TITLE 18. PROFESSIONAL AND OCCUPATIONAL LICENSING
Title of Regulation: 18VAC150-20. Regulations
Governing the Practice of Veterinary Medicine (amending 18VAC150-20-70).
Statutory Authority: §§ 54.1-2400 and 54.1-3805.2 of the
Code of Virginia.
Public Hearing Information: No public hearings are
Public Comment Deadline: April 19, 2017.
Effective Date: May 5, 2017.
Agency Contact: Leslie L. Knachel, Executive Director,
Board of Veterinary Medicine, 9960 Mayland Drive, Suite 300, Richmond, VA
23233, telephone (804) 367-4468, FAX (804) 527-4471, or email firstname.lastname@example.org.
Basis: Section 54.1-2400 of the Code of Virginia
authorizes the Board of Veterinary Medicine to promulgate regulations to
administer the regulatory system with a specific mandate enacted by Chapter 82
of the 2016 Acts of Assembly to include provisions for the satisfaction of
board-required continuing education through the delivery of health care
services, without compensation, to low-income individuals receiving health
services through a local health department or free clinic organized in whole or
primarily for the delivery of those health services.
Purpose: The purpose of the amended regulation is to
comply with the mandate of the General Assembly and provide an incentive for
licensees to volunteer professional services to free clinics or public health
centers. While a licensee can satisfy up to two hours of continuing education
with six hours of volunteer service, he is still required to have 13 hours of
approved continuing education necessary to acquire new knowledge and skills.
For veterinary technicians, one hour could be credited for volunteering with
seven hours of continuing education still required. Therefore, public health is
served by a potential increase in volunteer service for veterinary services
(such as rabies clinics scheduled through the local health department), but
public safety is not sacrificed by eliminating most or all of the continuing
education hours required for renewal.
Rationale for Using Fast-Track Rulemaking Process: The
allowance of hours for volunteer service to be counted towards the continuing
education requirement is a mandate of the General Assembly. A licensee is not
required to provide volunteer service but may be credited with continuing
education hours for doing so. The provisions are permissive and neither is
Substance: The board adopted amended regulations to
allow veterinarians to count up to two hours of the 15 hours required for
annual renewal to be satisfied through delivery of veterinary services, without
compensation, to low-income individuals receiving health services through a
local health department or a free clinic organized in whole or primarily for
the delivery of those services. Veterinary technicians will be allowed to count
up to one hour of the eight hours required for annual renewal of volunteer
service. One hour of continuing education may be credited for three hours of
providing such volunteer services, as documented by the health department or
Issues: The advantage to the public is the incentive
given for veterinarians and veterinary technicians to volunteer their services
in exchange for credit towards meeting continuing education requirements. There
are no disadvantages. There are no advantages or disadvantages to the agency or
Department of Planning and Budget's Economic Impact
Summary of the Proposed Amendments to Regulation. Pursuant to
Chapter 82 of the 2016 Session of the General Assembly,1 the Board
of Veterinary Medicine (Board) proposes to allow six hours of volunteer work to
be substituted for up to two hours of continuing education annually for
veterinarians and three hours of volunteer work to be substituted for up to one
hour of continuing education annually for veterinary technicians.
Result of Analysis. The benefits likely exceed the costs for
all proposed changes.
Estimated Economic Impact. Chapter 82 of the 2016 Session of
the General Assembly requires all health boards to promulgate regulations to
accept volunteer work provided to low-income individuals through local health
departments or free clinics in lieu of the required continuing education.
Pursuant to the legislative mandate, the Board proposes to accept three hours
of volunteer work in satisfaction of one hour of continuing education from
veterinarians and veterinary technicians. The limit on the continuing education
hours that can be satisfied by volunteer work is two hours for veterinarians
and one hour for veterinary technicians every year. Currently, veterinarians
and veterinary technicians are required respectively to take 15 and 8 hours of
continuing education every year for annual renewal of their licenses and
The proposed change will allow affected practitioners to
substitute volunteer work for continuing education. The educational value of
volunteer services may vary depending on each person's experience. However, the
proposed limits on the continuing education hours that can be gained through
this method are a relatively small portion of the annually required hours.
Also, it is not clear whether the ratio of required three hours
per continuing education hour is sufficient by itself to provide enough
incentives to offer volunteer service. It appears easier for affected
practitioners to spend one hour acquiring continuing education than to spend
three hours providing free services. However, it is reasonable to expect that
the additional incentive provided by the proposed regulation would lead to
increased volunteer hours by convincing affected practitioners who are
indecisive at the margin about providing such services. The proposed regulation
will also help those practitioners who have already been providing volunteer
services at the qualified locations by allowing them to earn continuing
education credit for their charity work.
In any event, the proposed regulation allows substitution of
volunteer work for continuing education, but does not mandate it. A
practitioner choosing to do volunteer work in lieu of the continuing education
reveals that he or she benefits more from doing so.
Businesses and Entities Affected. Currently, there are 4,279
veterinarians and 2,073 veterinary technicians with current licenses in
Virginia. According to data provided by the Virginia Employment Commission,
there are 870 establishments in the industry category of the affected entities.
All of the 870 establishments in that category satisfy the small business
criteria. The number of continuing education providers is not known.
Localities Particularly Affected. The proposed changes apply
Projected Impact on Employment. The proposed regulation may
lead to a decrease in demand for continuing education services. However, the
proposed limits on the continuing education hours that can be gained through
this method is a relatively small portion of the annually required hours.
In addition, the substitution of voluntary work for continuing education
hours is voluntary and may not be exercised by all practitioners.
Effects on the Use and Value of Private Property. The potential
impact on the asset value of continuing education providers is not known with
certainty, but appears to be small.
Real Estate Development Costs. No impact on real estate
development costs is expected.
Definition. Pursuant to § 2.2-4007.04 of the Code of Virginia,
small business is defined as "a business entity, including its affiliates,
that (i) is independently owned and operated and (ii) employs fewer than 500
full-time employees or has gross annual sales of less than $6 million."
Costs and Other Effects. All of the veterinary establishments
are small businesses. The proposed amendments do not impose costs on them. Most
providers of continuing education services are probably small businesses as
well. The proposed regulation may decrease the demand for their services by a small
Alternative Method that Minimizes Adverse Impact. There is no
known alternative that minimizes the potential small adverse impact on
providers of continuing education services while achieving the same goals.
Businesses. The proposed amendments do not have an adverse
impact on non-small businesses.
Localities. The proposed amendments will not adversely affect
Other Entities. The proposed amendments will not adversely
affect other entities.
Agency's Response to Economic Impact Analysis: The Board
of Veterinary Medicine concurs with the analysis of the Department of Planning
Pursuant to Chapter 82 of the 2016 Acts of Assembly, the
amendments allow veterinarians to substitute six hours of volunteer work for
two hours of continuing education and veterinary technicians to substitute
three hours of volunteer work for one hour of continuing education annually.
18VAC150-20-70. Licensure renewal requirements.
A. Every person licensed by the board shall, by January 1 of
every year, submit to the board a completed renewal application and pay to the
board a renewal fee as prescribed in 18VAC150-20-100. Failure to renew shall
cause the license to lapse and become invalid, and practice with a lapsed
license may subject the licensees to disciplinary action by the board. Failure
to receive a renewal notice does not relieve the licensee of his responsibility
to renew and maintain a current license.
B. Veterinarians shall be required to have completed a
minimum of 15 hours, and veterinary technicians shall be required to have
completed a minimum of eight hours, of approved continuing education for each
annual renewal of licensure. Continuing education credits or hours may not be
transferred or credited to another year.
1. Approved continuing education credit shall be given for
courses or programs related to the treatment and care of patients and shall be
clinical courses in veterinary medicine or veterinary technology or courses
that enhance patient safety, such as medical recordkeeping or compliance with
requirements of the Occupational Health and Safety Administration (OSHA).
2. An approved continuing education course or program shall be
sponsored by one of the following:
a. The AVMA or its constituent and component/branch
associations, specialty organizations, and board certified specialists in good
standing within their specialty board;
b. Colleges of veterinary medicine approved by the AVMA
Council on Education;
c. International, national, or regional conferences of
d. Academies or species-specific interest groups of veterinary
e. State associations of veterinary technicians;
f. North American Veterinary Technicians Association;
g. Community colleges with an approved program in veterinary
h. State or federal government agencies;
i. American Animal Hospital Association (AAHA) or its
constituent and component/branch associations;
j. Journals or veterinary information networks recognized by
the board as providing education in veterinary medicine or veterinary
k. An organization or entity approved by the Registry of
Approved Continuing Education of the American Association of Veterinary State
3. A licensee is exempt from completing continuing education
requirements and considered in compliance on the first renewal date following
his initial licensure by examination.
4. The board may grant an exemption for all or part of the
continuing education requirements due to circumstances beyond the control of
the licensee, such as temporary disability, mandatory military service, or
officially declared disasters.
5. The board may grant an extension for good cause of up to
one year for the completion of continuing education requirements upon written
request from the licensee prior to the renewal date. Such an extension shall
not relieve the licensee of the continuing education requirement.
6. Licensees are required to attest to compliance with
continuing education requirements on their annual license renewal and are
required to maintain original documents verifying the date and subject of the
program or course, the number of continuing education hours or credits, and
certification from an approved sponsor. Original documents must be maintained
for a period of two years following renewal. The board shall periodically
conduct a random audit to determine compliance. Practitioners selected for the
audit shall provide all supporting documentation within 10 days of receiving
notification of the audit.
7. Continuing education hours required by disciplinary order
shall not be used to satisfy renewal requirements.
8. Up to two hours of the 15 hours required for annual
renewal of a veterinarian license and up to one hour of the eight hours
required for annual renewal of a veterinary technician license may be satisfied
through delivery of veterinary services, without compensation, to low-income
individuals receiving health services through a local health department or a
free clinic organized in whole or primarily for the delivery of those
services. One hour of continuing education may be credited for three
hours of providing such volunteer services, as documented by the health
department or free clinic.
C. A licensee who has requested that his license be placed on
inactive status is not authorized to perform acts that are considered the
practice of veterinary medicine or veterinary technology and, therefore, shall
not be required to have continuing education for annual renewal. To reactivate
a license, the licensee is required to submit evidence of completion of
continuing education hours as required by § 54.1-3805.2 of the Code of
Virginia equal to the number of years in which the license has not been active
for a maximum of two years.
VA.R. Doc. No. R17-5016; Filed February 20, 2017, 11:31 a.m.