I support these changes to the Code of Virginia as they apply to the practice of veterinary medicine: 

In 18VAC150-20-10. Definitions, delete the following definition: 
"Immediate and direct supervision" means that the licensed veterinarian is immediately available to the licensed veterinary technician or assistant, either electronically or in person, and provides a specific order based on observation and diagnosis of the patient within the last 36 hours. 

And replace it with these three definitions: 
“Direct supervision” means the supervising veterinarian is on the premises at the time the patient is receiving veterinary care and is quickly and easily available to assist the person being supervised. 

“Immediate supervision” means the supervising veterinarian is in the immediate vicinity of where veterinary care is being provided and is actively engaged in supervising this care throughout the entire period it is being provided. 

“Indirect supervision” means the supervising veterinarian is not on the premises but is available for immediate contact by telephone, radio, or other electronic means; has given either written or oral instructions for treatment of the patient; the patient has been examined by the supervising veterinarian as acceptable veterinary medical practice requires; and the patient, if previously anesthetized, has recovered to the point of where it can safely be left in the care of a licensed veterinary technician. 

In 18VAC150-20-130. Requirements for practical training in a preceptorship or externship, delete the following section: 
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. 

Replace 18VAC150-20-130.B with a new section, number to be determined: 
18VAC150-20-XXX. Owner notification and consent required for practice by students, externs, and preceptees; and owner notification required for practice by interns and residents 

Subject to the further provisions of this Section 150-20-XXX, where students, externs, preceptees, interns, or residents will practice on a privately owned animal, in advance of such practice the owner shall be notified; and in the case of students, externs, or preceptees the owner’s consent shall be obtained. 

A. In any situation where an individual who is enrolled in but has not yet graduated from an AVMA accredited school or college of veterinary medicine or veterinary technology performs a task within the scope of §54.1-3800 of the Code of Virginia at a time when the owner is not present with the animal and observing the student, the owner shall be notified in advance and consent obtained. However, the following tasks do not require notification and consent: 
1. Grooming; 
2. Feeding; 
3. Cleaning; 
4. Restraining; 
5. Assisting in radiology; 
6. Setting up diagnostic tests; 
7. Prepping for surgery; 
8. Dental polishing and scaling of teeth above the gum line (supragingival); or 
9. Filling of Schedule VI prescriptions under the direction of a veterinarian licensed in Virginia. 

B. In any situation where an intern or resident will participate in diagnosis or will order, perform, or assist with any diagnostic or surgical procedure or treatment, the owner shall be notified in advance and shall be provided with an explanation of the role of the intern or resident and the role of the supervising veterinarian. 

C. In any case where notification is required, if the owner is on the premises, the notification (and consent if applicable) shall be in writing. If the owner is not on the premises, notification may be provided (and consent obtained if applicable) by telephone or electronic communication. In an emergency situation, care may be provided before notification is given, but the owner shall be fully informed of the care provided, and by whom, at the first opportunity. 

D. For students, externs, and preceptees notification shall include: 
a. name; 
b. level of education 
c. task(s) to be performed; 
d. whether the task will be performed with immediate, direct, or indirect supervision; and 
e. name of the supervising veterinarian or licensed veterinary technician

Sincerely, Robert Poignant 300 Lansing Ave., Lnchburg, VA 24503-2744