The Virginia Podiatric Medical Association would appreciate the Board considering some clarifying amendments as it proceeds with the “fast track” amendments to update and clarify regulations regarding Radiologic Technologists-Limited, especially as related to Rad Tech-Limited for podiatric medicine and surgery.  We believe that in attempting to clarify provisions related to Radiologic Technologists and Radiologic Technologists-Limited, the proposed amendments cause confusion for Radiologic Technologists-Limited (Podiatry). 

            VPMA also appreciates the extensive discussions of the past which have resulted in the Board of Medicine’s approval of VPMA offering and presenting the course and examination in order for a Rad Tech-Limited (Podiatry) to be licensed by the Board.  Despite the years of proven success of this system, we are concerned that an eventual change in Board staff may result in efforts to cease acceptance of this course and exam for this limited type of license. 

     Consequently, VPMA suggests the following clarifying amendments specifically related and limited to licensure of “Rad Tech-Limited (podiatry).”

1.         18 VAC 85-101-55 established educational requirements for radiologic technologists-limited.  Currently Rad Tech-Limited for Podiatrists would fall under section A.4. “Any other program acceptable to the board.”  To avoid confusion with existing regulations and to prevent possible future problems (perhaps resulting from eventual change in Board staff), VPMA suggests an additional option for Rad Tech-Limited:

“For a limited license in the anatomical area of the foot and ankle practicing under the direction of a doctor of podiatry, the applicable course presented by the Virginia Podiatric Medical Association shall be considered approved by the Board.”

2.         18 VAC 85-101-60 Licensure requirements, section E states that for the limited license for Rad Tech-Limited (Podiatry) the applicant shall provide evidence of passage of an “examination acceptable to the board.”  VPMA suggests it be amended to read:

“E.  To qualify for a limited license in the anatomical area of the foot and ankle to practice under the direction of a doctor of podiatry, the applicant shall provide evidence that he has taken and passed an examination acceptable to the board which shall include an applicable examination offered by the Virginia Podiatric Medical Association.”

These suggested amendments reflect long standing policy, developed after extensive discussions between the Virginia Board of Medicine and VPMA.  Those suggestions will provide clarification for those seeking licensure as a Rad Tech-Limited (Podiatrist).

Bruce B. Keeney, Sr.

Executive Director & Legislative Counsel

Virginia Podiatric Medical Association