Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Veterinary Medicine
 
chapter
Regulations Governing the Practice of Veterinary Medicine [18 VAC 150 ‑ 20]
Action Elimination of restriction on practical training only in final year of veterinary school
Stage NOIRA
Comment Period Ended on 7/1/2015
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6/26/15  11:10 pm
Commenter: Jennifer E. Daly, Ph.D.

Duty to protect patients and the public NOT eliminate restrictions
 

The purpose of a Licensing Board is to protect patients and the public from harmful practices and incompetent or impaired practitioners.  It is NOT the purpose of a Licensing Board to “eliminate burdensome restrictions” to allow training institutions to expand training into unaccredited community clinic settings.  I am truly astonished by the posted Action Summary. 

An infinite number of comments by veterinary students and professors does not change the duty of the Board to act for the good of patients and to PROTECT the public. 

Training safe and competent medical providers is the sole responsibility of an accredited veterinary medicine program.  The responsibility of the Licensing Board is to “ensure[s] competence and integrity to engage in the regulated professions” (§ 54.1-2400. General powers and duties of health regulatory boards).

Of course veterinary students should get as much direct, supervised experience as possible before they are licensed to practice medicine on our beloved family pets and animals in the State of Virginia.  It is somewhat disturbing to learn that accredited training programs do not believe that they currently provide enough training to their graduates.  Perhaps the Board should consider reviewing these programs to determine whether or not the public and patients are fully protected. 

Rather than “eliminating burdensome restrictions,” the Board should develop STANDARDS and REGULATIONS that ensure that programs that train veterinarians are (a) ACCREDITED by an appropriate authority and (b) follow clear and specific REGULATIONS governing supervisors, supervision, and supervisees.  In other areas of medicine, students REGISTER with the Board as trainees prior to direct care and LICENSED supervisors ATTEST to compliance with Board regulations.  The current change does not even specify this simple oversight to ensure safe practices and regulatory compliance by training sites that are, in most cases, licensed by the Board without even a site visit.  The Veterinary Licensing Board needs to align its practices with other Health Boards and PROTECT PATIENTS AND THE PUBLIC both during and after training.

Current regulations governing trainees DO NOT require students or clinics to obtain consent from pet owners for any procedures except surgery.  This is unacceptable and denies consumers of their basic rights to be informed that a student is providing care for their beloved family member.  It is also at odds with AVMA ethical standards that veterinarians “be honest in all professional interactions” within the veterinary-client-patient relationship.  Allowing students to practice medicine without informed consent from pet owners weakens trust in the profession and the Board.  INFORMED CONSENT from consumers should be standard practice for ALL care by students.  Consumers have a right to all the information necessary for them to act in the best interest of their pets.  They should be informed:  (1) who is the attending veterinarian; (2) how students will be supervised; and (3) how to contact the Board if they have concerns about the care that they receive from a supervised trainee and/or licensed supervisor. 

I strongly support strengthening training for veterinary students prior to licensure.  This change does not even begin to accomplish that goal.  I OPPOSE THIS CHANGE.

CommentID: 40420