June 19, 2023

Re:  Regulations Governing the Licensure of Radiologic Technology [18 VAC 85 ? 101]

Dear Dr. Harp,

On behalf of the Virginia Radiological Society, we would like to express our appreciation for the opportunity to provide comment on the petition.  The petition seeks to allow for remote supervision of Radiologist Assistants for minimally invasive procedures and diagnostic imaging.  We value the work of Radiologist Assistants and recognize the valuable role they play in the patient care team.  However, we must oppose the petition for the following reasons.  The petitioner leaves "minimally invasive procedures" undefined.  Even minimally invasive procedures can have serious complications that would require the attention of a Radiologist.  Adverse reaction to contrast being but one example.  Additionally, the petition represents a significant shift in how Radiologist Assistants are currently supervised. 

While we are in opposition to the petition currently, we would be more than willing to explore this issue with the petitioner, the professional associations representing Radiologist Assistants, and other interested parties. 

Thank you again for the opportunity to comment.

Most Sincerely,

Arun Krishnaraj, MD, FACR

President | Virginia Radiological Society

Richard A. Szucs, MD, FACR

Legislative Committee Chair | Virginia Radiological Society