I have reviewed 18VAC150-20-10 et seq., Regulations Governing the Practice of Veterinary Medicine, and my comments are follows.

There is nothing excessive in these regulations.  All elements are necessary for protection of the public, and none are unreasonable in terms of what they require of veterinary practices.

If anything, these regulations represent under-regulation, in that § 54.1-3804 of the Code of Virginia lists specific powers of the Board, the second of which is  “to establish and monitor programs for the practical training of qualified students of veterinary medicine or veterinary technology in college or university programs of veterinary medicine or veterinary technology.”

However, the Board has so far chosen to do no more than establish the point at which veterinary medicine and veterinary technology students may obtain practical experience outside the academic setting, and identify one situation in which owner consent is required.  The approval of practice sites is left to the total discretion of the academic programs, and the Board has no idea how many students are working in private veterinary offices, or which offices.

This needs to change, as the academic programs are performing little or no assessment of the practices which they are approving for the training of their students.  This is manifest in the rate of problem practices on their approved lists.

The veterinary medicine program at Virginia Tech has 850 approved sites, 140 of which are in Virginia and 116 of which are private practices.  Twenty-five percent of those practices have one or more veterinarians who have been reprimanded by the Board, some of them more than once.  Their offences range from the “minor” issues of failing to obtain the required annual continuing education or practicing with an expired license to some very major failings, such as providing substandard care or permitting an unlicensed person to perform surgery.

The practices which are serving as preceptorship locations for veterinary technicians are only slightly better.  Fifteen percent of the supervising veterinarians for Blue Ridge Community College have a disciplinary record.  For Northern Virginia Community College, sixteen percent of the practices which serve as preceptorship sites for the on campus program and seven percent of the veterinarians who serve as mentors for the online program have disciplinary records.

These regulations need to be expanded to set minimum standards for a veterinary practice to serve as a preceptorship site and for veterinarians to mentor veterinary medicine or veterinary technology students.  In addition, these regulations need to be expanded to assure that the Board of Veterinary Medicine knows which students are practicing in private offices and which veterinarians are responsible for their supervision.

Citizens of this state are entitled to assurance that their future veterinarians are trained by individuals whose professional competence, ethics, and teaching ability are at the upper end of the curve.  The current arrangement is inadequate, and is unfair to students and their future patients and clients.