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.

Owners of animals should have to be informed and give consent for students to practice medicine on their pets without DIRECT supervision!  I'm all for educating students (including when the patient is me) but just like with human patiens, informed consent is very important!  Clients should not have the incorrect impression that their animal is getting full vet care if a full vet is not even in the room!

The Board needs to require schools offering veterinary programs to only allow students to be trained in practices that have not been reprimanded by the Board until the reason for the reprimand is corrected. In other words, if a practice has been reprimanded by the Board no Virginia veterinary school should have students training in that practice until the reason for the reprimand has been corrected. The schools should be required to provide the Board with the list of the practices which train each schools' students.

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.

The purpose of the regulations is to protect practicing vets, the public and our companion animals.  This Board in my opinion fails that mandate in so many areas and when the chance arises to make meaningful changes, the board again fails both the public and our pets.

This Board does not even start with the most basic essential principle of providing care which is obtaining informed consent, ideally written informed consent, from the owner of the animal which is about to receive care from a student.

That this Board would allow a practicing vet who has been reprimanded by the Board to supervise students is not surprising.  This is the same Board that had a Board member who had twice been sanctioned by the board to be a participating member of the board and pass judgments over the care provided by other vets.  If this former board member could not conduct his own practice properly, how could the public have any confidence in his ability to pass judgments over another vet's standard of care?

How can the public have any confidence in the entire complaint process?  A pet owner files a complaint and the vet is allowed to see the complaint and respond.  The pet owner is not allowed to see the vet's response, which may contain inaccuracies.  An investigation is conducted, and the pet owner is not allowed to see the results of the investigation, which may and in my case (as verbally reported to me), did contain at least one inaccuracy.  And then the Board does not have an appeal process for the pet owner, but the vets are allowed an appeal process.  Is  that fair?  Is that transparent?

In my opinion, nothing will change that will help to protect the public and most important of all protect our animals, unless the Board is disbanded and a completely independent agency is created.  An agency that does not have active VA veterinarians on it and instead has retired vets or vets from out of state who do not practice in VA.

If significant changes and real transparency does not occur, VA will still have a standard of care that allows a vet to notice and document in the record that a kitten is non responsive 5 hours after surgery and the same vet does not check vital signs, does not check any lab work, does not call the owners, does not check the incision and then allows the kitten to die all alone overnight. The owner is never given the opportunity to make an informed decision to transfer the kitten to an overnight emergency vet for monitoring.   This is what this Board has determined is a reasonable standard of care for vets in VA.  (Anyone who wishes to review this kitten's record and the Board's response may contact me at mollymittens7@gmail.com).

The citizens and companion animals in VA deserve better than what this Board currently offers, in my opinion.

Respectfully submitted,

Molly Mittens Mom

The Veterinary Technology Program at Blue Ridge Community College allows students to choose their preceptorship practice but their selection must be approved by the Program.  This process provides the strongest learning experience for students as they are able to pursue their interests in an environment that best suits their needs.  The program director personally visits preceptorship practices each year.

Using this method, there are very few supervising veterinarians being utilized currently who have had a past disciplinary issue (roughly 8%, representing the 2014 and anticipated 2015 preceptorship sites).  The most recent date of any disciplinary action concerning a current BRCC preceptor was 12 years ago.   The program feels there is a strong supervision and training program for veterinary technology preceptorships and will continue to be diligent in efforts moving forward.