Title 15

Title 15
DEPARTMENT OF AGRICULTURE

Subtitle 14 BOARD OF VETERINARY MEDICAL EXAMINERS

15.14.09 Qualifications for Licensure, by Examination, as a Veterinarian

Authority: Agriculture Article, §§2-304 and 2-307, Annotated Code of Maryland

Notice of Proposed Action

[11-130-P]

The State Board of Veterinary Medical Examiners proposes to amend Regulations .02—.05 under COMAR 15.14.09 Qualifications for Licensure, by Examination, as a Veterinarian.

Statement of Purpose

The purpose of this action is to permit the State Board of Veterinary Medical Examiners to accept for consideration of veterinary licensure certain candidates or graduates of veterinary medical colleges not accredited by the Council on Education of the American Veterinary Medical Association, but who are candidates for, or have earned certification from, the Program for the Assessment of Veterinary Education Equivalence.

Comparison to Federal Standards

There is no corresponding federal standard to this proposed action.

Estimate of Economic Impact

I. Summary of Economic Impact. Because the State Board of Veterinary Medical Examiners (SBVME) has made several regulatory amendments during the current fiscal year, to reduce the costs associated with notifying its licensees, it plans to send to all licensees one mailing that would include all regulatory amendments made during the current fiscal year. The current proposal is expected to economically impact only the SBVME and the Department of Health and Mental Hygiene's Division of Drug Control; the impacts will be relatively minimal.

Revenue (R+/R-)

II. Types of Economic Impact.

Expenditure (E+/E-)

Magnitude

A. On issuing agency:

(1) SBVME
(R+)
$3,150—$4,725
(2) SBVME
(E+)
$500

B. On other State agencies:

(1) DHMH Division of Drug Control

(R+)
$1,200—$1,800

(2) DHMH Division of Drug Control

(E+)
Undeterminable

C. On local governments:

NONE

Benefit (+)
Cost (-)

Magnitude

D. On regulated industries or trade groups:

Veterinary hospital owners

(+)
Undeterminable

E. On other industries or trade groups:

NONE

F. Direct and indirect effects on public:

Individuals who own pets

(+)
Undeterminable

III. Assumptions. (Identified by Impact Letter and Number from Section II.)

A(1). It is estimated that the SBVME may receive approximately 10—15 more applications for veterinary licensure annually. On average, the SBVME licenses 145 veterinarians annually; therefore, the licensure of 10-15 more individuals represents a 7%—10% increase in the number of licenses granted by the SBVME. A number of factors were considered in this estimate: several individuals who are either candidates, or graduates, of PAVE have contacted the SBVME's office to inquire about its acceptance of the program; the State of Maryland is surrounded by other states that accept PAVE for licensure consideration, including Virginia, West Virginia, and Pennsylvania; and the number of individuals who have been awarded certificates from PAVE over the past 2 years. The percentage of individuals who were issued PAVE certificates rose by 18% between 2009 and 2010. The SBVME should see an increase in the number of applications from PAVE candidates or graduates in the coming years, provided the number of certificates awarded continues to increase. Based on the SBVME's current fee structure, the SBVME would receive an additional $3,150—$4,725 in revenues. The SBVME's examination/application fee is $175, and its registration fee, paid upon initial licensure and annually thereafter, is $140.

A(2). The SBVME would see an increase in expenditures for the first year due to the following: preparing notification to veterinary hospital owners of the regulatory amendments (this may be combined with other recently promulgated amendments that would be sent via regular, first-class mail); revising the SBVME's application for veterinary licensure; preparing and submitting amended language to the agency's Information Technology department for placement on the SBVME's webpage; preparing an article regarding the amendments for publication; and ordering additional supplies for SBVME staff.

B(1). Provided each veterinarian who is licensed by the SBVME as a result of the regulatory amendments also applies for a controlled substances registration through the Department of Health and Mental Hygiene's Division of Drug Control, that agency may see an increase in revenues between $1,200—$1,800 initially, and then every 2 years thereafter. The impact on the Division of Drug Control in terms of expenditures is anticipated to be undeterminable, but minimal.

B(2). The additional staff time required to process more controlled substance registrations is expected to be minimal, as the increased number of applications should represent a very small fraction of the total registrations issued by the Division of Drug Control.

D. The SBVME's consideration of PAVE certificate holders for veterinary licensure will increase the pool of eligible candidates for hiring purposes.

F. Individuals who own pets and who seek veterinary services in the State of Maryland will have a larger selection of veterinarians from whom they may seek veterinary care.

Economic Impact on Small Businesses

The proposed action has minimal or no economic impact on small businesses.

Impact on Individuals with Disabilities

The proposed action has no impact on individuals with disabilities.

Opportunity for Public Comment

Comments may be sent to Laura C. Downes, Executive Director, Maryland State Board of Veterinary Medical Examiners, 50 Harry S Truman Parkway, Room 102, Annapolis, MD 21401, or call 410-841-5862, or email to DownesLC@mda.state.md.us, or fax to 410-841-5780. Comments will be accepted through June 6, 2011. A public hearing has not been scheduled.

.02 Definitions.

A. (text unchanged)

B. Terms Defined.

(1)—(6) (text unchanged)

(7) "Evaluated clinical experience" means a minimum of a 12-month period during which a PAVE candidate is evaluated by clinical faculty at an AVMA-accredited veterinary college.

[(7)] (8) "Foreign veterinary [graduate (FVG"] graduate" or "FVG" means an individual who has received a professional veterinary medical degree from an AVMA-listed veterinary college which is not approved or accredited by the American Veterinary Medical Association.

[(8)] (9) "Maryland State Examination" means:

(a) The Board Examination and the NAVLE; [and]

(b) The BCSE and CPE, if the applicant is an FVG[.]; and

(c) The QE and evaluated clinical experience or VCSA, if the applicant is a PAVE graduate.

[(9)] (10)[(11)] (12) (text unchanged)

(13) "PAVE" means the Program for the Assessment of Veterinary Education Equivalence.

(14) "PAVE graduate" means an individual who has been issued a certificate by the Program for the Assessment of Veterinary Education Equivalence after successfully completing either:

(a) A minimum of 12 months of evaluated clinical experience at a veterinary college accredited by the American Veterinary Medical Association; or

(b) The Veterinary Clinical Skills Assessment examination.

(15) "QE" means the Qualifying Examination, produced by the National Board of Veterinary Medical Examiners, assessing the applicant's basic science knowledge acquired in the pre-clinical portion of veterinary education.

[(12)] (16) (text unchanged)

(17) "VCSA" means the Veterinary Clinical Skills Assessment produced by the National Board of Veterinary Medical Examiners, evaluating clinical skills through a hands-on clinical examination.

.03 Maryland State Examination.

A. Subject Matter.

(1) The Maryland State Examination shall consist of the:

(a) (text unchanged)

(b) NAVLE; [and]

(c) BCSE and CPE, if the applicant is an FVG[.]; and

(d) QE and evaluated clinical experience or QE and VCSA, if the applicant is a PAVE graduate.

(2) (text unchanged)

B.—E. (text unchanged)

.04 Application Process for Taking the Maryland State Examination.

A. Eligibility. To be eligible to take the Maryland State Examination, an examination applicant shall:

(1) (text unchanged)

(2) Be within approximately 8 months of graduating from an AVMA-accredited or approved school of veterinary medicine on the date the examination is taken; [or]

(3) If an FVG, be enrolled in, or have received a certificate from, the ECFVG program[.]; or

(4) If a PAVE candidate, be enrolled in, or have received a certificate from, the PAVE.

B. Board Examination. To take the Board Examination, an applicant shall submit the following to the State Board within 1 year from the date the Board has received the application:

(1) (text unchanged)

(2) The application fee, as provided in COMAR 15.14.12.02, in the form of a check or money order, payable to the [State Board of Veterinary Medical Examiners] Maryland Department of Agriculture;

(3) (text unchanged)

(4) The following information pertaining to the applicant's schooling[, unless previously submitted to the NBVME when applying for the NAVLE]:

(a) (text unchanged)

(b) For the student within approximately 8 months of graduating from an AVMA-accredited or approved school of veterinary medicine, a letter from the school indicating the student's expected date of graduation; [and]

(c) For the FVG:

(i) (text unchanged)

(ii) An ECFVG certificate or, if currently enrolled in the ECFVG program, a letter from the school offering this program indicating the applicant's participation in it[.]; and

(d) For the PAVE candidate:

(i) A school authenticated copy of the applicant's veterinary medical school transcript or diploma and, if applicable, an English translation; and

(ii) A PAVE certificate or, if currently enrolled in the PAVE, a letter from the school offering this program indicating the applicant's participation in it.

C. NAVLE.

(1) To sit for a scheduled NAVLE, an examination applicant shall submit to the NBVME, by a date specified by the NBVME, the following:

(a) (text unchanged)

(b) Completed NBVME [and State Board applications] application to take the NAVLE; and

(c) (text unchanged)

(2) (text unchanged)

.05 License Issuance.

Except as otherwise provided under COMAR 15.14.08, the Board may not issue a license to practice veterinary medicine in this State to an applicant unless the applicant:

A. (text unchanged)

B. Submits the following information pertaining to the applicant's schooling:

(1) For the graduate of an AVMA-accredited or approved school of veterinary medicine, a school authenticated copy of the applicant's transcript or diploma, and, if applicable, an English translation; or

(2) For the FVG:

(a) A school authenticated copy of the applicant's veterinary medical school transcript or diploma, and, if applicable, an English translation[,]; and

(b) Either:

(i) A copy of the applicant's ECFVG certificate; [and] or

(ii) A copy of the applicant's PAVE certificate; and

C. (text unchanged)

EARL F. HANCE
Secretary of Agriculture