I am supportive of the radiologist assistant regulations advancing to the Board of Medicine.

 I fully support the Radiologist Assistant regulation. There is a DEFINITE need today and in the future particularly in an effort to control rising health care costs and providing optimal patient care. 

I am in support of the RA licensure in Virginia.  I believe that, as a seasoned Radiologic Technologist, this type of physician extension, will have a great impact on the care of patients in our Commonwealth.  RA, like Radiologic Technologists, can be with patients from beginning to the end of procedures, improving the continuity of care.  I believe that it will help with decreasing costs of care associated with the RA's provision of Care, vs. the Radiologists.

I am concerned that we have not established a fee schedule for RA's, thus, making it difficult to convince Radiologists groups to take on the work associated with training the RA.  Expediting this would help to support getting this program off the ground and enhance its acceptance in the Commonwealth.

I fully support the Radiologist Assistant legislation. In this time of rising health care costs, we need the option of an advanced level practitioner who can perform radiologic examinations while providing excellent quality patient care.

Given the difficulties in the current radiology environments and future Radiologist workforce shortages, Radiologist Assistants could become an effective solution to the existing organizational issues and could significantly improve the overall productivity of radiology departments. Workforce shortage leads radiologists to the need for performing more and more routine functions, while the quality of radiology care suffers.  The RAs is a beneficial option to hospitals and related healthcare facilities: they can not only relieve the burden of responsibilities and routine functions in radiologists, but can significantly contribute to improved care and productivity through reduced wait times, increased patient turnover, improved quality of pre- and post-procedural follow-ups, better patient interactions, and the reduced number of complications and lawsuits for malpractice.

I have been a radiology professional for 25 years and see a great need for the RA program and the support these individuals can bring to the health care setting.  I fully support this legislation.

Lorie L. Kappeler, BSRT-CRA

To Whomever it concerns, 

As President of the Society of Radiology Physician Extenders, I oppose the draft regulations as written because it fails to acknowledge the contributions of the Radiology Practitioner Assistants to the radiology extender profession and as an equally trained and Board certified radiology extender. Since enactment of the § 54.1-2900 of the Code of Virginia, (Radiologist Assistant Law), the atmosphere surrounding this profession has changed drastically. With collaboration of the American College of Radiology (ACR), American Society of Radiologic Technologists(ASRT), American Registry of Radiologic Technologists (ARRT), and Society of Radiology Physician Extenders (SRPE), the Radiology Practitioner Assistants and Registered Radiologist Assistants are being written into Federal Law drafts and state licensure frameworks under the common moniker “Qualified Radiologist Assistant” A “Qualified Radiologist Assistant” is defined as a radiographer who is certified by the American Registry of Radiologic Technologists as a registered radiologist assistant or by the Certification Board for Radiology Practitioner Assistants as a radiology practitioner assistant to perform advanced radiologic procedures under the  supervision (as determined by state law) of a radiologist and who is an employee, leased employee, or independent contractor of the supervising radiologist. With federal legislation being considered and ultimately passed, it will be important that there be consistency with the way these two designations are listed and properly regulated under the guidance of the ASRT practice standards and scope of practice. Please consider referring the regulation draft back to committee and amending the original law. It is not the substance of the law that is deficient but rather the exclusion of the Radiology Practitioner Assistant that makes it an opposable bill.

Respectfully,

Jason Barrett RPA/RRA

SRPE President

While I am in favor of the language of this RA proposal, I am opposed to the exclusion of the Radiology Practitioner Assistant (RPA) within the context of this bill. The RPA set the foundation for what the RA is. With upcoming Federal Legislation concerning this profession being brought to the Senate for discussion, BOTH credentials need to be recognized at the state level. Both the RPA and RA community have become a unified profession and any and all future State and Federal legislation needs to reflect that. The ARRT, ASRT, ACR and SRPE have worked hard to meld these professions and I feel STRONGLY that this bill needs to reflect that.

I Strongly OPPOSE RA legislation that Does Not Include the RPA community.-Rob Tweed

I strongly oppose this legislation for the advancement of the RA law because it has not included the RPA profession.  I support the srpe view of this regulation along with the professional organization that supports them.

                                                                                              thank you,

                                                                                               Fely Caccam RN

I oppose the draft regulations because it does not acknowledge the contributions of the radiology practitioner assistants and i will continue to oppose it until the includes the RPAs.

Thank you,

Kris Andre'

I strongly oppose RA legislation without inclusion of RPA.

Working in a hospital that has RPAs in its department, I find them to be a great asset to the department, not only do they serve as an extention to the radiologists, they are able to provide a more personalized experience to our patients, especially in  a time in health care when everything seems to be rushed and impersonal. I strongly oppose this legislation.

I oppose the draft regulations is presently because it doesn't include the RPA. I work with a RPA who is wonderful, professional and attentive to his a patient. If this is passed he would no longer have a job. The community as whole would be at a lost.

I oppose the draft regulations as written because it fails to acknowledge the contributions of the Radiology Practitioner Assistants to the radiology extender profession.

Dawn White RTR

i oppose this regulatory  as written because it does not  include the rpa community as support by the asrt,arrt,acr and srpe.

I am in opposition to the current regulation as written because it overlooks the involvement of RPAs.  Indeed, these professionals are an asset to the healthcare community and their patients.  Exclusion from the proposed regulation will not only impact the livelihood of many RPAs but it will also do a disservice to the community as a whole.  

Thank you

I am opposed to bill as it is currently written, because it currently excludes RPA.  RPA's are licensed by their own certification board (CBRPA) and should be granted recognition and privilages just as RA's.  The ARRT does not govern all imaging modalities.

I oppose this RA regulatory proposed that does not support or include the Radiology Practitioner Assistant (RPA). RPA's are the building block of this advance mid level profession .This bill does not reflect the radiology professional present day the American College of Radiology (ACR) American Registry of Radiologic Technologists (ARRT),  American Society of Radiologic Technologists (ASRT), and Society of Radiology Physician Extenders (SRPE) views; therefore, I cannot support this bill as a long-time Virginia resident.  I respectively request this bill include RPAs.

Radiology Practioner Assistants and Radiology Assistants are equal in support from SRPE, ACR, ASRT, and ARRT, which have pushed for federal legislation of Qualified Radiological Assistants.  I also ask the present deficit of RPAs be addressed and not omitted from the regulation.

In conclusion, I am opposed to this version of this bill due to the RPA exclusion and stand by the ASRT, ACR, ARRT, and SRPE version of this bill.

Respectively,

Everette Williams, RPA, RA (CBRPA), RT(R)

I opposed this bill brecause it does not include the Radiology phyician assistants. They are a big asset to the Radiology committee and are supported by the ASRT,ARRT,ACR, and SRPE.

Working in a hospital that has RPAs in its department, I find them to be a great asset to the department, not only do they serve as an extention to the radiologists, they are able to provide a more personalized experience to our patients, especially in  a time in health care when everything seems to be rushed and impersonal. I strongly oppose this legislation.

I oppose the draft regulations as written because it fails to acknowledge the contributions of the Radiology Practitioner Assistants to the radiology extender profession.

I am opposed to bill as it is currently written, because it currently excludes RPA.  RPA's are licensed by their own certification board (CBRPA) and should be granted recognition and privilages just as RA's.  The ARRT does not govern all imaging modalities.

I opposed this bill brecause it does not include the Radiology phyician assistants. They are a big asset to the Radiology committee and are supported by the ASRT,ARRT,ACR, and SRPE.

Respectively,

Bill Bobrich R.T. (R)

RPAs are a great asset to the hospital, not only do they assist the radiologist they give a great service to our patients in a rushed hospital setting.I  strongly oppose this legislation because it does not include the RPAs.

 Sue Midgett.

To whom it may concern,

As an actively employed RPA/RA  in the state of Virginia I am opossing the draft regulations as written as it fails to acknowledge the contributions of the Radiology Practitioner Assistants to the radiology extender profession and as an equally trained and Board certified radiology extender.  Since the enactment of 54.1.2900 the relationships between many of the national governing bodies has changed drastically.

  The current collaboration between the ACR, AART, and the SRPE focuses on inclusion of both the RRA certified by the AART as well as the RPA certified by the CBRPA.

On the surface this law is a great leap forward for the advancement of the profession, however consistency with the proposed Federal laws will be vital to all aspects of the profession.  I would urge the board to send the bill back to committee to amend the law so that the RPA can be included. 

Respectfuly,

Rick Sharp R.T. (R) (RRA) RPA

I am opposed to the RA bill as written.  My opposition  to the bill is because of the exclusion of the RPA (Radiology Practitioner Assistant).  Upcoming Federal Legislation concerning our profession will make it necessary for the state regulations to recognize both titles. The ARRT, ACR and SRPE have worked hard to meld these professions and I feel that this bill needs to reflect that.

Jeff LaPole RT(R),RPA, RRA, CV, BA
 

I oppose the draft regulations as written because it fails to acknowledge the contribution of the Radiology Practitioner Assistants to the radiology extender profession.

Working in a hospital that has RPAs in its department, I find them to be a great asset to the department, not only do they serve as an extention to the radiologists, they are able to provide a more personalized experience to our patients, especially in  a time in health care when everything seems to be rushed and impersonal. I strongly oppose this legislation..

I oppose this regulatory action because it doesnot include the radiology practioner assistant,

I oppose the RA legislation that does not include RPAs.

Thank you,

Carolyn T. Pabustan, RN, BSN

I oppose this legislation as is it is written because it excludes the Radiology Practioner Assistants.

I oppose the RA legislation because it does not include the Radiology Practioners Assistant. I

I oppose this legislation as it is wirtten because it excludes the Radiology Practioner Assistants

I appose the bill for personal reasons.

oppose because this bill excludes rps's

I oppose this regulation because it does not include the RPA's.

I oppose the RA legislation that does not include Radiology Practioner Assistant

As a radiologist practicing in the state of Virginia and one who is actively involved with the American College of Radiology on the state and national levels I am fully in support of licensure of RAs and the regulations as written. This has been a collaborative effort of the ACR and the ASRT on the national level. Virginia is one of only a few states with RA training programs. It is important that they be licensed so that they will have the opportunity remain in Virginia to practice . With the provider shortages that are projected to exist with healthcare reform it is critical that we have all the help we can get to provide care to the citizens of the Commonwealth.

As an experienced radiologist, I recognize the value of a specially trained and experienced technologist. Their experience having seen thousands of xray images and studies gives them real insight and distinguishes them from other nonphysician practitioners.

We need to ask ourselves what is in the best interest of our patients. Radiologists are physicians who are trained to perform various invasive and non-invasive procedures after many years of medical school, residency and fellowship programs. We are trained to recognize unforeseen problems or complications, including very subtle abnormalities. I am personally responsibile to provide the best care to my patients and I take that responsibility as a solemn duty. Patients want  their arthrograms, upper gastrointestinal barium studies, myelograms, etc. performed and interpreted by radiologists.  I have an overall disagreement with the concept that non-physicians can provide this level of care. Therefore, I oppose legislation that would allow further expanse into this area.

As an experienced radiologist, I value the unique and valuable expertise that a radiologist assistant brings to the practice of medicine.

I strongly support the regulations for Radiologist Assistant licensure as proposed. The Virginia Chapter, American College of Radiology worked long and hard with the General Assembly to get the licensing legislation passed. At no time during the  House and Senate subcommittee or committee hearings for this legislation did the RPA community make any comments before the legislature to register their concerns, and it's a bit too late now to try to set the clock back.

Furthermore, the law and proposed legislation deal ONLY with licensing of the Radiologist Assistant. There is NOTHING in the law or regulations that would prohibit RPA's (or Nurse Practioners or any other physician extenders) from doing what they do now. If the RPA community wants to be licensed, regulated, and LIMITED in their practice like the RA's are by this law and regulations, go ahead and have licensing legislation introduced. I can tell you from personal experience that the process is tedious and requires a lot of time, energy, and funding.

As a practicing radiologist for over 30 yrs, Vice-Chair of the Radiology Dept at VCU Medical Center, Radiologist Preceptor of the VCU/MCV RA Training Program, and also as a Board Member of the Virginia Chapter of the ACR, which represents over 500 radiologists in the state of Virginia,  I am strongly in support of the RA licensure bill as written.

RAs are a valuable addition to the radiology workforce of the state, serving as radiologist extenders in a similar manner as other designated physician extenders to other medical specialties.  State licensure of RAs needs to occur  so that the Commonwealth can achieve the benefit of this enhancement to the workforce and therefore increased patient access as well as bringing the state in line with  multiple other states throughout the country who have already approved licensure of RAs or who have pending legislation.

The posted objections of the RPAs are noted, however, many of the posted objections are by RPAs who do not live or practice in VA.  Also, there is an option for RPAs to take the same licensing exam as RAs and they would then be certified RAs and fall under the current wording of the bill.  We should not stall or amend this legislation now.  If the RPA community wants separate wording to be included, then they can go through the legislative process as was done with the RA licensure.

As a longtime practicing radiology who participates in the training of RAs and whose practice includes RAs in the environment,  and as a radiologist actively involved with  the state and national radiologists groups,  I stongly support the legislation for licensure of RAs in Virginia.

I strongly support state license, and I thank all the folks for the amount of time, money and effort put into this bill.  I am not trying to "kill the bill" I am just asking for the board to reconize the RPA at the state level.  There is a national effort being carried out by a consortium of leaders from the American College of Radiology, American Society of Radiologic Technologist, American Registry of Radiologic Technologists, and The Society of Radiology Physician Extenders.  Documents from both federal and state efforts use one moniker, "Radiologist Assistant", defined as

"Qualified radiologist assistant" means a radiographer who is certified by the American Registry of Radiologic Technologists as a registered radiologist assistant or by the Certification Board for Radiology Practitioner Assistants as a radiology practitioner assistant to perform radiologic procedures under the supervision (as deteremined by state law) of a radiologist.

If this could be put in place, this would allow us all to move forward.  I understand that the RPA's had a certain time table to set for the RA exam, one concern is the RPA who is currently working in another state, and wants to work in Virginia in the future.  I believe the time table for the RPA ends Dec 2011.  This would not allow future RPA's to obtain a state license.

Thanks,

David Pyle RPA/RA

I think and know from experience that the Radiology Practitioner Assistant (RPA) serves as a great

asset in the hospital and private office environment.  I had the pleasure of being cared for and seen

by a RPA in a hospital vist.  He gave above average care and made the unexpected vist to the

hospital less than painless.  Without his knowledge, professionalism my family would have

endured much pain.  The efficient care and time spent was priceless for us.  I am a Virginia resident

and hope the hospital administration  and  the VA Medical Soceity appreciates the

 RPA commitment.  My hat goes off to the trusted Radiology Practitioner Assistants.

I fully support the Legislation as written, while I believe that language which could include the RPA credential should be addressed in the future, it is imperitive that this legislation move foreward as expeditiosly as possible so that radiology physician extenders can have a greater impact on the way care is delivered in radiology without any further delay.

As a Registered Radiologist Assistant (RA) currently working in the state of Virginia, I see first hand how benifical RAs are to healthcare.  I strongly support the RA Licensure as it is currently written.  The RA profession needs to move forward to increase patient care  as well as bringing the state in line with  multiple other states throughout the country who have already approved licensure of RAs or who have pending legislation.

Oppose as written.