To Whom It May Concern:

The Virginia Association of Genetic Counselors (VaAGC) is submitting comments regarding the drafting of regulations for the licensure of genetic counselors, specifically Chapter 266, section 54.1-2957.18 (D), the grandfathering clause for currently practicing genetic counselors.

Although the bill for licensure was signed in 2014, we are concerned that rules have not been finalized and the application deadline for this section of law has expired. The expiration date for 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 anticipated. VaAGC 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.  

VaAGC appreciates the consideration of these comments as you work to finalize the rule and regulations.

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

Sincerely,

Elizabeth Chisholm Spears, MS, CGC

President

Virginia Association of Genetic Counselors