Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Veterinary Medicine
 
chapter
Regulations Governing the Practice of Veterinary Medicine [18 VAC 150 ‑ 20]
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11/14/17  12:08 pm
Commenter: Virginia Association of Licensed Veterinary Technicians

The VALVT firmly opposes Petition 261
 

Virginia Association of Licensed Veterinary Technicians

3801 Westerre Pkwy D, Henrico, VA 23233

(804) 346-2611

11/13/2017

 

The VALVT firmly opposes Petition 261 submitted by Claire Webster: To authorize the delegation of administration of Schedule II-V drugs by any route to an unlicensed assistant under the direction and supervision of a veterinarian or a veterinary technician.

With the opioid crisis running rampant across the state and nation, allowing personnel who are not educated and trained to have access to the variety of drugs included in this petition is reckless and detrimental to the resolution of opioid access.  Not only would this allow more people access to commonly abused drugs, it would allow those not versed in the pharmacological effects of these drugs to administer them to patients who could be adversely affected. The reasons the current language is in the regulations remain valid and we support not making a change.

The VALVT is strongly aware of the unmet demand for licensed veterinary technicians in the Commonwealth of Virginia. Allowing non-licensed personnel to handle and administer Schedule II-IV controlled substances is not a viable solution to this problem. Currently there are two programs in The Commonwealth for hands-on, AVMA accredited, campus-based training of  veterinary technicians and over five distance education programs available. Hospitals who cannot hire LVTs have the opportunity to offer their long-term, valued employees access to these accredited, proven educational programs. There they will receive the education and training that busy practices are not equipped or qualified to provide. We are currently in a crisis in the Commonwealth of Virginia for licensed and dedicated team members for necessary patient care.  Allowing unlicensed assistants to perform acts such as this is one of the top reasons LVTs leave the profession.  It is demeaning to the profession and demonstrates a lack support from their veterinary colleagues.  Attrition from the profession is key to the shortage of LVTs.  Most people will agree that a lack of LVTs in practices puts patients and the entire veterinary profession at risk.

The VALVT values the entire veterinary team.  We have not ever been adversarial toward veterinary assistants and value the contribution they make to patient care. We do highly encourage all veterinary hospitals with the shortage of licensed technicians to support students of veterinary technology, encourage staff to become licensed by offering formal AVMA accredited training and utilize assistants to the extent of the law and not beyond.

Changing regulations to make unlawful practices lawful is not a solution to a challenge that has existed for decades. We welcome the opportunity to partner with practices wishing to employ LVTs, access training in AVMA accredited programs for their valued employees or practice effectively and legally with unlicensed staff.

Thank you for your consideration,

 

The Virginia Association of Licensed Veterinary Technicians

 

CommentID: 63271