Virginia Regulatory Town Hall
Agency
Virginia Department of Health
 
Board
State Board of Health
 
chapter
Virginia Radiation Protection Regulations: Fee Schedule [12 VAC 5 ‑ 490]
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9/16/09  7:51 am
Commenter: Peter S. Ross, MD, N. VA Endocrinologists

Excessive licensing fee
 

Apparently because of the absence of a small business discount, you charge nearly twice what we were paying to the NRC for the same service. 
 
We are the largest private practice provider of thyroid I131 therapies in N. Virginia.  Our ability to treat our own patients offers huge benefits to our patients in terms of convenience and, most importantly, safety (no misadminstrations in some 3,000+ cases over nearly thirty years), and cost.  However, our revenues--maybe $30,000 per year--from our program barely cover our costs.  In fact, economics have already forced us to give up I123 scans and uptakes. 
 
Doubling of our licensing fee is quite likely to force us out of nuclear medicine completely.  I think this would be bad for us, our patients, and for RMP--I suspect that RMP's costs to license our simple program (receive I131 capsules; administer same.  Period.) are lower than even the NRC rate for small business.
 

CommentID: 9962