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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6/5/23  10:48 am
Commenter: Rick Sharp. Valley Health

Remote Supervision

I feel this is necessary.  As Health care organizations continue to expand and purchase smaller more rural hospitals Radiology groups cannot physically be present and frequently opt to read remotely.  Allowing the Radiology Assistant this rule change will expand the ability for rural areas to get fluoroscopic studies performed in their local hospital as opposed to driving to a large center frequently a good distance away.  This rule amendment aligns with the scope of the RA and would be a positive move for the profession.


As a practicing RA I think this is long overdue.

CommentID: 217054

6/15/23  12:18 pm
Commenter: Jeff LaPole, Winchester Radiologists

Radiologist Assistant Supervision

I support changing the regulations of the Radiologist Assistant to allow supervision of diagnostic procedures ( fluoroscopy ) and minimally invasive needle procedures to "general" or remote supervision. Currently the regulations read that the Radiologist must be "in the building" in order to supervise the Radiologist Assistant.  Changing the regulations  would provide greater flexibility in scheduling for more rural healthcare settings and provide greater access to care for our community. With the nationwide shortage of Radiologists,  optimizing the use of the resources we have is imperative to keep up with the growing demand.  It is important to emphasize that all studies performed by the Radiologist Assistant are reviewed with the Supervising Radiologist before the Physician provides the final interpretation.  

I encourage the board to amend the Radiologist Assistant Rules and Regulations to allow for general supervision for diagnostic imaging and minimally invasive needle procedures so we can provide greater access to care for our community.  

CommentID: 217266

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

6/19/23  3:29 pm
Commenter: Virginia Radiological Society

Regulations Governing the Licensure of Radiologic Technology

June 19, 2023


Re:  Regulations Governing the Licensure of Radiologic Technology [18 VAC 85 ? 101]


Dear Dr. Harp,


On behalf of the Virginia Radiological Society, we would like to express our appreciation for the opportunity to provide comment on the petition.  The petition seeks to allow for remote supervision of Radiologist Assistants for minimally invasive procedures and diagnostic imaging.  We value the work of Radiologist Assistants and recognize the valuable role they play in the patient care team.  However, we must oppose the petition for the following reasons.  The petitioner leaves "minimally invasive procedures" undefined.  Even minimally invasive procedures can have serious complications that would require the attention of a Radiologist.  Adverse reaction to contrast being but one example.  Additionally, the petition represents a significant shift in how Radiologist Assistants are currently supervised. 


While we are in opposition to the petition currently, we would be more than willing to explore this issue with the petitioner, the professional associations representing Radiologist Assistants, and other interested parties. 


Thank you again for the opportunity to comment.


Most Sincerely,


Arun Krishnaraj, MD, FACR

President | Virginia Radiological Society


Richard A. Szucs, MD, FACR

Legislative Committee Chair | Virginia Radiological Society

CommentID: 217311

6/27/23  12:39 pm
Commenter: Jeffrey LaPole

Clarification of Minimally Invasive Procedures

Clarification of "minimally invasive procedures"

Dr. Harp,
I appreciate the comments posted to the forum and the opportunity to clarify what was meant by "minimally invasive procedures" in the petition to change the rules regarding Radiologists Assistants.  Other than diagnostic fluoroscopy, the specific procedures that would be most beneficial to be included in the proposed change are PICC lines (peripherally inserted central catheter) and image guided large joint injections (shoulder, hip, knee) for either therapeutic purposes or for arthrography pre-MRI.  
I would also like to address another comment posted and assure its author that Radiologists Assistants are keenly aware of the potential risks and complications from any procedure.  Radiologist Assistants are Advanced Practice Clinicians who specialize in performing these procedures.  If it would be helpful to alleviate any safety concerns for these procedures, we could mirror the Regulations Governing the Practice of Physician Assistants in Virginia, specifically 18VAC85-50-110 Subdivision two (2) part B.  This section reads that Physician Assistants can perform invasive procedures without direct observation or supervision after they have performed three (3) of the procedures and are deemed competent.  
I apologize for the confusion and would be glad to discuss the proposed rule change.  
Jeffrey LaPole
CommentID: 217473

6/30/23  9:29 am
Commenter: American Society of Radiologic Technologists

Regulations Governing the Practice of Radiologic Technology

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.  

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Meredith Check, MPP 
Manager of Government Relations and Public Policy 

CommentID: 217586