Dear Dr. Harp and the Virginia Board of Medicine, 

The American Society of Radiologic Technologists is the premier association for the medical imaging and radiation therapy profession, with nearly 156,000 members nationally including 4,245 members in the Commonwealth of Virginia.  

ASRT’s main mission as an organization is to advocate for patient safety by ensuring the technologists providing care remain within their scope of practice and under appropriate clinical supervision. With this mission in mind, I am writing to express concerns over the petition to allow for remote supervision of minimally invasive procedures and diagnostic procedures. 

The main concern is over the lack of definition for what procedures would be classified as minimally invasive. Additionally, a radiologist assistant does not have the practice authority to work autonomously. With these concerns, we propose the following wording to balance concerns and accessibility.  

Recommendation “A radiologist assistant may provide imaging services that do not require informed patient consent under the remote supervision of a radiologist. If a supervising radiologist is not physically present at the location at which a radiologist assistant is practicing, the radiologist assistant shall provide services for any procedure requiring informed consent only when a physician licensed pursuant to 18VAC85-20, who need not be a radiologist, is physically present at the location and would be responsible for providing intervention or assistance in the event of a medical emergency.” 

I look forward to working with you as the Department of Health Professions evaluates this petition to amend. ASRT is happy to be a resource on all things related to the medical imaging and radiation therapy professions.  

Sincerely, 
 
Meredith Check, MPP 
Manager of Government Relations and Public Policy 
ASRT