I opposes this petition for rule making allowing veterinary assistants to administer by any means

I don't think the wording should be changed to include assistants in having access/administering controlled drugs. Schedule VI drugs are all meds that require a prescription that are not controlled so every vet office carries them.

In this day and age when, due to the human abuse potential, authorities threaten to remove the veterinarian's ability to utilize effective opioid analgesics in our patients, it seems counter-productive to lessen restrictions regarding who may handle those same substances. I strongly believe that only licensed personnel should be permitted to handle DEA Controlled Substances. We don't even let non-licensed personnel administer rabies vaccines, but they should be able to handle controlled substances? No. Absolutely too much risk of abuse.

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

 

To my knowledge, no other field permits this sort of transaction by untrained personnel – even under professional/licensed supervision.  Petition 261 is a dangerous and negligent proposal. It does not specifically address the personnel shortages in the veterinary field. If anything the proposal opens doors to aggravate the ongoing opioid crisis and fails to consider how the current language might impose undue risk and liabilities upon DVMs & LVTs.e over this text and enter your comments here. 

This petition is a bad idea on many levels. 

Granting unlicensed individuals access to controlled drugs only opens the door for more abuse of drugs that are under scrutiny nationwide and are becoming less and less available to veterinary practices.  Putting schedule II-V drugs in the hands of unlicensed assistants  potentially puts patients at risk and threatens the trust that the public has in veterinary medicine.

The request to allow assistants to administer drugs by any route has been proposed countless times and has been denied.  That should continue. 

The level of supervision requested in the petition is not defined in the regulations governing the practice of veterinary medicine.

Virginia has long been know for being progressive and a leader in laws and regulations that protect the public and their pets. This would be a giant step backwards.