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