerned about students in the clinic, think about it this way: with supervised students assisting, you've got MORE highly educated and motivated individuals caring for your pet to the best of their abilities. As the saying goes, two heads are better than one! Everyone in vet school is there because they love animals and want to help care for them - please help us develop those skills to be the very best they can be in safe, supportive learning environment!

Cannot Support Without Changes

When this change was first proposed it was clear from vet student comments that they are not getting what they need from the program at VA Tech. I strongly support improving veterinary education, but I do not believe that this change will accomplish that goal.

My first objection is that this change would permit students to practice as early as their first year of vet school. This is much too early. Practice before the start of the third year should be limited to observation only.

Second, I cannot support any expansion of student practice in an off-campus setting until the Board takes steps to assure that those veterinary practices are at the upper end of the continuum relative to clinical competence, professional ethics, and teaching ability. 25% of the vet school’s list of approved practices in Virginia have one or more veterinarians who have been fined and/or reprimanded, some more than once, for infractions ranging from the “minor” issue of failing to obtain required continuing education to problems as major as permitting an unlicensed individual to perform surgery. This does not provide the quality of education which the students need, and their future clients and patients deserve.

Last but definitely not least, I strongly object to this statement found athttp://townhall.virginia.gov/L/GetFile.cfm?File=C:\TownHall\docroot\33\4277\7088\AgencyStatement_DHP_7088_v1.pdf: “The purpose of the regulatory action is to eliminate a burdensome restriction on the preceptorships for veterinary students in which they gain practical experience under the direct supervision of a licensed veterinarian. Currently, students are not allowed to be engaged in a preceptorship until their final year in veterinary college.”

This implies that students have some right to have access to patients prior to their fourth year, and that this right is being improperly denied. THERE IS NO SUCH RIGHT. Student access to patients is a privilege, and one which should only be granted by the patient’s owner. Yet the owner's right to give or withhold consent is currently being violated because regulations permit veterinarians to use patients as teaching material without even informing the owner – much less obtaining their consent – unless they intend to go to the extreme of letting the student perform surgery unassisted. This is the true burden relative to student practice, and it is being borne by the patient and the owner, not the student. This absolutely must change, and as it applies to both veterinary medicine and veterinary technology students, before any other changes are made to student practice regulations.

The very existence of this discussion speaks to a serious flaw in VTech's training regimen for veterinary students. Other professional schools around the nation (medicine, dentistry, psychology, social work) have protocols for experiential learning that include (1) clear notice that a practitioner is a student and (2) highly regarded professional settings that regularly train students in these fields. These settings have a commitment to education and provide thorough supervision of those assigned to their clinic, hospital, or social service program.

Furthermore, students are educated in the classroom and in clinical work in an orderly manner such that the student is not asked to do more than he or she has been prepared to do at any given point, and the public is not put in the position of endangerment. Would a second-year medical student be asked to perform brain surgery? No, but he very well might perform certain aspects of a physical examination or basic procedures and then discuss it with his medical supervisor. What's any different about veterinary training?

Vet students deserve to know they'll be asked to perform tasks that help them practice what they've learned, tasks within their comfort range but that also give them the opportunity to stretch; this they can do by learning from their supervising vets; thus they develop confidence that they're providing good service to their animal patients. Animal owners would know from the start that a student was working on their pet or livestock; it serves no one well for the owner not to know and not to be able to opt out of having a student work with their animal. However, in well-run internship programs, the public feels confident that students' services are based on the competence of the entire setting and are less likely to feel apprehension.

It's not clear to me, an animal-owning member of the public, that VTech has developed sufficient links to excellent clinical training settings for their vet students; this puts students and the animal-owning public in awkward and potentially painful situations. The school has produced many wonderful veterinarians but needs to work out these questions in a forthright manner that benefits students and public alike.

It is my right as owner and person responsible for financial costs to agree to or decline services performed  by students, trainees, or residents performing or observing any and all medical treatments, examinations, or diagnostic procedures on my animal.  

As a veterinary student, even though we have the opportunity to learn the different skills required to be a future veterinarian, we are often limited in our ability to practice those skills. Some of the basic skills, such as doing a physical exam, giving an intramuscular or subcutaneous injection, or placing a catheter are taught in laboratories but we have very little chance on practicing them since there are 120+ of us and only about 30 teaching animals. There are regulations the dictate how much can be done with these teaching animals for their protection. Being able to have more exposure would allow us to hone our skills even more, it would prepare us for fourth year and for life after school better. That being said, this increase in hands-on experience should be accompanied with a veterinarian supervision and the consent from the client. 

As a rising third year student, I am honored to have the opportunity to work towards joining the veterinary medicine community.  As a future veterinarians, we strive to gain as much experience as possible to become competent doctors.  However, as a pet parent, I can certainly empathize with a clients' potential concern with allowing a student to work with their pets.  By the same token, as an owner and future veterinarian, I want nothing more than to be 110% confident in every procedure I perform on an animal, no matter how small.  Even a practice which may be perceived as minor (such as a physical exam) can reveal significant clues to a potential, underlying health concern.  The best way to work towards achieving excellence is to practice and receive constructive feedback from a licensed, supervising veterinarian.  Any hesitant clients should know how grateful we are as students for the opportunity to learn from their pet, and not a single student would ever want to place an animal in a potentially compromising situation.  They can also rest assured they are in fact investing in their own pets' futures by ensuring futuring veterinarians have sufficient experience and skills to treat patients, so that one day this student becomes a doctor who is capable of saving another four-legged family member. 

The regulation clearly states that direct supervision by a licensed veterinarian is necessary, as is owner consent. A student will never be performing any diagnostic or procedure on a pet without first receiving the owners approval and certainly not without being supervised by a licensed professional.

I also want to assure people that we are not asking that first year students be allowed to perform surgeries. We are asking that students have expanded opportunties to practice skills and use knowledge relevent to where they are in their current level of education. In our first year of veterinary school we learn to draw blood, place IV catheters, and perform physical exams. Surgery is not performed until the third year of veterinary school, this regulation change is not going to authorize first year students to perform surgery.

I also want to share an example. I am a licensed veterinary technician - I am licensed in both MD and in VA. As an LVT it is legal for me to place IV catheters and prepare patients for general anesthesia - these are things I also learned and practiced during my first and second years of veterinary school. Currently as the laws are written it is illegal for me, despite my licensure, to perform these duties. But it is perfectly legal for students in other programs to perform these activities. What we are asking for is essentially, equal treatment for students. Please remember that veterinary students already have bachelors degrees, if not masters or doctorates - we are professional, animal loving, and responsible adults. There should be nothing wrong with a first year veterinary student performing a physical exam on a pet. This is how we learn. This is how we become the Veterinarians that are tasked with keeping your pets healthy and happy. We are asking for this change because we want to graduate being the best that we can be, because once we graduate there is no guarantee another doctor will be standing behind us to answer our questions. After we graduate there is no guarantee another doctor will be around to help us through a trying case. After we graduate we may be on our own - and we want to graduate knowing that we are confident and capable enough to take care of every pet that walks into our exam room. Our goals are entirely based in the health and welfare of each and every one of our future patients.

We appreciate the respect and trust of all of the pet owners in VA, please consider what we are asking for and rest assured that we will be doing nothing without supervision and your consent will always be requested.

Thank you.

Several comments in this forum have stated that the proposed regulations require owner consent for any procedures performed by a student/intern.  However, the regulations only require owner consent for a student performing unassisted surgery.   Specifically, the regulations state:  Prior to allowing a preceptee or extern in veterinary medicine to perform surgery on a patient unassisted by a licensed veterinarian, a licensed veterinarian shall receive written approval from the client.    The proposed regulations do not require owner consent for any other procedure. 

If most students are comfortable requesting owner consent for any procedure that they perform, why not broaden the requirement for owner consent in the proposed regulations?    I think that many of the commenters are assuming that veterinarians will inform their clients that a student will be examining their pets or performing a procedure.  Some veterinarians may but others may not.   All clients deserve to know who is practicing on their pets.  Whether clients are informed should not be left up to individual veterinarian practices.   The regulations should consider the client’s rights and interests as well as the student’s. 

The Board also needs to ensure that the veterinary practices where students practice are at the upper end of the continuum relative to clinical competence, professional ethics, and teaching ability.   Currently 25% of the vet school’s list of approved practices in Virginia has one or more veterinarians who have been fined and/or reprimanded.  This is unacceptable and does not provide students with the quality of education they need or their future clients and patients deserve.

Finally there is nothing in the proposed regulations that outlines what students could do in a practice in year 1, 2, 3 or 4.   Unless the Board provides more guidance on what is permissible, practice before the start of the third year should be limited to observation only.

I understand that students need to learn, but this makes me very uneasy, especially in the early years of vet school.  I take my cats to my vet for her professional expertise, and I don't like the idea of anyone who is not fully trained working on them. There are no circumstances where a student should even touch an animal without the owner knowing and giving their permission.  I doubt that I would agree to very much.

C Cooper, Radford VA

Vet students who will be working on animals need as early a start as they can get. Viewing procedures and assisting professionals is the best way to do this. But, they need to do this in a strictly supervised setting all four years. AND the animal's owners need to know the expertise and experience of those working on their animals and give their consent for student primary involvement.

As the Associate Dean for Professional Programs at the Virginia Maryland College of Veterinary Medicine I have oversight of the DVM program as well as being involved in teaching veterinary students.  Our students gain the knowledge, skills and aptitudes to become competent, practicing veterinarians over a number of years and involving a wide variety of experiences.  Even before they enter the DVM program, the average student has spent more than 400 hours in a veterinary practice, observing qualified veterinarians and helping where permitted.  Once in the DVM program, the College provides a rigorous training program aimed at developing skilled, capable veterinarians benefiting a variety of animal species (dogs, cats, horses, cattle, sheep, pigs etc).  

Students undertake skills training in a number of different settings, including on University farms and in our Veterinary Teaching Hospital, as well as in our newly developed Clinical Skills Laboratory (CSL).  In the CSL we use a wide variety of model and mannequins to help students develop the (motor) skills required to perform routine basic procedures, thus enabling them to be far more efficient when they perform these procedures on animals.  This skills training now starts in the first semester of the first year of the program, and continues over the next four years.  However, it has clearly been shown, that the models and mannequins cannot completely replace using animals to develop these skills.  Therefore, enabling students to further practice these procedures, not only when they at the College, but also when observing practice, would result in even more skillful veterinarians for Virginia and Maryland.         

I understand the concerns regarding notification of the animal's owner and fully support the requirement to request client approval before students are able to undertake any procedures on a client's animal.  Interestingly, many clients who bring their animals to our Veterinary Teaching Hospitall prefer to come to our hospital, even though they know that veterinary students will be working on their animals, as they are committed to help train the next generation of veterinarians.  Oversight of the student by experienced veterinarians, should also be a requirement. 

How I wished I had had more hands on, real world practice with the supervision of experienced veterinarians as a student.  I feel that I would have missed fewer things and made fewer mistakes as a new graduate.  There is nothing that can replace touching/palpating something for yourself, listening closely to a patient's breathing and heart (is that a murmur or the way the patient happens to be breathing in sync with it's heart rate?), examining eyes, ears, mouth and getting a full understanding of what is normal (including breed variation) and what is not.  This takes PRACTICE.  I did not feel that as a student I was allowed to do anything that was beyond my skill level, but that skill level would have been higher at graduation had I had more clinical experience.  Every exam I did was repeated by the attending DVM.   When I placed a catheter, I was coached by a DVM or LVT,  when I did a spay or neuter surgery it was with direct assistance and supervision on the attending DVM.  I was allowed to assist with other surgeries as well, discussing the plan (techniques and materials) prior.  The more you do and see, the better you become.  Best to gain as much experience while being coached and supervised so that our new DVMs will be more competent as new graduates when there is much less (if any) supervision and coaching.

As a veterinary clinician and educator for 30 years, I totally support veterinarian supervised experiences by students enrolled in a veterinary curriculum with consent from owners. The more practical experience a student has during their educational career, the better they will be at the practice of veterinary medicine upon graduation.  

With the proposed new curriculum at VMCVM integrating students into clinical clerkships at the end of their 2nd year of veterinary medical education, it is vital that these students have as much real world experience with practicing veterinarians as possible so that they will be able to use their clinical years of their educational experience to effectively develop the skills necessary for day one competency as a veterinarian.  Our students and the citizens of the Commonwealth deserve this.

J. Phillip Pickett, DVM, DACVO

Professor, Ophthalmology

VA-MD CVM