Virginia Regulatory Town Hall
Department of Health Professions
Board of Medicine
Regulations Governing the Licensure of Radiologic Technology [18 VAC 85 ‑ 101]
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6/19/23  9:49 am
Commenter: Medical Society of Virginia

MSV Comment Regarding Regulations Governing the Licensure of Radiologic Technology

Re: Medical Society of Virginia (MSV) Comment Regarding Regulations Governing the Licensure of Radiologic Technology [18 VAC 85 ? 101]

Jun 19, 2023

Dear Dr Harp,

The Medical Society of Virginia (MSV) strongly supports proven efforts to expand healthcare access while maintaining the highest standard of patient care. Unfortunately, any effort to allow for remote supervision of Radiologist Assistants fails to clear that hurdle—and as such, the MSV must oppose this petition.

Virginia’s PAs, medical students, and physicians know firsthand how complicated even “minimally invasive procedures” can be. And the fact the petitioner fails to define such procedures gives the MSV great concern regarding potential patient safety issues. Any medical procedure carries risk. When serious complications arise (and they inevitably will) patients deserve an immediate response by a practicing physician with clinical judgment based on years of clinical experience.

Plainly, we are concerned this proposal will lower Virginia’s high standard of patient care and increase the potential risk to Virginia patients. 

The petition as written must be opposed, but the MSV stands ready to work with all stakeholders to increase healthcare access and empower the Commonwealth’s healthcare workforce.


Clark Barrineau
Assistant Vice President of Government Affairs and Public Policy
Medical Society of Virginia

CommentID: 217299