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.