To Whom It May Concern:

The National Society of Genetic Counselors (NSGC) is submitting comments regarding the drafting of regulations for the licensure of genetic counselors, specifically 18VAC85-170-60 Licensure requirements pursuant to Chapter 266, section 54.1-2957.18 (D) which is a grandfathering clause for counselors;

B. Pursuant to § 54.1-2957.19 D of the Code of Virginia, applicants for licensure who do not meet the requirements of subsection A of this section may be issued a license provided they (i) apply for licensure before July 1, 2016; (ii) comply with the board's regulations relating to the NSGC Code of Ethics; (iii) have at least 20 years of documented work experience practicing genetic counseling; (iv) submit two letters of recommendation, one from a genetic counselor and another from a physician; and (v) have completed, within the last five years, 25 hours of continuing education approved by the NSGC or the ABGC. For the purpose of this subsection, the board deems the provisions of Part IV (18VAC85-170-110 et seq.) of this chapter to be consistent with the NSGC Code of Ethics.

Although the bill for licensure was signed in 2014, NSGC is concerned that rules have not been finalized and the application deadline for this section of law has expired. The application requirements in the law are very clear. NSGC respectfully requests that the draft rule be modified to include clarifying language that individuals who supplied the required application information to the Virginia Board of Medicine by the July 1, 2016 deadline, as required by law, are deemed to have met the requirements under section 54.1-2957.18(D).  This will ensure the final rule implements the law as the legislature intended.  

NSGC appreciates the consideration of these comments as you work to finalized the rule and regulations.

If you have any questions, please do not hesitate to contact me directly.

Sincerely,

John Richardson

Director of Policy and Government Relations

National Society of Genetic Counselors

2025 M Street Suite 800 NW

Washington, DC 20036

202-367-1239