To Whom This May Concern:

I am sending this comment in response to the regulations regarding the licensure of genetic counselors, Chapter 266, section 54.1-2957.18 (D) which includes a grandfathering clause for counselors, such as myself, that have been practicing for over 20 years but do not have their master's degree. Although the bill for licensure was signed in 2014, the date listed to apply for licensure based on the grandfathering clause was July 1, 2016, which has now expired. The expiration date of the grandfathering clause was inserted into the bill with the full intent that all genetic counselors would obtain licensure by that date. Unfortunately this process has taken longer  than anyone imagined. I have complied with the date listed in the grandfathering clause by submitting the required documents to the Virginia Board of Medicine by certified mail which they received June 21, 2016. However, the feedback I received from them was that this action may not be adequate for me to obtain licensure after the regulations are passed. I am posting this comment to request that as the regulations are finalized, that either the date for the grandfathering clause be updated to allow adequate time for counselors to whom this pertains to comply with the requirements, or that the language be changed to permit acceptance of the documents sent in prior to July 1, 2016 so that those counselors like myself can obtain licensure. I have been a prenatal genetic counselor for 29 years. If the date or language for the grandfathering clause is not amended and I am unable to obtain licensure due to this circumstance, then I will no longer be able to call myself a genetic counselor or maintain a job in the field that I have worked in for more than half of my life. During this time I have assisted thousands of patients by providing genetic counseling services, trained 18 years of master's level genetic counseling students at VCU who are now my colleagues, and elevated the standard of care in the practices where I have worked by imparting my expertise in this field.

Thank you for your time and consideration of my proposal to modify the regulations regarding the grandfathering clause. 

Respectfully,

Laurie Tams, Genetic Counselor