These proposed regulations are significantly better than what was contained in the Notice of Intended Regulatory Action.  I specifically support
  – The requirement for written informed consent for surgical procedures
  – The requirement that any student performance of surgery be included in the consent
  – The requirement that the supervising veterinarian be present in the operatory at any time that a student is performing surgery

The change regarding owner consent is still insufficient.  A notice posted in the office that students are working in that location is not the same as consent, and is not an adequate alternative to consent.  

Veterinarians are not required to accept students into their offices for practical experience.  If they choose to do so, they need to confirm that the owner understands the situation and agrees to the student’s involvement.  ANY SITUATION IN WHICH A STUDENT WILL BE PERFORMING A TASK WHICH ORDINARILY REQUIRES LICENSURE MUST REQUIRE THE OWNER’S SPECIFIC CONSENT.

These proposed regulations are better than what was contained in the Notice of Intended Regulatory Action, but the change regarding owner consent is still insufficient. A notice posted in the office that students are working in that location is not the same as consent, and is not an adequate alternative to consent. 

Veterinarians are not required to accept students into their offices for practical experience. If they choose to do so, they need to confirm that the owner understands the situation and agrees to the student’s involvement. ANY SITUATION IN WHICH A STUDENT WILL BE PERFORMING A TASK WHICH ORDINARILY REQUIRES LICENSURE MUST REQUIRE THE OWNER’S SPECIFIC CONSENT.

Without this change, I remain opposed to expanding the possibility of student preceptorships before the fourth year,

Pets are part of our families. We would not let an unqualified med student practice on a family member either  First Do No Harm!

Posting the notice on a wall that a student will be conducting a surgery that specifically requires a licensed Veterinarian is not sufficent notice nor does it consistute specific, infomed consent.  Please require a detailed statement on a signature required release form.  

We have a right to know the level of education, experience and expertise of the "veterinarian" performing the procedure on our pets!

Dear Regulation Committee, 

Many owners of pets consider them to be a part of the family and as part of the family, we wish to take a pro-active role in our animal's healthcare decisions.  Who treats my animal is part of that decision-making process. Please consider our concern for transparency and the guardian's right to know who is giving our animals treatment and how experienced they are. 

Sincerely,

Beth Woolsey

Fur Mom

These regulations are improved and for that this pet owner is appreciative. However, in the event that my veterinarian should utilize vet school externs or trainees, at any level of their training, in his or her practice, I want nothing less than to be directly informed of this, both as a general circumstance and as a particular circumstance in the case of my pet, and to document my approval with my signature on an informing form. Mere "signage" - where, anyplace on the premises ? - is inadequate. This is not in the least burdensome for a practice carried on with any level of professionalism.

The purpose of regulations and this Board in part is to protect the public.  The Board has a duty to protect the public and allowing unlicensed students to work on our furry family members needs very specific guidelines.

As noted by others I specifically support—

• The requirement for written informed consent for surgical procedures at the time of the procedure

• The requirement that any student performance of surgery be included in the consent

• The requirement that the supervising veterinarian be present in the operating area at any time that a student is performing surgery.

Actual notice with discussions to include risks and benefits must be provided at the time of the procedure.  It should not and cannot be a generic statement that the client sign that states the vet clinic has students who may assist the veterinarians.  It has to be signed each and every time the student is going to do anything invasive to the pet. 

Question for the Board, if you allow this, will you also regulate the students?  If the student does something to harm the pet, will the student be subject to investigation?   If students are allowed to work on our pets with our specific written signed consent, then they should be regulated as any licensed veterinarian or tech.  And subject to disciplinary action. Or will you tell the owner that you do not have jurisdiction over students?

On a personal note, if this is approved, I will be sending a certified letter to my vet stating that students are not permitted to care for my pets in any manner except for observation.  I will not take my pets to any vets who allow students to perform invasive techniques on the pets especially if the owner does not have the protection of a strong informed consent requirement.

Respectfully submitted,

Molly Mittens Mom (may she rest in peace following the care she received by a “licensed vet”)  What harm might a student do?

The change regarding owner consent is still insufficient. A notice posted in the office that students are working in that location is not the same as consent, and is not an adequate alternative to consent.

Veterinarians are not required to accept students into their offices for practical experience. If they choose to do so, they need to confirm that the owner understands the situation and agrees to the student’s involvement. ANY SITUATION IN WHICH A STUDENT WILL BE PERFORMING A TASK WHICH ORDINARILY REQUIRES LICENSURE MUST REQUIRE THE OWNER’S SPECIFIC CONSENT.

Without this change, I remain opposed to expanding the possibility of student preceptorships before the fourth year.

Thanks for making progress,but even with owner's consent, how can we make sure Vets do give proper notice?

Any situation in which a student will be performing a task which orginarily requires licensure must require the owner's specific consent.  I do not want ANY student working on surgery in which owner consent has not been guaranteed. over this text and enter your comments here. You are limited to approximately 3000 words.

While I believe education and practicals are essential in learning the skills of one's trade, I also feel it necessary to let the owner make that decision. To most pet owners, a pet is a part of the family. As with any family member there should be consent to let an unlicensed, and on most levels, lesser skilled practitioner treat the patient.  I love my pets a great deal and if I am at a time when my pets need medical care, I need to make the decision on whether or not a student would be involved. If the case is a critical case then pet owners will prefer the most skilled and tenured veterinarian possible to ensure the best outcome possible. If the cases are minor, then giving the pet owner the right to allow a student is a viable option. I recently had to seek the services of VA Tech Vet School for IMHA in my dog. I spent thousands in care costs for him and needed to know he was getting the best chances he could get. There were students involved in his case because it was a rare and serious disease. VA Tech did disclose to me the involvement of students and I am grateful for the knowledge and the ability to ask for more skill and tenure. My dog did not survive the illness, but I would have been more devastated and angry to learn after the fact that he had only been treated by students who may have not had the knowledge to save him. To avoid further devastation when losses do occur, the insult to injury of wondering if anything more could have been done is too much to bear. Please let the owners' decide the level of care. It is the more ethical route and sometimes the only hope a pet parent can cling to. 

I lost a very precious dog when an unsupervised student missed significant symptoms during an emergency visit.  I not only want a veterinarian to require my consent before allowing a student to work on my pet.  I also want to know wnat role the veterinarian will have in the procedure.

Veterinarians are not required to accept students into their offices for practical experience. If they choose to do so, they need to confirm that the owner understands the situation and agrees to the student’s involvement. ANY SITUATION IN WHICH A STUDENT WILL BE PERFORMING A TASK WHICH ORDINARILY REQUIRES LICENSURE MUST REQUIRE THE OWNER’S SPECIFIC CONSENT.

Without this change, I remain opposed to expanding the possibility of student preceptorships before the fourth year.

To the Board: Reconsider your position and require owner notification and consent for all student practice. 

To the Association: Reconsider your position and support requiring owner notification and consent.

I have carefully read and considered the proposed changes to 18VAC150-20-130. I do not believe they will cause undue effort for veterinarians, and will ensure that pet owners get the standard of care they are paying for.

I am opposed to allowing students at any level to practice in any way without specific, individual owner knowledge and written consent for each procedure. Placing a "notice" in the practice office is not sufficient. I will be sure to only work with vets who do not allow students to work in their practices if this blanket notice is enacted. I appreciate the adjustments made based on public comment regarding written consent for surgical procedures, but this does not go far enough. The fact that your organization received so much public comment should suggest that your recommendations do not go far enough. Owners must be given written and verbal information, and right of refusal, in each specific instance of student care for any procedures that would normally be conducted by a licensed tech or vet. I'm sorry if you find this time consuming and a bother, but these are our family members and they deserve that level of respect if your profession is truly "caring" for our animals.

While I see that some improvements have been proposed, the requirement for consent before a member of the family is operated on by a student must not be ignored. That's right I said a member of the family, which is what animal companions acatually are, not property, not "just" animals to be experimented upon. I understand that veterinary students need the opportunity to perform what they are learning under real world conditions, but before any medical procedure, especially considerably risky ones, cannot and should not be done without the informed consent of the "owners" (for lack of a better term!) of the animals in question. One would never allow surgery to be performed on humans who cannot give their own consent, and then have no one to be able to give that consent in their stead; why does anyone think that animals should be any different since they can never give their own consent to begin with? Please amend your rules so that people who love their animals no less than any other human member of their families (and sometimes MORE than their human family members!) MUST give their consent, so that everyone can be put at ease, especially if there is an unfavorable outcome! The term "burdensome" should never be used when a matter of life and death, or even the possibility of a potentially negative outcome affecting even the quality of the animal's life going forward. Please reconsider this final request, and do what is right and good, even if it takes some work to make it happen, and to follow through over time. Thank you for your consideration.

No vet student should be allowed to work on anyone's precious pet WITHOUT their expressed permission.

These proposed regulations are significantly better than what was contained in the Notice of Intended Regulatory Action. I specifically support
– The requirement for written informed consent for surgical procedures
– The requirement that any student performance of surgery be included in the consent
– The requirement that the supervising veterinarian be present in the operatory at any time that a student is performing surgery

The change regarding owner consent is still insufficient. A notice posted in the office that students are working in that location is not the same as consent, and is not an adequate alternative to consent.

Veterinarians are not required to accept students into their offices for practical experience. If they choose to do so, they need to confirm that the owner understands the situation and agrees to the student’s involvement. ANY SITUATION IN WHICH A STUDENT WILL BE PERFORMING A TASK WHICH ORDINARILY REQUIRES LICENSURE MUST REQUIRE THE OWNER’S SPECIFIC CONSENT.

Without this change, I remain opposed to expanding the possibility of student preceptorships before the fourth year.

These proposed regulations are significantly better than what was contained in the Notice of Intended Regulatory Action. I specifically support
– The requirement for written informed consent for surgical procedures
– The requirement that any student performance of surgery be included in the consent
– The requirement that the supervising veterinarian be present in the operatory at any time that a student is performing surgery

The change regarding owner consent is still insufficient. A notice posted in the office that students are working in that location is not the same as consent, and is not an adequate alternative to consent.

Veterinarians are not required to accept students into their offices for practical experience. If they choose to do so, they need to confirm that the owner understands the situation and agrees to the student’s involvement.

Without this change, I remain opposed to expanding the possibility of student preceptorships before the fourth year.

When I was a student, all of my patients had to give consent to my "practising" on them. I see no reason why that should be different with pets.  I do not want a 4th year student operating on my beloved pet without supervision of the licensed vet and I can't imagine the student would feel confident or safe either.

As a practicing veterinarian who teaches veterinary students I am strongly in favor of the proposed changes. Students currently are involved in mentored experiences in veterinary practices from the time they are in high school through graduation from veterinary school. They start out observing and cleaning kennels but as they go through veterinary school and have gained the clinical skills important to veterinary practice the opportunity to use these skills is critical to their overall professional development. This experience and relationship with the veterinarians practicing in the state is critical to professional maturation of the student and can be beneficial to the patient and client as well. Additionally, these relationships are often an important reason that good students choose to stay in the State after graduation. Codifying the ability of the student to legally participate under the direct supervision of a Virginia licensed veterinarian makes these relationships more transparent. It is very important that the client is a partner in this process and that they know and consent to the student involvement.  The language clearly articulates this requirement. 

I feel this is smart as vet students get less hands on practice in school and this will enable them to get more all 4 years rather than just the last year. They will graduate with better skills

Having worked with doctors fresh out of school I think allowing them more time for hands on experience is key. As far as I read into it owners are informed and must sign off before a student vet can do anything to there animal, and that's fine. I also support a supervising veterinarian being avialable to monitor and provide help if needed.

They get so little experience in school as it that it would be real benefit to veterinarians and clinics everywhere if new "green" doctors had a bit more expirence under their belts.

I believe that it depends on the type of surgical procedure and the situation.  In an emergency, with a licensed veterinarian available by skype or phone, I could envision some mass injuries that would benefit by immediate action by a veterinary student.

If a veterinary doesn't have the time to talk directly to me about who will be caring for my pet, I would change vets. Posting a notice in the office lacks sympathy and professionalism. Remember who pays for the care of these animals!  Ginny Welton over this text and enter your comments here. You are limited to

All students should be supervised by licensed veterinairians during surgery and owners' consent should be required if students are doing surgery. Pets are part of the family and just as informed consent by parents is required for any surgery on children so should informed consent by owners be required on animal surgery. Licensure itself becomes a mockery if an unlicensed student is allowed to practice without a licensed vet supervising.

I have been following since the beginning Ms. Henkel's faithful commitment to protect our pets and the students who are practicing their veterinary skills on them by her insistance that this practice only be with signed owner consent.  As a retired clinical social worker, I recall the many times I asked clients to allow me as a student to be their social worker.  Some declined and I did not fault them, assuring them that if my precious life or that of my child were on the line, I might say 'no' as well.  Most gave permission, often saying that they thought they might get better care because 2 heads (mine and that of my superisor) might be better than one.  And many realized how hard students try, another benefit of their being involved.  I will not rest easy ,and I am very sure that Ms. Henkel will not rest at all, until owners are fully involved in care of their pets.  Let's not waste time by doing it any other way and lets be ethical.

I think students should get as much hands on experience as possible with preceptoships

After reviewing these proposed regulations, I specifically support:

• The requirement for written informed consent for surgical procedures
• The requirement that any student performance of surgery be included in the consent
• The requirement that the supervising veterinarian be present in the operatory at any time that a student is performing surgery

However, these proposed regulations would still permit vet students to practice with patients before their fourth year without a requirement that owners give their consent.   Posting a notice which states that students are working in a veterinary office is insufficient.    Any situation in which a student will be performing a task, which ordinarily requires licensure, must require the owner’s specific consent.  Without this change, I remain opposed to expanding the possibility of student preceptorships before the fourth year.     

One final comment -- this requirement that owners be informed and provide their consent is important not just to owners but also to veterinary practices.   If a student practices on an animal and the owner is not satisfied with the care and then finds out that a student performed the task and not the licensed veterinarian, that owner is going to feel like he/she has been deceived and his/her response is likely to be more extreme.   I think that any veterinarian who does not specifically ask clients for their consent for student practice is going to end up alienating clients and damaging their practice.   

While I'm very much in favor of students acquiring as much hands-on experience as possible during their training, I strongly believe that it is ESSENTIAL TO INFORM THE OWNER if a student will be treating their animal AND to RECEIVE THE OWNER'S INFORMED CONSENT PRIOR TO STUDENTS PERFORMING ANY TASK ON THE ANIMAL FOR WHICH LISENSURE IS REQUIRED.

Posting a notice informing clients of students working at that location is NOT the same as owner consent.

The proposed regulations are significantly better than what was contained in the Notice of Intended Regulatory Action. I specifically support
– The requirement for written informed consent for surgical procedures
– The requirement that any student performance of surgery be included in the consent
– The requirement that the supervising veterinarian be present in the operatory at any time that a student is performing surgery

Please include in the regulations the REQUIREMENT FOR WRITTEN INFORMED OWNER CONSENT FOR ALL TASKS TO BE PERFORMED ON AN ANIMAL BY A STUDENT THAT WOULD ORDINARILY REQUIRE LISENSURE.

The informed consent for surgery concerns me. I think most veterinarians try to inform clients as well as possible to the risks and alternatives to surgery. I think adding this legal requirement will result in an undue burden on veterinarians, as it is impossible to foresee all possible complications from surgery and this  will likely be used in lawsuits by clients.

The change regarding owner consent is still insufficient. A notice posted in the office that students are working in that location is not the same as consent, and is not an adequate alternative to consent. Having worked for years in the organ and tissue procurement industry in Quality Assurance, I am well familiar with informed consent. It is unethical and unnecessary to pursue this course of inadequate information to pet owners, and effectively takes away our ability to withdraw consent, which will lead to feelings of helplessness and distrust towards your profession. I can only wonder, is that your intent, to not allow pet owners a reasonable opportunity for informed consent? Are you fully prepared for the ramifications: The bad press, the word of mouth to avoid practices using students (which will adversely affect the ability to place and train students as fewer and fewer practices are willing to chance the negative publicity and ulitimately negative impact on their profits)?

Veterinarians are not required to accept students into their offices for practical experience. If they choose to do so, they need to confirm that the owner understands the situation and agrees to the student’s involvement. ANY SITUATION IN WHICH A STUDENT WILL BE PERFORMING A TASK WHICH ORDINARILY REQUIRES LICENSURE MUST REQUIRE THE OWNER’S SPECIFIC CONSENT.

Without this change, I remain opposed to expanding the possibility of student preceptorships before the fourth year.

       I definitely believe that any situation in which a student will be performing a task that ordinarily requires licensure must require the animal's owner's consent. Without this change,  i am opposed to expanding the possibility of student preceptorship before the fourth year.Thank you for considering our comments.pe over this text and enter your comments here. You are limited to approximately 3000 words.

In my previous comment I did not address the question of owner consent for any procedures involving students practicing without direct supervision of a licensed veterinarian. As stated before, if a student is working on a patient/animal without a licensed veterinarian present then the student is the same as an unlicensed practitioner -- which makes a mockery of licensure. And owners need to be made aware that an unlicensed person may be treating their animals. A sign in the office does not equal informed consent.

I don't believe students lower than 4th year should be practicing on patients outside of a veterinary school (where clients might understand that a student will probably be involved in their pet's care to some extent). The veterinary school's sole purpose is to teach students paying $40K+ a year the best way to complete proceedures. Clients should most certainly know if non fully-trained students will be practicing on their pet. I would most certainly want to know if a student of ANY year would be involved in proceedures on my pet!

I have used the Vet school on a number of occasions. I see no problem with having me as the owner and paying client, signing an informed written consent. If you have nothing to hide from me, then you would have no problem with that. I want any and all students to have a supervising veterinarian present during the surgery. At the prices you charge me, this is not asking very much of you as an provider of services to the public. ANY SITUATION IN WHICH A STUDENT WILL BE PERFORMING A TASK WHICH ORDINARILY REQUIRES LICENSURE MUST REQUIRE THE OWNER’S SPECIFIC CONSENT. This is not something I should have to ask for, it is something that you should gladly provide us a consumers at the Vet School.

I request that if the Vetinary Board gives vet students the right to practice their skills before the fourth year, that there must be informed consent for all surgeries and a requirement that the supervising veterinarian be present where a student is performing surgery.

The tasks that a vet student may be doing could require licensure - definitely need owner consent and explanation for that!!

This is the comment I made the last time this proposal was up for public review:

"I understand that students need to learn, but this makes me very uneasy, especially in the early years of vet school.  I take my cats to my vet for her professional expertise, and I don't like the idea of anyone who is not fully trained working on them.  There are no circumstances where a student should even touch an animal without the owner knowing and giving their permission.  I doubt that I would agree to very much."

I haven't seen anything since then to make me change my mind.  I remain opposed.

I have commented on this proposal previously, and I remain concerned that the current version of the regulations still privileges student practical experience over the owner’s right to know and give or withhold consent for student practice.

As a retired physician and former professor of pediatrics at UVA Medical School who taught medical students in Roanoke, I am very aware of the benefits of maximum supervised experience prior to entering practice. I am not opposed in principle to permitting students to practice before their fourth year.

However, it is unethical and improper for this to occur without the owner knowing exactly who will be doing what with their animal, and with what level of supervision. A sign which states that students are working the office is totally inadequate. Unless a requirement for owner CONSENT is added, I am opposed to this change.
 

Veterinarians are not required to accept students in their practices – they choose to do so. That choice needs to be extended to their clients, in the form of a conversation about what they propose to permit the student to do, and how the student will be supervised.

A sign in the office saying “student working in this practice” is inadequate. The performance by a student of ANY task which ordinarily requires licensure MUST require owner consent, not just notification.

The change regarding owner consent is still insufficient. A notice posted in the office that students are working in that location is not the same as consent, and is not an adequate alternative to consent.

Veterinarians are not required to accept students into their offices for practical experience. If they choose to do so, they need to confirm that the owner understands the situation and agrees to the student’s involvement. ANY SITUATION IN WHICH A STUDENT WILL BE PERFORMING A TASK WHICH ORDINARILY REQUIRES A LICENSURE MUST REQUIRE THE OWNER’S SPECIFIC CONSENT.

Without this change, I remain opposed to expanding the possibility of student preceptorships before the fourth year. Katherine Bishop Roanoke, Va **** SAVE A LIFE - RESCUE, WOOF

The change regarding owner consent is still insufficient. A notice posted in the office that students are working in that location is not the same as consent, and is not an adequate alternative to consent.

Veterinarians are not required to accept students into their offices for practical experience. If they choose to do so, they need to confirm that the owner understands the situation and agrees to the student’s involvement. ANY SITUATION IN WHICH A STUDENT WILL BE PERFORMING A TASK WHICH ORDINARILY REQUIRES LICENSURE MUST REQUIRE THE OWNER’S SPECIFIC CONSENT.

Without this change, I remain opposed to expanding the possibility of student preceptorships before the fourth year.

I'm not even sure how it's legal to have students unsupervised in a life altering situation???

Please explain, I'm very confused.

Informed consent is not enough; a licensed Vet. needs to over look the students work.

Simply posting a notice in the office of the presence of students assisting in veterinary procedures is not sufficient.    As a long time pet owner and frequent client of veterinary services I would not be satisfied by this.  I do realize that students need to have practical experienc BUT -- I would strongly object if my animals were handled by someone other than my vet. - and in particular without veterinary supervision or oversight.   I would refuse to continue using a vet practice if I had any idea of this activity going one.