I am in favor of this bill. As a funeral director I have had numerous encounters where I could not get a doctor to sign a death certificate in a timely manner as required in the Code of Virginia 32.1-263 C. (Doctors or nurse practitioners are required to sign within 24 hours of death). It causes a lot of issues with the progress of making final funeral arrangements as noted within the attachment Also, it can be an additional financial burden on families as there can be extra charges for storage/refrigeration of the deceased, families having to reschedule flights and/or hotels, etc. In addition, the loss of a loved one is an emotional time but having to delay the process of arrangements can add more emotional stress.

This is an onerous bill for physicians. Requiring all physicians to do this is crazy. A significant number of physicians do not need to do death certificates such as lab pathologists, plain film radiologists, etc. Large percentage of physicians do a good job completing death certificates when the funeral home enters the correct information into the system and they enter the info in a timely fashion. Completing death certificates has been a several decade issue dating back to the 1990s. I would recommend instead of requiring all physicians and advance practitioners taking this course, develop a system notifying the Board of Medicine and Nursing when a death certificate is not completed in a timely fashion to investigate the cause. If the physician or advance practitioner is not completing the required certificate in a timely fashion that particular person then be required to complete the CME. As a physician I spend enough time trying to keep up with the practice of medicine, dealing with electronic medical records and dealing with prior authorizations.

As an educator and a licensed radiologic technologist, I strongly oppose HB 452. I completed a rigorous education, passed national certification exams, and maintain continuing education to uphold patient safety and high standards of care. Radiation is a powerful medical tool that requires extensive education, clinical training, and professional accountability to be used safely. The Virginia Society of Radiologic Technologists (VSRT), along with its parent organizations, the ASRT and ARRT, has formally submitted letters opposing HB 452. I stand with these organizations in opposition. While I support thoughtful discussion on responsibly expanding the pool of qualified imaging professionals, removing licensure requirements raises serious concerns for patient safety and professional standards. HB 452 risks inconsistent training, inadequate supervision in exempt hospital settings, and regulatory inequity by holding independent imaging centers to stricter standards than hospitals. It may also limit access to appropriately credentialed supervision for imaging students as facilities prioritize rapid staffing solutions over registered personnel. Licensure exists to ensure consistent quality, accountability, and patient safety across the Commonwealth of Virginia. While hospitals may maintain internal oversight programs, ongoing staffing shortages raise important questions about whether patient protections would be weakened under this bill. Standards designed to protect patients should not be relaxed during times of workforce strain. Lowering professional standards to address staffing challenges may offer short-term relief, but it does so at the expense of patient safety, diagnostic accuracy, and public trust. I respectfully urge lawmakers to oppose HB 452 and support policies that protect patients, students, and the integrity of medical imaging in Virginia. Radiologic technologists are highly trained healthcare professionals educated in anatomy, radiation physics, patient care, image evaluation, and radiation protection. We assess each patient individually, recognize contraindications, and follow the ALARA principle to minimize exposure while maintaining diagnostic quality. Lowering standards to address short-term staffing challenges compromises patient safety, diagnostic accuracy, and public trust. Patients deserve assurance that the person performing their exam is properly educated, certified, and held to professional standards. This bill undermines patient safety, professional integrity, and the healthcare system as a whole, and I urge lawmakers to reconsider.

The Virginia Society of Radiologic Technologists (VSRT), along with its parent organizations—the ASRT and ARRT—have formally submitted letters opposing HB 452. I stand with these organizations and strongly oppose HB 452. While I support thoughtful discussion around responsibly expanding the pool of qualified Radiologic Technologists and Limited X-Ray Machine Operators, the removal of licensure requirements raises serious concerns for patient safety and professional standards. HB 452 could result in: Inconsistent employee training, placing staff competency and patient safety at risk Inadequate or variable supervision in exempt hospital facilities Regulatory inequity, where independent imaging centers are held to stricter standards than hospital entities Reduced access to ARRT-registered technologist supervision for imaging students due to high turnover in general radiography positions and the prioritization of non-registered or limited-scope personnel to quickly fill staffing gaps Licensure exists to ensure consistent quality, accountability, and patient safety across the Commonwealth of Virginia. While hospitals may have internal oversight programs, ongoing staffing shortages raise a critical question: Is licensure-based oversight unnecessary when staffing is strained? For example, Physician Assistants and Nurse Practitioners may independently operate urgent care facilities with only one radiologic technologist on site—who must be ARRT-registered. Will hospitals continue to meet this standard under HB 452? I respectfully urge you to oppose HB 452 and support policies that protect patients, students, and the integrity of medical imaging in Virginia

Please take a moment to read this and feel free to reach out to me, at 540-613-9275, regarding this bill. Radiologic Technology, perhaps better know as xray imaging, is a highly skilled science and profession. These individuals spend years and perform hundreds of clinical hours learning how to safely take the images that are so vital in the healthcare community. I have seen my own daughter successfully go through this incredibly intensive program. The information and skills that they must learn is mind blowing and through their dedication, radiologic imaging can be done safely. These incredible men and women are licensed professions who know what they are doing, how to do it, and they do it very well. If this bill passes, anyone, without the necessary training could be allowed to do imaging. I don't know about you, but I want to feel confident that the person using radiation to capture my xrays is highly qualified and licensed and not someone who has received no training except to push a button. Please stand with us and let the committee know that you are opposed to VA HB452 by voting no. Everyone deserves better and our healthcare and the safety in which it is provided should be handled by those who are qualified, licensed, and registered to do so. Thank you.

During the Health Professions Subcommittee meeting on HB 452 held on January 29, 2026, Delegate Tran asked whether other states were pursuing legislation to remove licensure requirements as a means of addressing shortages of radiologic technologists. The answer is no. Currently, only ten states do not explicitly require licensure for radiologic technologists, and there has been no indication that any additional states are sponsoring or considering legislation similar to HB 452. Rather than eliminating licensure requirements, states addressing healthcare workforce shortages—particularly in other professions—have taken targeted steps to modernize licensure systems and reduce unnecessary barriers to entry. These efforts include streamlining application processes, expediting licensure for out-of-state practitioners, recognizing equivalent education and national certification, reducing duplicative documentation requirements, and offering temporary or provisional licenses. Importantly, no states have removed licensure requirements for healthcare professionals as a workforce solution. At this time, there is no interstate licensure compact for radiologic technologists. However, pursuing the development of an interstate compact or further modernizing Virginia’s licensure process to improve reciprocity and efficiency would be more appropriate and sustainable workforce strategies than extending or expanding existing radiologic technologist licensure exemptions. These approaches would increase workforce mobility and access while preserving licensure standards and patient safety.

attached

The Society of Radiology Physician Extenders in accordance with ARRT, ASRT, and VSRT vehemently oppose HB 452.

Dear Delegate Willett, The American Society of Radiologic Technologists represents more than 155,000 medical imaging and radiation therapy professionals across the nation, including 4,092 in Virginia. Our main mission as an organization is to advance and elevate the medical imaging and radiation therapy profession and enhance quality, safe patient care. Please see attached for ASRTs comments on House Bill 452- Practice of radiologic technology; licensure exceptions. Warm regards, Meredith Check Director of Government Relations & Public Policy

This is a terrible idea. We are dealing with radiation and it is important to have licensed professionals radiographers. It’s dangerous to the public and I only see lawsuits in its future.

I oppose this bill. Radiology is important but carries risk and it is important that radiology technicians are trained at accredited programs and maintain the current training requirements to maximize safety during radiation exposure.

Passing the bill is only beneficial to a company's profits. It does NOT take into consideration the care and safety of the patients and communities at large. We have been trained to provide quality imaging without further injuring patients or exposing them to unnecessary doses of radiation, which as any trained technologist who has gone through schooling and licensing knows is cumulative and can have repercussions later in life. All licensed technologists have had radiation safety training, as well as radiation physics and patient care as well as other courses. How is it to be expected that anyone without proper training will be able to understand the ramifications of this?

I stand by the VSRT's statement that we cannot and should not reduce the requirements for radiologic technologists and their licensure. Our education and experience is thorough and necessary for the radiation we administer. We directly affect patient's health outcomes both directly by providing quality images for accuracy and improved outcomes and indirectly by reducing their necessary lifetime radiation doses by eliminating repeats and accurate techniques. Limited or untrained technologists do not help fill a workplace gap but rather dilute down further the expertise needed for this profession. Please do not lower our standards when we should be working to increase and expand.

The Consumer-Patient Radiation Health and Safety Act of 1981 (CPRSA) is a federal law designed to protect the public from unnecessary radiation exposure by setting minimum federal standards for training and certification of individuals performing radiologic procedures and for accrediting training programs, ensuring safe equipment use, and providing model state laws for radiation safety. It requires states to implement these standards, mandating that only certified professionals perform X-rays, thereby reducing risks like cancer from overexposure and ensuring proper equipment maintenance and usage, like shielding and limiting exposure time. Key Provisions & Goals: Training & Certification: Directs the Secretary of Health and Human Services to establish standards for accrediting educational programs and certifying personnel (radiologic technologists, dental assistants, etc.) who administer radiation. State Implementation: Requires states to adopt these standards, making it unlawful for uncertified individuals to perform radiologic procedures. Equipment Safety: Sets guidelines for the maintenance of X-ray equipment and promotes practices like shielding and increasing distance from radiation sources. Federal Oversight: Applies standards to federal agencies and provides a model law for states, with potential financial penalties for non-compliance. Why It Matters: Patient Protection: Minimizes risks of harmful effects, including cancer, from excessive radiation. Professional Standards: Ensures those taking X-rays have adequate education and competence. Equipment Integrity: Promotes proper upkeep and usage of X-ray machinery. In essence, the CPRSA aims to make sure that medical and dental radiology procedures are performed safely by trained professionals using well-maintained equipment, consistent with high safety standards. This bill will not help with the shortage and will make unsafe conditions for patients. I oppose this bill.

The Consumer-Patient Radiation Health and Safety Act of 1981 (CPRSA) is a federal law designed to protect the public from unnecessary radiation exposure by setting minimum federal standards for training and certification of individuals performing radiologic procedures and for accrediting training programs, ensuring safe equipment use, and providing model state laws for radiation safety. It requires states to implement these standards, mandating that only certified professionals perform X-rays, thereby reducing risks like cancer from overexposure and ensuring proper equipment maintenance and usage, like shielding and limiting exposure time. Key Provisions & Goals: Training & Certification: Directs the Secretary of Health and Human Services to establish standards for accrediting educational programs and certifying personnel (radiologic technologists, dental assistants, etc.) who administer radiation. State Implementation: Requires states to adopt these standards, making it unlawful for uncertified individuals to perform radiologic procedures. Equipment Safety: Sets guidelines for the maintenance of X-ray equipment and promotes practices like shielding and increasing distance from radiation sources. Federal Oversight: Applies standards to federal agencies and provides a model law for states, with potential financial penalties for non-compliance. Why It Matters: Patient Protection: Minimizes risks of harmful effects, including cancer, from excessive radiation. Professional Standards: Ensures those taking X-rays have adequate education and competence. Equipment Integrity: Promotes proper upkeep and usage of X-ray machinery. In essence, the CPRSA aims to make sure that medical and dental radiology procedures are performed safely by trained professionals using well-maintained equipment, consistent with high safety standards. This bill will NOT make the shortage go away, will make patients less safe, and I oppose this bill as a radiographer.

I oppose this bill & it should be dismissed with prejudice immediately. Should have never even been considered. I have worked in a radiology department for over 33 years & have been a registered Radiologic Technologist for over 27 years. I am also registered in Mammography, Computed Tomography & Bone Density. What Mr. Willett states in this letter would be a disservice to all imaging professionals & the patients that we serve as well as just dangerous. The changes suggested will not solve the technologist shortage, quite the opposite. Language in this bill further expands the exceptions, currently reserved for employees of hospitals, to all persons employed or engaged by a hospital, health care system, or urgent care center that is affiliated with a hospital or health care system. The result of this language would be to no longer require a license to practice as a Radiologic Technologist, Radiologic Technologist Limited, or Radiologist Assistants, in any of these settings. This language would apply a licensing requirement in privately owned unaffiliated health clinics only but nowhere else. Allowing unlicensed or minimally trained individuals to operate imaging equipment puts patients at real risk of unnecessary radiation exposure, mispositioning, repeat exams, and missed pathology. Radiologists need qualified radiographers to produce quality images for interpretation. It is more than just pushing a button! Licensure exists to protect the public, not to create barriers. Stripping these requirements devalues the profession & disregards the science, skill, & accountability required to safely administer ionizing radiation. Patients deserve to know that the technologist performing their exam is properly educated, certified, & held to professional standards. This bill undermines patient safety, professional integrity, & the trust placed in healthcare workers. I strongly urge lawmakers to reconsider & protect both patients & the licensed professionals who dedicate their careers to safe, competent care. Radiologic technologists are not simply “button pushers”; we are highly trained medical professionals educated in anatomy, radiation physics, patient care, image evaluation, & radiation protection. We are taught to assess each patient individually, adapt exams when necessary, recognize contraindications, & follow the ALARA principle (do you even know what stands for?) all while still obtaining high-quality images. This is a huge patient safety issue. Which brings us to The Consumer-Patient Radiation Health & Safety Act of 1981. Have you read it? This profession exists for a reason. C.E. Gibson ARRT R.T.(R)(M)(CT)(BD)

I strongly oppose this bill. Radiology is the heart of the hospital. Without properly trained imaging professionals who are educated in radiation safety there is no trust in our care. Patient radiation exposure will go up, repeat imaging rates would go up, employee burn out will be at an all time high for those who are licensed and have to train these “technicians”. It will significantly decrease the quality of care to our patients and increase the risk of patient injury. Radiation safety is not something you can just be trained on in a short period of time. We as technologists are constantly teaching doctors on what to order to keep dosing low and get necessary imaging done correctly. This is disheartening to think this is even being considered an option when we have trained so hard and are passionate about our career.

I strongly disagree with this bill. If this bill passes it would be a huge setback for our profession. We have all went to school and put in the time to learn the knowledge to provide the best care possible for our patients. Not requiring licensing would be extremely degrading and a huge slap in the face to all radiologic technologist. We took the time to learn the background information that is required for patients safety. Passing this bill would not benefit the patients in any way, it would only be saving money for the big companies with disregard to the patients. I believe that patients would be at risk for more repeats, higher dose exposure and lower quality images. Quality images are produced by radiologic technologist because we went to school to learn about radiation safety, physics, anatomy, positioning, and patient care. Without this knowledge images may not be properly obtained. Passing this bill would also not be beneficial for schools. There would be no incentive to take the courses required for proper licensing. As a radiologic technologist in a very busy orthopedic office I do not have time to teach someone from the ground up. This takes entirely too long and is too time consuming for current techs. This would also affect the patients by slowing us down and not being as efficient. As a tech in a specialty this is not fair to our doctors, patients, or current techs.

I strongly oppose this bill. We, technologists, are the ones advocation for patients when they get radiation. We educate doctors and practitioners on the dose these patients get. Patients that come to Emergency Rooms always get some kind of imaging and to let just anyone perform that is a risk to the patient. Your family members could be getting a higher dose or even the wrong test for the symptoms they have. They could even be given the wrong medication during their testing. Would you want an imaging professional providing pain medication to your family members by an imaging professional. I wouldn’t Think so being that they are not trained and licensed in doing so. This is a slap in the face to everyone that takes pride in their training and education.

This is an insult and slap in the face to technologist in this state. We are the ones CONSTANTLY advocating for our patient when your "ER physicians," order wrong exams, don't pay attention to contrast allergies, and order excess amount of radiation to peds pts. We are the only ones with the pts best interest in mind. I highly suggest using this time and effort to provide radiation saftey courses to physicians, PAs and NPs instead of degrading and down playing our profession. It's an insult to our radiologist as well. Providing them non diagnostic images from a limited tech with little to no on the job training.

You must have licensure in Radiology. Do you really think training a person with no education or experience in radiology for a month or two and giving the. A limited license is a safe thing to do? Patient safety is gone. You will have poor patient safety, over exposure to radiation, numerous exspore to lack of positioning knowledge, the list goes on. If you want to do Radiology, you need to get educated in a accredited program like myself and my colleagues.

This bill is taking steps backwards in several aspects in the field of medical imagining. It directly affects areas of quality imaging, patient safety, and equipment safety. A “limited radiographer” is a severe danger to our patients, as these individuals will not be trained and licensed with the understanding of the detrimental effects of even small amounts of radiation, poor positioning, and overexposure. We learn these machines inside and out, This is an extremely POOR solution to the shortage in our field. If this bill passes, in the state of Virginia you have to be certified from an accredited program to draw blood.. but not to RADIATE someone? This is taking a million steps backwards in terms of medical imaging and imaging safety. I am a proud technologist, and in this moment I am ashamed to be represented by the Virginia State Governor/Government

Passing this bill would be a complete disservice to radiologic technologists who earned their license to practice and most importantly would be a disservice to our patients and upholding patient care/safety standards. I STRONGLY oppose this bill.

I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing. Patient safety should always be a priority, and allowing anyone to use ionizing radiation without proper training and education is not putting patients safety first.

I respectfully oppose this bill. While I understand the intent behind it, it raises serious concerns regarding its impact, enforcement, and unintended consequences. Passing this bill will negatively affect individuals, families, and communities. X-ray technologists work hard to earn and maintain their licenses through extensive education, clinical training, and certification. Any bill that weakens licensing standards undermines patient safety and devalues the profession.

This bill needs to be opposed!! As an x-ray tech for over 10 years now who worked hard for my education to become licensed and registered to practice as a radiologic technologist it is completely absurd and astounding that anyone would think it is okay to allow someone who is not licensed to be able to practice radiology! This is UNSAFE for our patients!! It is a slap in the face to all of us who worked hard and continue to work hard to keep our continuing education, registries and licensures up to date!!! Kill this bill!!!

As a physician specializing in radiology who has practiced in central Virginia for seventeen years, I respectfully urge the General Assembly to veto this legislation in order to preserve the safety and quality of patient care throughout the Commonwealth. Throughout my career, I have worked closely with highly trained and dedicated radiologic technologists who possess extensive knowledge of anatomy, physiology, medical physics, and the safe use of ionizing radiation. These professionals have completed rigorous educational programs, passed comprehensive examinations, maintained required certifications, and are appropriately vetted through licensure by the Virginia Board of Medicine. While seemingly a quick fix to address workforce shortages, exemptions to licensure would ultimately compromise patient safety by lowering established standards for education, training, and professional accountability. Radiologic technologists and radiologist assistants perform patient facing, complex clinical functions that require a high level of competence and regulatory oversight. Radiologist assistants, in particular, provide direct patient care and function in a capacity that is comparable in several respects to physician assistants. In addition to being qualified as technologists, as defined by the Board of Medicine, radiology assistants are responsible for assessing and evaluating patients’ physiological and psychological responses to radiologic procedures; performing assessments and assisting with management and education; evaluating image quality and communicating initial observations to the supervising radiologist; administering contrast media and other medications as prescribed; and performing or assisting in imaging procedures in accordance with established professional guidelines. Licensure is a fundamental mechanism for ensuring patient safety, professional accountability, and uniform standards of care. Just as physicians, nurses, and physician assistants are required to be licensed to practice, radiologic technologists and radiologist assistants must remain subject to licensure requirements. Eliminating these safeguards—regardless of practice setting or affiliation—would undermine the delivery of safe, high-quality health care to the citizens of the Commonwealth. Ref: https://www.dhp.virginia.gov/media/dhpweb/docs/med/leg/RadTech03282024.pdf Regulations Governing the Practice of Radiology Technology, rev. March 28, 2024 (attached)

January 26, 2026 Rodney T. Willett General Assembly Building 201 North 9th Street Richmond, VA 23219 RE: ARRT Opposes Language in HB 452 that Expand Exceptions, Weakens Licensing Requirements, and Reduces Patient Safety for all Virginians Dear Chairman Rodney T. Willett, The American Registry of Radiologic Technologists (“ARRT”) is a national, voluntary certification organization that develops and administers standards to assess the qualifications of individuals who perform medical imaging and radiation therapy procedures. ARRT currently certifies and registers more than 364,000 individuals nationwide, including over 8,850 radiologic technologists in Virginia who hold more than 14,000 certifications across 15 imaging disciplines. Founded in 1922, ARRT is incorporated as a not-for-profit organization under Section 501(c)(6) of the Internal Revenue Code. ARRT’s vision is “Exceptional patient care for all, provided by qualified medical imaging and radiation therapy professionals.” ARRT’s mission is “To promote safe, high-quality patient care through credentialing, collaboration, and advocacy.” Consistent with ARRT’s above-listed vision and mission, ARRT respectfully opposes HB 452 and supports the current Code of Virginia 54.1-2956.8.1., as written. Language in this bill further expands the exceptions, currently reserved for employees of hospitals, to all persons employed or engaged by a hospital, health care system, or urgent care center that is affiliated with a hospital or health care system. The result of this language would be to no longer require a license to practice as a Radiologic Technologist, Radiologic Technologist Limited, or Radiologist Assistants, in any of these settings. This language would apply a licensing requirement in privately owned unaffiliated health clinics only and nowhere else. ARRT supports that any healthcare professionals who perform medical imaging procedures, should be educationally prepared and clinically competent to ensure that patients are receiving safe, high-quality medical imaging that minimizes dose to ionizing radiation. ARRT opposes the use of uncertified or unlicensed health care professionals to perform medical imaging or radiation therapy. Uncertified or unlicensed individuals performing medical imaging or radiation therapy have not met the rigorous educational, clinical, and certification standards required for safe and effective medical imaging practice. The proposed change to state law would reduce patient safety for all Virginians by allowing individuals who are not properly educated or who have been proven clinically competent to perform medical imaging and radiation therapy procedures to apply ionizing radiation to patients in the state. Given the resulting absence of minimum education and competency requirements for Radiologic Technologists, Radiologic Technologists Limited, and Radiologist Assistants in medical imaging under state law in specific settings, ARRT strongly opposes any statutory or regulatory changes that would lower the standards for medical imaging practice and potentially jeopardize patient safety. Thank you for your attention to this important matter. Please do not hesitate to contact me at (651) 687-0048, ext. 3121, if you need further information. Sincerely, Liana Watson, DM, R.T.(R)(M)(S)(BS)(ARRT), RDMS, RVT, FASRT, CAE, ICE-CCP CEO

I’m an educator w/ over 30 yrs of experience & a member of the VSRT for over 20 yrs. I am also a member of the American Society of Radiologic Technologists (ASRT) & certified in Radiography, Mammography & MRI by the American Registry of Radiologic Technologists (ARRT). I have never been required to have a license to practice. I’ve always worked in a hospital which had strict requirements plus required ARRT certification. I am a firm supporter that licensure is important for facilities that don’t have requirements as strict. Changing requirements without an in-depth investigation into the issues listed in Mr. Willett letter would be a disservice to all imaging professionals & the patients that they serve as well as just dangerous. The changes suggested will make the shortage worse & put undue hardship on all imaging programs in Virginia. The Joint Review Committee on Education in Radiologic Technology (JRCERT) accredits imaging programs for Radiography which requires that techs be ARRT certified to work with & train imaging students. This alone would make for a disastrous outcome without sufficiently qualified personnel to assist in the clinical education of students. Radiographers are considered an extension of the radiologist. Radiologists need qualified radiographers who produce quality images to do their job. What we produce allows them to find or not find tumors & other diseases. The quality images the radiologist reads or interprets are only as good as what the radiographer produces. It is more than just pushing a button! It comes from being thoroughly trained by educators following a strict curriculum from the ASRT & ARRT which establishes the procedures that students must be competent in performing. Competence is established when the student successfully completes all the ARRT competencies, ASRT curriculum & abides by the ARRT Standard of Ethics. They also must have an associate degree. Short cutting this process would lead to inferior quality images, increased radiation exposure to patients, potential missed diagnoses of cancer among other diseases & potential lawsuits against radiologists & hospitals. And let us be honest! Who sues the low-income tech when the radiologist & hospital have deeper pockets! On another note, the VSRT was only contacted recently about this issue. In the letter sent to Nick Gimmi, VSRT legislative rep. on Jan 16th, Mr. Willett stated he was put on this committee in 1/2024 & that he consulted the VA Depart. of Health Professions & VA Board of Medicine for feedback on what they were seeing in the trenches. However, the VSRT is the organization representing the imaging professionals working in the trenches in Virginia. While updates might be needed, a better solution or protocol could be conceived. It would have been beneficial for the VSRT to have this info 2 yrs ago when we could have worked together & help modernize this legislation. But, Making it easier for non-qualified people to perform x-rays because of a shortage is putting patients at risk. You can’t see or feel x-rays! That is why we are trained to protect ourselves & most importantly protect our patients. Our patients trust that we are well qualified & are protective of them as we use ionizing radiation! You want a solution? The VSRT has ideas, but it is not something that can be done in a day. I hope that we can all come together & do what’s best for patients which is by upholding a higher standard & not lowering it.

This bill needs to be passed

I agree with the VSRT and oppose this bill. As a radiography student, I’ve learned the importance of radiation safety for patients and radiographers. The administration of radiation should not be practiced by anyone who has not received the education in safety standards and quality imaging. I was unaware of the extensive knowledge needed to take a single plain film x-ray until I became a student and experienced patient care first hand. It requires so much more than just pushing a button. Patient safety and their quality of health care should always be a top priority. By allowing individuals who are not equipped with the proper education and licensing, radiation administration will no longer be held to the current standards.

I do not support this bill. It is not safe for the patients. Anyone that is exposing others to radiation should be educated and complete a radiography program and have RT(R) behind their name before doing so.

In reference to HB452 I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing. As a registered nurse I know the importance of prevention and safety for the communities, patients and families we serve. Consider these questions: Can radiation be harmful? Can it be lethal? Lead to cancer? Requires an understanding of anatomy, physiology and physics to safely do the job? The answer is obvious to all of these questions, YES! Radiology techs are highly trained and irreplaceable in the healthcare setting. The only way this bill should be considered is if safety is optional for patients, families and coworkers; which it is not! Jobs like this in healthcare are no joking matter, people’s lives are at stake here. I propose that this not carry forward as it would be detrimental to the safety of all those who work and seek healthcare. Sincerely, A concerned ED nurse, serving in emergency nursing for 19 of 21 years

As a Registered Radiologic Technologist and Educator and member of the VSRT. Unregistered and unlicensed individuals must not administer ionizing radiation to patients. This is like a regulatory drug or ammunition and only those properly trained then certified should be allowed to administer. No exceptions!

I do NOT support this bill. Licensure should be mandatory for the safety of patients and healthcare workers.

This bill is absolutely ridiculous. I have trained and studied extremely hard and extensively to be able to preform in multiple different settings such as a clinic, ER, outpatient settings and most importantly cardiac cath. I put in blood sweat and so many tears to be good and knowledgeable at my position. Being readily available for an acute MI 24/7 365 and to say anyone can just show up and do this job? Completely disagree. This will be a huge mistake and disgrace for the radiology community. Stay strong techs we know our worth.

I am against this bill! Radiologic Technologists are not just pushing a button . We are well educated and properly trained on how to properly position and expose for x-rays . If anyone were doing it , it is hard telling how many repeat images or bad quality films be taken. A good quality x-ray can make the difference of savings someone’s life when the doctors see a better quality x-ray . It is disappointing that this is even a thing a long with many other terrible bills in VA !

I stand with the VSRT. It takes education and skill to perform at the level professional excellence we all esteem ourselves to. This is not something to be taken lightly. Our scope of practice begins with education, clinical intervention and national licensing and to change that is undermine all RTs. Please do not allow this bill.

I stand with the VSRT in opposition of HB452. This bill was obviously proposed with no knowledge of the Radiologic Technology profession or the safety issues that come with this bill. If you are for this bill and need radiology services do you want non professionals doing your or your family members imaging? As an RT. and knowing the negative implications I definitely do not.

This bill HB452 cannot be passed. This is disgusting and a disgrace

I support the public statement of the VSRT. As a licensed Radiologic Technologist, it is my responsibility to provide safe patient care as it pertains to the tenets of my licensure.

Radiation is not a toy, it takes many hours and education to fully understand and safely utilize. This bill needs to be killed.

As an educator (with an associates degree and bachelors in radiologic sciences) for a radiologic technology program it is SCARY to imagine that anyone with any education would think that it is acceptable for an uneducated individual to use ionizing radiation that can KILL people. This is scary, unethical, and ridiculous. As a profession radiologic technology is overlooked and under appreciated. Would anyone allow a nurse to do this? A doctor? A dentist? NO. I am certain that whoever is making this irrational uneducated decision must have not done any research on what ionizing radiation can do to your body when an uneducated person is using it. Please listen to the people in this field that truly understand the dedication and training that goes into becoming a radiologic technologist. ONLY a licensed professional should be permitted to use radiation after having completed an associates program at minimum. Thank you for allowing people to voice their opinion on this.

As a Registered Radiologic Technologist in the state of Ohio I stand by the VSRT in opposing bill HB452. Exceptions of licensure is a complete disregard for patient safety.

I oppose this bill. We are trained for many years and learn the why - physics, radiation, anatomy, physiology. It is a profession.

As a radiological Technologist, I do not believe it is in the best interests of the public to have a person or persons take an xray of a patient outside the range of a hospital setting, IF they are not licensed. Radiology is more than just hitting a button! It is anatomy, physics and so much more. I am a licensed Rad Tech and work in an urgent care setting. As a patient, I would not feel comfortable having someone take my xray if they are unlicensed.

As a licensed radiologic technologist, I am deeply opposed to this bill. I worked hard for my degree, passed national boards, and maintain continuing education to ensure patient safety and the highest standard of care. Radiation is not harmless—it is a powerful medical tool that requires extensive education, clinical training, and ethical responsibility. Allowing unlicensed or minimally trained individuals to operate imaging equipment puts patients at real risk of unnecessary radiation exposure, mispositioning, repeat exams, and missed pathology. Licensure exists to protect the public, not to create barriers. Stripping these requirements devalues the profession and disregards the science, skill, and accountability required to safely administer radiation. Patients deserve to know that the person performing their exam is properly educated, certified, and held to professional standards. This bill undermines patient safety, professional integrity, and the trust placed in healthcare workers. I strongly urge lawmakers to reconsider and protect both patients and the licensed professionals who dedicate their careers to safe, competent care. Furthermore, this bill sends a dangerous message that specialized healthcare education, clinical training, and licensure are optional or expendable. Radiologic technologists are not simply “button pushers”; we are highly trained medical professionals educated in anatomy, radiation physics, patient care, image evaluation, and radiation protection. We are taught to assess each patient individually, adapt exams when necessary, recognize contraindications, and follow the ALARA principle to minimize radiation exposure while still obtaining diagnostic-quality images. Lowering these standards may appear to solve short-term staffing challenges, but it does so at the expense of patient safety, diagnostic accuracy, and long-term public trust in healthcare. Increased repeat imaging, unnecessary radiation exposure, missed or delayed diagnoses, and avoidable harm are real and preventable consequences of allowing unlicensed individuals to perform radiologic exams. Healthcare should never move backward by lowering standards—especially when those standards exist to protect patients from harm. This profession exists for a reason, and dismantling licensure undermines both the safety of patients and the integrity of the healthcare system as a whole.

Taking license requirements away in Virginia would be a disservice to the Radiology profession. Currently in Virginia Limited Rad techs have the ability to operate under a licensure. After completion of education and licensure exam through the state of VA. If licensing requirements were taken away this would allow any individual to practice Radiology without any formal education or examination. Radiation is a form a medicine and individuals using it need to be educated on the effects of radiation on the human body. For themselves and for the patient. Please do the same of the profession and patients DO NOT remove licensure requirements for Radiologic Technologist or Limited Radiologic Technologists.

I agree with the VSRT position statement and oppose the HB452 which eliminates licensing.

While I stand in support of the VSRT position statement concerning HB 452, I must also address my personal challenges to licensure reduction for radiologic technologists in Virginia. Radiologic technology has been my career choice, beginning in 1971 as a student, and retiring in 2019 as a radiologic technology educator. I still maintain ARRT certification, VSRT (Life Member) and ASRT membership, as well as licensure in the Commonwealth of Virginia because I support each of these components of professionalism. While now on the potential patient side of the equation, I believe even more strongly in the education and licensure requirements of individuals imaging the public. There are too many challenges to acquisition of healthcare today for our population; let's not compromise the quality and integrity of those providing that medical imaging care by reducing effective safety guards.

I agree with the VSRT position statement and oppose the HB452 which eliminates licensing.

I stand with the VA Society of Radiologic Technologist that non-licensed individuals must not perform radiographic procedures in settings where there is not direct, on-site oversight by appropriately licensed radiologic professionals. I strongly stand with VSRT strongly emphasizes the following principles as an Radiologic Technologist of 38 years and an Educator of Radiologic Technology. Radiographic procedures involve ionizing radiation and must be performed only by individuals who are properly educated, trained, and supervised. Direct, qualified oversight is essential when licensure exemptions are applied. System-level affiliation alone does not replace the need for on-site clinical supervision and accountability. Credentialing, competency verification, and scope-of-practice boundaries must be clear, enforceable, and consistently applied across all settings. Workforce solutions must strengthen the profession and protect patients—not lower standards or expand unsupervised practice. This bill will not improve patient care or workforce shortage. It will put patients lives in danger and severely compromise the care that providers render based on our many images studies performed daily in Virginia. Do not let this legislative house bill pass.

As a radiologic technologist, I loathe the bill HB452. Removing licensure requirements would be a great disservice to the people in our state. Licensure provides adequate training and the proper knowledge to perform our duties as X-ray techs. Licensed X-ray techs serve as essential links between patients, licensed practitioners, and other healthcare members, utilizing critical thinking and ethical judgment per the ASRT. We are trained to recognize patient needs through effective communication, assessment, monitoring, and provide patient care. Our job requires EXTENSIVE knowledge of anatomy, physiology, and disease processes to ensure proper imaging. Not only do we need to know this, but we also need to understand many technical factors to acquire diagnostic-quality images. These include our KVP, mAs, body habitus, age, gender, pregnancy status, distance, and timing. To further address this bill, it is important to recognize that no facility has the staffing capacity adequately supervise unlicensed personnel. While staffing shortages are a genuine concern, introducing individuals without a license into these roles would compromise the quality of diagnostic imaging, reduce critical-thinking and problem-solving, ultimately leading to more errors. These circumstances create an obvious risk for patient harm and legal liability. It is unreasonable to expect licensed professional to jeopardize their credentials by working alongside unlicensed individuals whose errors they would be responsible for identifying and correcting. Unlicensed personnel would not know that X-rays are a form of ionizing radiation that can damage living tissues. The deficit in their knowledge will contribute to repeated imaging and more radiation exposure, which could potentially lead to conditions such as cancer and burns. X-ray techs work throughout hospitals in many areas, serving outpatients, ICU patients, the emergency room, operating room, and inpatients. No two areas are the same, often involving different types of equipment (fixed rooms, portable X-ray machines, C-arms, O-arms). It takes YEARS to understand how to properly operate and adjust techniques to each patient with these machines. Patients can be critical in emergency rooms and intensive care units, requiring a licensed professional to handle their acuity and situation. An unlicensed person would not understand what is needed of an X-ray tech immediately after a code, for an incoming stroke alert, for an incoming code trauma, or how to X-ray for foreign body post op, or all of the terms surgeons use during a case. We work alongside many healthcare professionals, and we continue the workflow by using our critical thinking to determine where to go next. We are needed in multiple places at one time and have to determine what is more important, for example, going to verify NG tube placement or Code blue. Unlicensed staff would also not be able to administer contrast or barium for any tube placement verification, imaging, or for fluoroscopic procedures, as they are considered medications (VLIS, 2026). This is already limiting their scope of practice, and further proves that only LICENSED X-ray techs can replace LICENSED X-ray techs. References Virginia Legislative Information Systems. (2026). 22VAC40-73-680. Administration of medications and related provisions. https://law.lis.virginia.gov/admincode/title22/agency40/chapter73/section680/

In reference to HB452 I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing. I have been an X-ray tech for 16 years! This is absolutely absurd!!! We all have worked hard for this degree someone without education should not just be aloud without proper education /schooling and training!

As an advanced practice medical provider for critically ill and fragile patients, I rely on the accuracy of radiographic images on a daily basis to provide me with the appropriate data to make life threatening medical decisions. If radiographers are unlicensed, the integrity and quality time f the images I review will be compromised. Removing the licensure requirements is not a solution to staffing shortages in the profession, but rather presents an unnecessary compromise to patient safety and quality of care. Please consider rejecting this bill.

In reference to HB452 I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing.

In reference to HB452 I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing. Taking away the requirement to be licensed will not make the workforce shortage any better, but in fact greatly increase it over time. If you allow unlicensed techs to enter the workforce they will not receive the training from highly qualified, state licensed techs because of the increase in unlicensed ones coming in for cheaper rates. This will downgrade patient care and services received over time. Would nursing ever consider to have unlicensed nurses flooding the workforce? No, so this profession shouldn't either. Licensure makes sure that radiology professionals are highly qualified to protect patients from unnecessary radiation exposure. Take that away and more patients will end up with cancer and other conditions just like they did when this profession first came about.

I have been an Xray technologist for 20 years. This is a slap in the face for all of us. We go to school, learn about radiological physics, MaS and KvP, safe practice for radiation (ALARA), learn positioning of all body parts and setting techniques for patients of all ages and sizes. So the fact that this bill is even a thing is completely unbelievable and absurd. We all worked hard for our degrees and the fact that the “governor” is basically brushing that off is somethjng I cannot wrap my mind around. Please, squash this bill

As a current xray student, I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing. This bill would put patients at risk by allowing untrained people to use radiation.

I firmly believe everyone needs to be held to the same standard within the radiology side of the medical field. Anyone working within radiology & dealing with radiation needs to be properly certified as a radiology tech technologist. You are jeopardizing proper patient care otherwise & that would be very negligent for you to think otherwise.

In reference to HB452 I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing. Patient safety should always be a priority and never negotiated.

I support the VSRT in opposing bill HB452. This bill will create unsafe practices in the control of radiation exposure to both patients and staff. The residents of Virginia deserve better than this bill allows.

I stand with the VSRT in opposition of HB452 and oppose this bill eliminating licensure. As a Radiologic Technologist for the last 33 years, I do not feel this is the right direction for the future of our profession.

I stand with the VSRT in opposition to this bill, as it raises serious concerns regarding the safety of patients and healthcare professionals involved in the administration of radiation.

No education provides unhealthy practice of radiation.

I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing.

Radiation exposure carries lifelong risks and must be strictly limited to trained and licensed professionals. Safe use requires a foundational understanding of radiation physics, including energy transfer, dose, shielding, time, distance, and biological interaction. These principles cannot be adequately learned through on-the-job training alone and require formal education and structured instruction. Improper exposure can result in permanent, life-altering consequences.

As a Registered Technologist in Radiography, Computed Tomography, Cardiovascular Technology and a practicing Registered Radiologist Assistant, I stand with the Virginia Society of Radiologic Technologist Society statement and oppose the bill which eliminates licensure. Eliminating licensure diminishes years of experience and hard work in perfecting our art and science. Our patients in the Commonwealth deserve the best!

I stand with the VSRT statement and oppose the bill which eliminates licensure.

As a final semester Radiography student, I oppose this bill! The contents of this bill are not only insulting to radiologic technologists, but will prove to have detrimental outcomes for patients. Radiologic technologists go through intense training in topics such as patient care, radiation biology, positioning and anatomy, and radiation physics, as well as complete HUNDREDS of hours of clinical practice to solidify our skills. This bill is essentially saying that our jobs are not necessary and do not matter. We do not just "push a button". We must use critical thinking skills in cases where a patient may be limited physically or mentally, and sometimes we must find creative ways of getting the same "textbook image" if a patient is injured. That is not something just anyone can do, especially if they have not received the proper training. What we do as a profession is VITAL to the health and safety of patients. A healthcare worker who is not trained in our specialty would have no clue how to get a good quality picture without sacrificing the patient's safety. It is proven that radiation in large doses can cause cancer. Radiologic technologists are meticulously trained to understand how radiation affects cells and the human body and learn how to safely administer radiation for medical imaging or therapeutic purposes. If a nurse, doctor, physician's assistant, or any other healthcare specialist is ordered to "push a button," they will have no idea how to do it safely while still providing quality images for radiologists. Part of a radiologic technologist's training is centered around understanding a patient's radiation dose and learning how to keep it as low as possible. A couple of guaranteed outcomes will be observed if this bill passes. First, diagnostic images will severely lack in quality, which could potentially cause a delay in diagnosis or a misdiagnosis. Furthermore, there will be an increase in cancers, particularly in patients who are younger. This bill will only prove to hurt the ones we are trying to heal.

See position statement attached

I support the Virginia Society of Radiologic Technologists position statement in opposition to HB 452. As a second year student I have come to learn the importance of having the proper schooling to perform our jobs effectively and efficiently. This means that we greatly go into depth on how to safely do our jobs in consideration for ourselves, patients, and other healthcare workers we work alongside. Allowing someone to “push a button”, takes everything we have learned for granted and puts many at risk. We understand there is a shortage, however, forcing two years of education into simple classes does not do our patients, us, and our Radiologists justice.

As a Radiologic Technologist, I support the VSRT position statement and oppose the bill HB452 eliminating licensure, as licensing is essential to patient safety and professional standards.

As a second year X-Ray student, I would never want to allow anyone that doesn’t have proper licensure and education regarding radiological technology and radiation safety to examine me. This would negatively affect healthcare significantly as it is important for radiological technologists to be able to safely get the best images possible for patient diagnosis. Patients should be the number one priority, and this would only hurt them. Radiologic technologists were required licensure and proper training for a reason, every single one of them have worked hard for their credentials and making the mistake of passing a bill like this would undermine the integrity of the radiology profession.

I support the Virginia Society of Radiologic Technologists position statement in opposition to HB 452. I appreciate that the bill seeks to address healthcare workforce shortages, however, it raises concerns regarding patient safety, professional integrity, and public transparency. These issues could be more effectively addressed through balanced solutions such as streamlining the licensure process and addressing the underlying causes of radiologic technologist workforce shortages.

To take away licensure in our state is to do great harm to the residents and patients in our hospitals and medical facilities. A licensure is needed to ensure correct protections are maintained for the patient and technologists who perform these exams. We are trained and licensed for a reason: we must protect our patients while irradiating them, giving them correct instructions for diagnostic quality images, and make sure pertinent anatomy is showing. Untrained employees should never be allowed to do this because it will create more issues in diagnosing, radiation protection for the patient, and possibly create further misuse or misdiagnosis. We do not allow people legally to drive a car without a license; how much more should we expect from someone who exposing people to radiation to have a license. It is a necessary and vital part of our job to maintain and keep a license not only to protect our patients but to ensure that our job quality remains high, meaning that our images are the best not just images that can be done by anyone. We do over 1500 hours of clinical just to become the best technologists that we can, not just anyone can do this. It requires a lot of background in anatomy, patient care, and radiation safety. If we were to take away this licensure we would be doing a disservice not only to the patients but to every technologist who has come before to maintain patient safety. It is critical that we maintain a license for radiologic technologists, to protect the people that we serve and you serve as well.

I oppose this bill as a Healthcare Professional

Radiologic technologists have worked diligently for many years to be seen as a capable, and competent profession that is deserving of recognition, and licensure for the hard work and effort we put into our studies. Simply for the well being of our patients. Allowing just anyone to “push the button” degrades who we are as a profession, everything we’ve worked for, and the safety of our patients. Licensure should be kept exactly how it is currently.

I OPPOSE this bill

I oppose this bill. Radiology is not pushing a button. We go to school for years to understand patient positioning , radiation dose, and to make sure we are doing the correct exam needed for the patient. Someone with minimal training is not going to understand this. Repeat studies will go up and so will the dose to patient s. Do you want someone who knows what the are doing or someone who has no idea taking care of your family members

I am currently a final semester radiography student. I do not believe that getting rid of schooling etc. for these positions would do diagnostic imaging or patients justice. As a radiographer you need the knowledge and experience school provides you in order to thrive in this field. This idea is a disgrace to the field.

I oppose this bill. We have licenses for quality care and imaging. Patients welfare is our priority. Qualified radiologic technologists not only train for patient positioning and expertise in operating ionizing radiation equipment, but with experience they alert radiologists to any issues or concerns with imaging. Quality and excellence are our goals, not mediocre imaging

I stand with the VSRT as an imaging professional and a mother that I do NOT trust individuals without a license to be able to use ionizing radiation without a proper education.

As a licensed and registered technologist, I urge you to oppose House Bill 452 (HB 452), which would expand licensure exceptions for individuals practicing radiologic technology, radiologic assisting, and limited radiologic technology within hospitals and affiliated urgent care centers.  I find that this bill would extremely weaken essential professional standards. Under current law, licensure ensures that individuals performing radiologic procedures have met rigorous educational, experiential, and competency requirements established by the Board of Medicine. Essentially, these regulations and licenses protect public health by confirming that practitioners understand how to safely operate radiation-generating equipment, interpret imaging appropriately, and minimize risks to patients and staff.  My key concerns include: 1. Compromising Patient Safety: Radiologic procedures involve ionizing radiation and complex equipment. Unlicensed practice increases the risk of improper imaging, unnecessary radiation exposure, and diagnostic errors — outcomes that our licensure standards are designed to prevent. If you haven’t ever worked with a limited tech, I suggest you do so prior. It will become apparent that there is a large lack of anatomy, positioning and correction factors control. Add to this improper equipment handling and you have a recipe for disaster, all factors that these regulations work to correct! 2. Diminished Public Accountability: Licensure creates a clear pathway for oversight, complaint resolution, and disciplinary action when standards are not met. Expanding exceptions weakens this accountability framework. 3. Undermining Professional Standards: As someone who worked hard to earn my place in this profession, licensing signals minimum competency and ongoing professional development. Removing requirements for certain employees sends the message that some practitioners can operate without comparable benchmarks, which can erode trust in the profession and in Virginia’s health-care system. It’s honestly also a slap in the face to those who worked hard and learned how to protect ourselves and the patients that we serve. I ask that you vote no to this bill and keep the current standards in effect. We all know this is a way for some to “bend the rules” and “blur the lines” which is harmful to our profession as well as our patients.

As a licensed Radiologic Technologist, I stand AGAINST HB452. This proposal, although addressing a valid need in the healthcare field, would do the exact opposite of helping but instead hurting. The attempt at solving a patient's need while also creating a complete disregard for their safety as well as those who would be operating imaging equipment is deranged. The amount of education NEEDED to properly image for DIAGNOSTIC purposes is not something that can be shortened to "fill" empty seats. I am disgusted at the degrading of my career that I worked so hard for by someone who "did some research" and thinks this is the best outcome. I hope that the RT community is heard on how strongly this is opposed. While the need is present, there is a multitude of better options to suggest than lack of licensure and oversee of radiologic imaging.

I OPPOSE this bill. I have been in the medical field for 47 years. I worked very hard to achieve my diploma in Radiologic Technology. It would be disrespectful and dangerous if an unqualified person were to "shoot" an x-ray. There is so much behind what we do as a profession. The anatomy, the correct dosage for a particular body part, the understanding of the positioning to obtain all the information you can. There are so many other reasons to NOT pass this bill.

Vote NO to this bill. Radiation safety is a paramount issue in current health care. With doctors and providers ordering X-ray, CT, and other imaging test at the rate they are, we as the profession of imaging technologists are more important than realized. We fight to make sure that patients aren’t overexposed the best we can following ALARA principles. Being able to maximize ALARA principles is something that takes someone who has had a proper education in the classroom and in the clinical setting. I dare to say that with developing technology, there are some technologists in the profession that are carefree with ALARA. With this in mind we cannot further degrade knowledge and application of ALARA by allowing untrained, unqualified, and frankly sub-standard individuals to be in charge of ionizing radiation. Radiology has been fighting for decades to get recognition for our efforts to the medical field. Without Radiology Technologist, most diagnoses would be half-measures. Bills like this will knock our institution and the work we have done, back the decades we have been scratching and clawing to establish our place in the medical community. Vote NO, help us stand up and fight this bill that can, and most likely will, damage healthcare here in the Commonwealth of Virginia.

I do not approve of non trained personnel and un licensed personnel performing radiology exams. Without proper educational training both initial and continuous education the radiology exams will lack quality and safety needed to perform proper diagnostic images, all of which can be harmful to patients by leading to misdiagnosis and unnecessary exposure to ionizing radiation.

I am writing in opposition of HB452. Having an individual performing radiologic technology exams that has not been properly trained in anatomy, positioning, and radiation physics (at the least) compromises patient safety, image quality & the quality of medical care for the patient. Technologist receive extensive education and clinical training during schooling that the general public does not even realize that we have to go through in order to graduate from x-ray school & be eligible to sit for our board. Without the proper formal training these individuals have no idea how to produce a correctly positioned image nor what technique to use. By not being able to produce a properly positioned image the doctor might not be able to see the anatomy that he is requesting due to poor positioning. That impacts not only patient safety, but also the quality of medical care that the patient could possibly receive. You are not doing these individuals any justice because they will only be able to work in other radiology modality nor be able to further their education because they are not eligible to take any other imaging modality board. In other words no job growth. There is no such thing as a limited respiratory or Ml/MLT technologist license, nor a limited nursing license. In my opinion, there should be no such thing as a limited radiologic technologist license. How would you feel if someone was a limited licensed respiratory therapist that came in to intubate your child? No formal training they’re just there to try to put that breathing tube in your child or family member? Or limited license. ML/MLT come to draw blood gases on your family member? Oh wait they haven’t had any formal training-no anatomy. Do they even know that blood gases are supposed to be drawn from an artery? Do they even know where your radial artery is? How would you feel about that? (Yes there are a large number of radiologic technologist that do procedures that require training in venipuncture) It’s a slap in the face to all of us that graduated from college with. degree in radiologic science & maintain all of our continuing education credits in compliance with state & federal regulations for all of imaging modalities that each technologist has obtained & are registered to preform. Not to mention they are paying limited individuals not much less technologist with 20-30 years of experience. My suggestion is in order to address the lack of qualified radiologic technologist is start with high school guidance counselors. They need material to share about job possibilities in respiratory, lab & all imaging modalities. Medical offices could have an incentive program where if they pay for their current employee to go to an actual accredited x-ray school after graduation & successful passing of board they work for said company for a contracted amount of time. Just a suggestion. Gibson ARRT R.T.(R)(M)(CT)(BD)

Please OPPOSE this bill....

VOTE NO to this bill. Technologists across Virginia and the U.S. have spent YEARS studying this everchanging field. This bill is a direct violation of PATIENT SAFETY and REGULARATORY ACCOUNTABILITY. Those who know anything about this field, understands how important patient safety is and our patient's come first. Additionally, the state of Virginia Medical Board charges the well-educated technologist $300+ to obtain a state license that requires background check, fingerprint, and education documentation from an accredited school, to practice outside of a "hospital umbrella." To be accepted into the accredited program, a criteria must be met. With a short staffed field already, having to supervise and make sure the patient is having the best possible patient care, is NOT helping our field to become stronger. This a direct slap in the face to veteran technologists. Until the one(s) who proposed this bill can tell technologists what the Inverse Square Law and ALARA pertain to, they might want to do some education themselves first.

As an RT, I strongly oppose this bill as should everyone. I can’t imagine there would be any patient who would appreciate an unlicensed person radiating them with no accountability for the dosage being given to the patient. I can remember a time when this was allowed and the undiagnostic quality of images being taken and attempted to be read. Sounds like a horrible idea to go backwards here. Not to mention all of the people who will lose their careers they’ve dedicated their lives to for the improvement of healthcare. Do no harm!

I am very opposed to this bill. It completely discounts the hard work and training current registered radiologic technologists have completed to be in this profession. It would be irresponsible and unsafe to patients for someone without proper education, training, and clinical experience to become a radiologic technologist. This career is ever-growing and changing and allowing someone to jump in without any prior education is ridiculous and unsafe.

No to the HB452 bill

I am not even a healthcare worker and I still do not stand for this bill. I (As should everyone else) want someone who is properly trained to care for me. Does patients safety and proper knowledge for the job not matter? This is HEALTH CARE???

I oppose bill HB452

I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing. This will not help with the shortage. It will put patient safety at risk and reduce the quality of training for Radiology Students.

As a Registered Nurse, I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing.

I am strongly opposed to HB452. Allowing individuals to perform X-ray imaging without proper licensure poses a serious risk to patient safety and the quality of medical care. Radiographic imaging is not simply the act of pressing a button; it requires extensive education and clinical training in anatomy, radiation safety, image evaluation, and precise patient positioning. Even minor errors in positioning can significantly alter an image, obscure critical anatomy, or create artifacts that may lead to missed or incorrect diagnoses. A subtle malposition—mere millimeters—can hide fractures, joint abnormalities, pulmonary findings, or spinal pathology, ultimately delaying treatment or leading to inappropriate clinical decisions. Licensed radiologic professionals are trained to adapt positioning based on patient condition, body habitus, injury, and clinical indication while minimizing radiation exposure. Individuals without this training lack the foundational knowledge to consistently produce diagnostic-quality images or recognize when an image is inadequate and must be repeated. Permitting unlicensed individuals to take X-rays undermines established standards of care, increases the risk of diagnostic error, and places patients at unnecessary risk. Protecting patients requires that radiographic imaging be performed only by properly trained and licensed professionals who are accountable to regulatory and ethical standards

As a registered and licensed Radiologic Technologist for over 20 years, I oppose HB452! A state licensure requires that credentials are maintained at the same high standard the American Registry of Radiologic Technologists holds for technologists. Allowing individuals to perform X-ray imaging without proper licensure poses a serious risk to patient safety and the quality of medical care. I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing.

I have given my life to this field. This is the longing agenda to make professionals non existent. To further pay radiologic technologists less. We care about our patients, we care about using only the amount of radiation required, we have bachelor degrees/ associate degrees that further this passion. The fact that this is even a bill for discussion is despicable. I don’t plan on explaining anything medical to politicians, however we follow the ARRT , ASRT , and VRT . They all say this is a bad idea. So why is this even a bill? If nurses wish to be ARRT certified they can go to a 2 year program , complete clinical, and graduate and practice as a technologist/ nurse. Thank you, RT (R)

I oppose bill HB452. Our jobs may look easy however, we all put in the hard effort of teaching ourselves how to do that. We are considered the eyes of medicine. Our job is to take the best images possible, so we can identify life changing pathology. If we don't center our beam correctly it causes distortion of anatomy, even if we're off by centimeters. If we don't provide the appropriate angle it makes a huge difference. We acquired so much knowledge in school to learn how to give our patients answers. You can easily miss a fracture, spinal pathology, and defects.

I am a licensed and registered radiologic technologist working in an urgent care facility. I have been one for 20 years. I beg you not to take away the licensure requirements for this profession. We learn how to give proper dosages of radiation to patients through lots of college physics. This is not a profession that should have anything less in the requirements. The shortage of radiographers will not be helped by making the standards and requirements less! The public will be in danger from over exposure to radiation through unknowledgeable people or through multiple retakes of images trying to get a good image. These are things a registered and licensed radiographer has learned. Please do not change the standards here! Thank you, Shannon Elixson R.T. (R) (ARRT)

I am strongly opposed to HB452. Allowing individuals to perform X-ray imaging without proper licensure poses a serious risk to patient safety and the quality of medical care. Radiographic imaging is not simply the act of pressing a button; it requires extensive education and clinical training in anatomy, radiation safety, image evaluation, and precise patient positioning. Even minor errors in positioning can significantly alter an image, obscure critical anatomy, or create artifacts that may lead to missed or incorrect diagnoses. A subtle malposition—mere millimeters—can hide fractures, joint abnormalities, pulmonary findings, or spinal pathology, ultimately delaying treatment or leading to inappropriate clinical decisions. Licensed radiologic professionals are trained to adapt positioning based on patient condition, body habitus, injury, and clinical indication while minimizing radiation exposure. Individuals without this training lack the foundational knowledge to consistently produce diagnostic-quality images or recognize when an image is inadequate and must be repeated. Permitting unlicensed individuals to take X-rays undermines established standards of care, increases the risk of diagnostic error, and places patients at unnecessary risk. Protecting patients requires that radiographic imaging be performed only by properly trained and licensed professionals who are accountable to regulatory and ethical standards

I oppose HB 452. This bill lowers professional standards in radiologic imaging and directly compromises patient safety. Radiologic imaging is a regulated medical practice that requires formal education, extensive supervised clinical training, and successful completion of national competency examinations. It is not a task that can be safely performed with minimal instruction. Radiologic technologists are responsible for producing diagnostically accurate images while adhering to strict radiation safety principles designed to minimize patient exposure. Radiation is inherently harmful if misused. Inadequate training increases the risk of improper positioning, repeat imaging, excessive radiation dose, and misdiagnosis. These risks are not theoretical. I have personally observed individuals in urgent care settings, trained through abbreviated courses, attempt to perform radiologic examinations. The resulting images were frequently nondiagnostic, necessitating repeat exams and exposing patients to unnecessary radiation. HB 452 would expand this unsafe practice by permitting individuals without sufficient education or clinical competency to administer ionizing radiation. Rather than weakening standards, the legislature should be strengthening licensure, training, and oversight requirements that exist to protect the public. Patient safety must take precedence over convenience or cost. For these reasons, HB 452 should not be passed.

I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing.

I strongly oppose HB452. Passing this bill would be a serious disservice to both the field of radiology and the patients who rely on properly trained professionals for safe, accurate care. To an outsider, it may appear that we simply “push a button.” What is not seen is the extensive schooling, clinical training, rigorous testing, and countless hours dedicated to mastering this craft. Radiologic imaging is not a task that can be safely performed with minimal instruction. Without appropriate education and oversight, this bill would allow individuals with insufficient training to administer radiation. Radiation exposure carries real risk, and improper technique can result in misdiagnosis, repeat imaging, unnecessary exposure, and harm to patients. I have personally witnessed individuals in urgent care settings complete short courses and then attempt to perform radiologic exams. The resulting images were clinically unacceptable and underscored the dangers of lowering professional standards. This is not a hypothetical concern-it is already happening, and patients are paying the price... We should be strengthening training and safety standards, not weakening them. Patient safety must come first!!

I stand in opposition to this bill. Allowing non-registered individuals to irradiate anyone/anything is dangerous and can be detrimental to patient care across the board. This would hinder the training and forward progress of future technologists. This would cheapen the profession and make it so that seasoned staff would leave facilities offering competitive pay to someone with very little training.

I stand along with Virginia Society of Radiologic Technologists that opposes the elimination of the requirement for Radiologic Technologists licensing. Everyone that is a Radiologic Technologist should be required to have a license to practice their trade. We have gone through extensive training to learn safety and positioning.

I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing. This will not help with the shortage. It will put patient safety at risk.

I agree with the VRST position statement and strongly oppose of the HB452. As a patient, I expect medical imaging to be performed by properly licensed and trained professionals. Weakening licensure requirements increases the risk of errors and puts patient safety at risk. Patients should expect and deserve consistent standards, accountability and confidence in the care we receive.

There are so many reasons why passing this bill will be detrimental to not only the field of radiology but patient care. Letting undereducated and non licensed people come in to take X-rays is extremely dangerous to patients. These people do not understand radiation safety protocols nor the damages overexposure can cause, (genetic effects, cancer, etc.). Radiologic Technologists are the EYES of the entire healthcare field. We are trained and educated on how to take the correct views in order to see the correct anatomy of interest, there is VERY LITTLE room for mistake. One mistake could easily cause a misdiagnosis for the patient. This won’t just have an effect on radiology, this will affect the entire healthcare system. We’re not letting unlicensed people practice as nurses or doctors so why are we trying to allow this with radiologic technologists? This is dangerous and I do NOT stand with this. There are other ways to battle the shortage of radiologic technologists, but this is not the way nor should it ever be considered.

I oppose HB 452 because expanding licensing exceptions for radiologic technologists weakens essential professional standards and patient protections. Removing the requirement for full, state-regulated licensure in certain settings risks allowing individuals with less standardized training and oversight to perform complex imaging procedures. This can lead to increased errors in radiation use, poor image quality, and compromised patient care. Consistent licensing and accountability are critical for ensuring competence, maintaining public trust, and safeguarding patient safety. This bill undermines those safeguards and could negatively impact both the profession and the people we serve.

I highly oppose this bill because removing licensure requirements for any medical professional undermines patient safety, accountability, and the high standards our community expects of our health care system. Licensure exists to ensure that individuals have met rigorous training, competency, and ethical standards before caring for patients. Without these safeguards, we risk: • Compromised quality of care • Increased potential for medical errors • Erosion of public trust in the health care system • Legal and ethical ambiguity regarding scope of practice Rather than reducing essential safeguards, I encourage you to support solutions that expand training pipelines, improve retention of qualified professionals, and invest in workforce development—all while preserving patient protections.

I am a fully licensed Radiologic Technologist (ARRT), I join the Virginia Society of Radiologic Technologists (VSRT) in opposing HB 452. I stand firm that proper schooling, training, and licensure needs to be obtained to do the role of a Radiologic Technologist. There are significant safety issues that can arise if proper schooling and licensure are not obtained. The biggest issue is patient safety; over exposure of radiation. The other major concern is knowing the proper positioning. There are mandatory views that a Radiologic Technologist needs to obtain in order for the Radiologist to diagnose the patient. If you allow anyone to do this job without the proper schooling and licensure you will do a disservice to the patients. You are putting the patients at risk of unnecessary radiation exposure and misdiagnosis from Radiologists.

The "dumbing down" that removal of licensure would cause would severely impact the quality of patient care! It's dangerous and should not even be considered!

We oppose this bill as ARRT, RT.(R) who have rigorous training in radiation safety.

Campbell County Diagnostic imaging is a high-risk, highly specialized area of healthcare that demands comprehensive education, hands-on clinical training, and sound clinical judgment to ensure accurate diagnoses, safe radiation practices, and quality patient care. Assigning these responsibilities to individuals with substantially less training increases the likelihood of imaging errors, unsafe radiation exposure, and diminished patient outcomes. I have seen images in the past taken by untrained, non registered people and they were horrible. No way a doctor should have been using to diagnosis . Please reconsider this. Would you want your family taken care of this way.

The consideration of allowing anyone off the street with no real experience in this nature is purely unfathomable. If I broke a bone or needed any sort of radiology treatment in any regard, I would not want an individual who has had no schooling to get these procedures done. It is unprofessional, anxiety ridden, extremely careless, and inconsiderate of the Virginian citizens. EVERY SINGLE position at a hospital or doctor’s office needs SCHOOLING and LICENSURE, Radiology should follow suit. Why would anyone even think this would be such a grand idea? I’m sure a comeback would be that individuals can keep this career for a long time and would know the procedures like second nature, however that goes against ALL of the students who have been going through all the schooling and trainings in order to become a successful radiology technician, regardless of their position within the field. Not to mention the individuals who already have their schooling and licenses, their hard work and dedication goes unnoticed the SECOND a bill like this would go into effect. It’s disgraceful to the field itself and I can assure you that ALL current and potential radiology students and technicians in the state of Virginia would fight back this bill just as they fought to become a known and fair field to require the need of schooling and licensure. There are schools READY to take on a new course of Radiology and allow these new a prospering individuals help the lives of both the patients and the nursing and doctor staff at each health facilities. This field is growing immensely and you’re going to sit there and tell us that you want individuals who know absolutely nothing about the process, the procedures, the equipment, or anything at all about the anatomy of a human being to take your x-ray the next time you break a bone or need an MRI or a CT scan done to find your life altering cancer or disease or need an ultrasound to make sure your unborn baby has a heartbeat. The Virginian people are at risk if this bill passes. Do NOT let this bill go through.

I stand with the VSRT on this matter! Assigning responsibilities of imaging to individuals with less training & no licensing increases imaging errors, radiation exposure that could be regrettable and misdiagnosis of disease or injury. Please don’t not do this to Radiologic Technologist or to the patients.

I stand along with Virginia Society of Radiologic Technologists that opposes the elimination of the requirement for Radiologic Technologists licensing. Everyone that is a Radiologic Technologist should be required to have a license to practice their trade.

I stand in agreement with the VSRT position statement and oppose the bill 452 which eliminates licensing. This will decrease patient safety by allowing unqualified people to use ionizing radiation which can damage living tissue and DNA. Unqualified individuals lack the necessary training to minimize radiation exposure using principals like ALARA. In the healthcare setting many physicians and departments depend on highly skilled technologists to produce images to help diagnose . There is an increased legal liability by permitting an uncertified ,non licensed individual to perform a regulated medical procedure .I have been in the imaging field for over thirty years and this is a disgrace to the highly skilled and highly qualified professionals! This Bill should be ELIMINATED ……………

I agree with the VSRT position statement and oppose the HB452 which eliminates licensing.

I stand in agreement with the VSRT statement and oppose the elimination of licensure. Why do we need to dumb down everything? I want all of my healthcare professionals to be just that, professional!

I stand with the VSRT and oppose bill HB452. My profession requires proper education, training, and licensure. Me and every tech who came before me has worked hard to get where we are and our career should not be diminished. Lack of proper licensing puts patients at risk and that is not something to be taken lightly.

I am a radiologic technologist and I strongly oppose this bill. Reducing licensure requirements for radiologic technology puts patients at risk and allows untrained individuals to take x-rays. This bill is an insult to me and to any technologist who worked tirelessly through school, clinical training, and certification to earn the RT(R) credential.

As a registered and licensed technologist, I oppose HB452. A state licensure requires that credentials are maintained at the same high standard the American Registry of Radiologic Technologists holds for technologists. I went to school for 2 years and have to prove continuing education and ethical requirements every year. The general public should be able to go into a healthcare facility and trust that all caregivers are educated, trained and properly credentialed to perform duties appropriate to their job role. Scope of practice is part of the integrity of all health professions. We are educated. We are not “button pushers”. Please help maintain the integrity of our profession and do not pass HB452.

I agree with the VSRT position statement and oppose the bill which eliminates licensing.

I support the Virginia Society of Radiologic Technologists (VSRT) and strongly oppose HB 452, which would eliminate licensure for radiologic technologists. Licensure is essential to ensuring patient safety, maintaining professional standards, and protecting the public from unnecessary radiation exposure. Radiologic technologists are highly trained healthcare professionals, and removing licensure undermines the quality of care patients deserve. I stand with VSRT in advocating for strong regulations that prioritize patient safety, accountability, and excellence in medical imaging.

I stand with the VRST

Simple vote = Dissent

I vote….. NO. Absolutely not. This cannot happen. Healthcare cannot turn into this. Health care professionals need to be properly trained and S C H O O L ED. How could this even be considered? This world is getting very scary

Passing this would be a dishonor and disrespect to everyone that EARNED the credentials RT(R). There is so much more to it than “pushing a button”. It takes years of training, studying and dedication to earn the right to work in this profession.

I OPPOSE THIS BILL

HB452 My child is in radiologic technology school and has to pay for education to learn how to do this and now you want to lessen the requirements so any Tom, Dick and Harry can just push a button with no schooling. This is absolutely ridiculous just like the governor!

As the Radiography Program Director at Central Virginia Community College, I stand in support of the VSRT position statement opposing bill HB452. Licensure, as my students could tell you, came about in Virginia as a result of the 1981 congressional act. The Consumer-Patient Radiation Health and Safety Act of 1981 (CPRSA) is a federal law designed to protect the public from unnecessary radiation exposure by setting minimum federal standards for training and certification of individuals performing radiologic procedures and for accrediting training programs, ensuring safe equipment use, and providing model state laws for radiation safety. It requires states to implement these standards, mandating that only certified professionals perform X-rays, thereby reducing risks like cancer from overexposure and ensuring proper equipment maintenance and usage, like shielding and limiting exposure time. Unlicensed persons do not understand these basic concepts. According to the American Registry of Radiologic Technology, more than 75% of states have licensing laws…yet this bill wants to remove ours. With the removal of licensing in the Commonwealth, you will be decreasing patient safety and radiology professionalism by allowing unqualified, undereducated persons to deliver ionizing radiation to patients without understanding consequences, safety precautions, or proper knowledge of equipment and positioning modifications. Your addition of limited radiographers in this bill shows your lack of understanding of our profession and its credentials. The 1981 federal law set about to prevent, as an example, office secretaries from being shown by a doctor how to take an Xray with no knowledge of radiation protection or medical imaging principles. Your bill allows this situation to become reality. In addition, Limited radiographers cannot and do not work in hospitals nor can they be involved in training students, or working with fluoroscopy. This bill eliminates what little didactic and clinical education they now receive. I appreciate this bill was put forward to try to improve workplace shortages. This bill will not accomplish that. It will, however, help to set back this profession by decades in Virginia. I, and others, would be willing to work with the committee to come up with better solutions to address shortages in radiography. Please kill this bill in its current form. Medical safety is important… this bill makes us all less safe.

As a Radiologic Technologist of 30+ years, I think this bill should not be passed. We fought years ago to get licensure for Rad Techs in Va. We are not just button pushers! There is a science to taking x-rays, while keeping patients safe from over exposure.

This is not right. Giving patients a disservice for not being properly educated and trained for something that takes 6 semesters versus someone hiring someone off the streets. I sure hope this bill does not get passed or I would recommend anyone I know and family members to not go to any “doc in the box’s” that allow this kind of thing

As a registered Radiologic Technologist in Diagnostic radiology as well as Mammography, I believe you need well educated technologists who have taken the appropriate classes to do this job. Working with radiation is no joke and needs to be handled by people who understand how this can affect in the human body. Just teaching someone how to position a body part is a small part of the job.

I do NOTTT simply stand for this proposed bill. I stand AGAINST this, easily

I do NOTTT simply stand for this proposed bill. I stand AGAINST this, easily

This bill threatens all we have worked for as Radiologic Technologists. To pass this would illegitamize our profession as a whole. I understand this is in response to helping staff these areas within healthcare, but that can not come at a price for those of us that have worked over 20 plus years in this profession to ensure we are seen as professionals in the healthcare community. Please do not allow this to pass! We urge you to think of the safety and wellbeing of our patients and protect them from harmful radiation at the hands of those less trained to perform such studies. This does not help, but it hurts patients. They deserve the best standards of care and treatment and this bill sends the wrong message to them. Times are difficult, but downgrading a healthcare service does not fix the issue. Instead, focus needs to be placed on this profession as a whole to allow for more training and credentials to ensure that quality care is delivered to patients. I urge you to reconsider this bill, and place it on the back burner so as to find better solutions for the shortages in this field.

This bill is not okay. All of us radiologic technologists went to school for this and are highly trained. Please do not pass this.

I feel it’s imperative that the licensure be mandatory. The education that the radiology techs receive keeps us safe and comfortable during procedures. It concerns me greatly to think it may be someone “trained” in office for this. Who does the training? It will not be done to the degree needed. Thank you for your attention to this.

To most, we’re “button pushers”, and sure if you walked into a room that’s what it may look like, but the education we as radiologic technologists undertake is for the bettering of our healthcare system and the safety of our patients. Radiation exposure is not something that someone needs to just mess around with. I would never try to do the job of a nurse, lawyer, teacher, or any other licensed professional after having only a few lessons on the subject. For the safety of my patients, I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing.

As a Radiologic Technologist, I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing. Trying to combat staffing shortages by eliminating licensure will lead to exposing patients to medical negligence.

I would like to stand against the proposed bill that would allow nurses to assist in performing X-ray procedures. Nurses in all different types of healthcare environments are persistently overworked and overwhelmed with their daily workload. Because of the many tasks demanded from nurses in a given shift, often times tasks such as charting, a crucial part of communication between healthcare professionals , insurance, patients, and billing comes second to the patient in front of them in need of immediate care. To place even more responsibilities on overworked and understaffed nurses would be a careless change to healthcare as the expertise could be better used on the floor, seeing patients. Secondly, radiologic techs undergo extensive, specialized training including radiation safety and radiation physics, and patient protection/occupational exposure that cannot be accurately communicated by an additional course or on-the-job training. Lack of thorough education puts at risk the safety of patients and workers by increasing the procedural errors and potential harm from unnecessary exposure to radiation. Therefore, for the safety of patients and healthcare workers alike, I strongly feel that radiologic imaging should not be extended to nurses, but remain under the care of adequately trained, licensed radiologic professionals.

As a licensed radiologic technologist of 15 years, I oppose HB452 due to concerns of patient safety. Virginia x-ray technicians are licensed healthcare professionals who complete extensive education, clinical training, and certification to safely use radiation. This license and education exists to protect patients. Lowering these standards compromises this safety! This bill devalues our profession, the training and expertise required of licensed technologists.

I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing.*******

As a trained and licensed Radiologic Technologist, I stand in agreement with the VSRT position statement and oppose this bill.

As a student getting ready to graduate a radiology program to become a X Ray tech in virginia, I am very saddened to hear this is even a bill trying to be passed. In no shape or form can/should any nurse have the capability of being able to assist a physician or radiologist or PA in taking x ray’s whether that is in the operating room, fluoroscopy, or diagnostic imaging. We spend 18 months straight learning the ends and outs of patient and workers protection when it comes to radiation that no nurse could be taught in a couple of trainings. No patient will be safe if this bill passes.

I strongly oppose this bill. Lowering education and training standards will not fix the workforce shortage. The shortage exists due to burnout, poor retention, and lack of support—not because standards are too high. Weakening requirements will drive qualified professionals out of the field and make the shortage worse. Radiologic imaging requires extensive training to ensure patient safety. Allowing less-trained individuals to perform these procedures increases the risk of errors, repeat radiation exposure, and misdiagnosis. This bill puts patients at risk and devalues licensed radiographers. The solution is to invest in education, retention, and safe staffing—not to lower standards.

As a Registered Radiologic Technologist through the ARRT for 30 years and also as a Licensed Radiologic Technologist through the State of Virginia, I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing.

I stand with VSRT as a registered technologist with three credentials - accumulating 4+ years of schooling and clinical advancement.

I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing.

Please don’t pass this bill. Would you want someone who has no knowledge of radiation safety, protection or positioning do an X-ray exam on you? I have worked in this profession for thirty-three years. I would want someone with the proper education in radiology technology doing my X-ray exams. Proper use of radiation is a must in healthcare. Letting people with no prior education do X-rays is dangerous to the public.

I oppose House Bill 452 due to its potential to weaken licensure standards and undermine the quality and safety of medical imaging services in Virginia. Radiologic technologists play a critical role in patient care, and any legislation that risks lowering educational or professional requirements threatens patient safety and workforce integrity. I support maintaining strong licensure standards and evidence-based training requirements to protect both patients and the profession

I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing. I have worked in Healthcare as a Respiratory Therapist for 18 years and I would never want someone with no real training in a position to do a job that was not meant for them to do. We all go to school and work hard for the degree we went to school for and that shouldn’t be degraded by allowing someone who has no training to do our jobs. I Love my Rad friends!!

I stand with the VSRT concerning licensure for the practice of radiologic technology. I have worked as a RTRM for over 32 years and have been dedicated to patient care and safety after having proper education and clinical time. Being an xray tech has been fulfilling and our career should not be changed just to fill job positions without licensing!!

As a licensed and certified radiologic technologist and radiography educator, I support the Virginia Society of Radiologic Technologists position statement in opposition to HB 452.

As a student finishing up my degree, the thought of Nurses being allowed to take X-rays after only a few trainings I don’t believe is in the best interest for patients. The knowledge, skill, and ability to properly perform X-rays is not something that can be learned and applied in a short amount of time. Not only does this add on to the heavy workload that nurses are already accustomed to, it opens the possibility to more burnout and stress on the nurses which will result in patients receiving less than optimal care.

As a Radiologic Technologist, I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing.

I am writing to formally oppose the proposed bill that would allow nurses to assist physicians, radiologists, or physician assistants in performing X-ray procedures. In no circumstance should nurses be permitted to assist in taking X-rays in the operating room, fluoroscopy, or diagnostic imaging. Radiologic technologists undergo extensive, specialized education often 18 months or more of focused training dedicated specifically to radiation physics, radiation safety, patient protection, and occupational exposure. This depth of training cannot be adequately replaced by a brief course or limited on-the-job instruction. Radiation use carries inherent risks, and improper handling or lack of thorough understanding directly impacts patient safety as well as the safety of healthcare workers. Allowing individuals without comprehensive radiologic education to participate in these procedures increases the likelihood of unnecessary exposure, procedural errors, and long-term harm. For these reasons, I strongly believe that patient safety would be in major risk if this bill were to pass. Radiologic imaging should remain the responsibility of properly trained and licensed radiologic professionals.

In reference to HB452 I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing. Patient safety should always be a priority and never negotiated.

Patient care and safety should be of the utmost importance! This will not help with the shortage. It will only put patients at risk.

I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing. This will only hurt the profession and inhibit patient safety.

I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing. A radiology technologist has been through the proper education and training necessary to aid in finding and diagnosing imperative medical conditions. Without this, several things will be missed or overlooked.

I have been a radiologic technologist for 26 years and I as long as my colleagues worked hard for our certification and work hard in this field every day. To allow others without proper qualifications to do our job is a huge disservice to our profession as well as our patients. I strongly oppose this bill.

In my opinion, this is a slap in the face to everyone who worked incredibly hard to master radiology and put in the work. I disagree with this bill wholeheartedly.

As a retired Radiologic Technologist and Mammographer, I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing.

I am an ARRT Licensed Radiologic Technologist of 34 years, who teaches a Limited X-ray Tech Program at Carilion Clinic. We work very hard to get these students to the certification process. Prior to our current program, our clinic used an online program with very little success. Most of them failed. Our current Limited X-ray tech program is 9 weeks of in class learning basic math, basic radiation physics, radiation protection, x- ray positioning and patient care. They then have to pass clinical competencies and be certified before they are able to take an x-ray exposure alone. The entire process takes approx 8 months. Why must they wait to make an exposure on a patient you ask? It is the risk of too much radiation exposure to the patient. We are to do no harm to our patients. It terrifies me to think we are opening that door again to allow just anyone to xray a patient. Much research has been done on the effects of excessive radiation exposure so I will not bring it up here. But, I urge you to think of patient safety first. Would you allow just anyone with no certification or license xray your mom, dad or child? I urge you in the interest of patient safety to throw this bill out. Thank you.

We worked hard to get the credentials that represent us and did it with pride. Allowing others to do the same job we worked hard for is disgraceful in the name of medicine.

Terrible idea to allow untrained, unqualified personnel operate radiographic/X-ray equipment. They should be properly trained via a specialized advanced training program or school. Would be a disservice to the general public and their safety with regards to ionizing radiation.

In reference to HB452 I stand in agreement with the VSRT position statement and oppose the bill which eliminates licensing.

As a licensed Radiologic Technologist, I strongly oppose HB 452. Allowing individuals with limited licensure or significantly reduced training to independently perform medical imaging puts patient safety at risk and undermines the standards that protect the public. Diagnostic imaging is not a low risk task. It requires extensive education, supervised clinical training, and a strong understanding of anatomy, pathology, radiation physics, and radiation protection. Fully credentialed Radiologic Technologists are trained to ensure diagnostic image quality while minimizing radiation exposure and preventing repeat exams that unnecessarily increase patient dose. Lowering these standards increases the risk of diagnostic errors, improper radiation use, and compromised patient outcomes. Virginia has long upheld strong licensure requirements to ensure that medical imaging is performed safely and competently. Creating a two tier imaging workforce weakens professional accountability, devalues the expertise of fully licensed technologists, and erodes public trust in a critical area of healthcare. Workforce shortages should not be addressed by reducing licensure and training standards. Patient safety must remain the priority. I urge the committee to oppose HB 452 and maintain Virginia’s established standards for radiologic technology practice.

This degrades our profession. We worked hard to be able to do X-ray and imaging

I have been in Radiology as a Radiologic Technologist and a Ultrasonographer for almost 40 years. It is a insult to the profession to think that it is ok to give someone the ability to administrator radiation to someone with no training and education in that field. Would you want this done to you or a family member. I thought as Healthcare providers we put patients first, that means providing safe imaging that means providing quality images, safe exposure and excellent patient care. If this bill passes, what a disservice to patients and a insult to me and all my colleagues that have worked so hard for the education and credentials that we have.

Allowing limited-license Radiologic Technologists to independently perform medical imaging raises serious patient safety and quality-of-care concerns. Diagnostic imaging requires extensive education, clinical training, and judgment to ensure accurate results and safe radiation use; reducing these standards increases the risk of errors and unnecessary exposure. Creating a two-tier imaging workforce also weakens accountability, undermines established licensure standards, and risks eroding public trust in a critical area of healthcare

I am employed at a private practice as a radiographer. We need to keep the state licensing as well as the national certification. I support the VSRT decision and oppose this bill .

Diagnostic imaging is a high-risk, highly specialized area of healthcare that demands comprehensive education, hands-on clinical training, and sound clinical judgment to ensure accurate diagnoses, safe radiation practices, and quality patient care. Assigning these responsibilities to individuals with substantially less training increases the likelihood of imaging errors, unsafe radiation exposure, and diminished patient outcomes.

Please reconsider this bill. This is definitely unsafe for patients and takes away all the progress that has been made for our profession. The Radiologic Technology profession is far more than “pushing a button”. The radiation exposure and protection safety of each patient is a learned skill. History provides many instances of radiation harm before education was established. For the health of your mothers, daughters, sons, fathers and all family members, leave this PROFESSIONAL ORGANIZATION to the PROFESSIONALS!

These changes are absolutely ridiculous. We fight constantly to be listened to by doctors with very little knowledge of radiation safety; as we spendt years studying to understand what is safe for our patients. We have earned our licensure and live it every single day we go to work.

Allowing limited-license Radiologic Technologists to independently perform medical imaging does not serve the best interests of patients or the profession. Diagnostic imaging is a complex, high-risk component of healthcare that requires extensive education, clinical training, and critical judgment to ensure accurate results, radiation safety, and appropriate patient care. Expanding imaging responsibilities to individuals with significantly reduced training increases the risk of diagnostic errors, improper radiation exposure, and compromised patient outcomes. From a professional standpoint, this approach undermines established standards of practice and devalues the expertise of fully credentialed Radiologic Technologists who have met rigorous educational and licensure requirements. It creates a two-tier system that weakens professional accountability and erodes public trust in medical imaging.

As a retired Radiologic Tecnologist and Radiologic Technology Educator, I join the Virginia Society of Radiologic Technologists (VSRT) in opposing HB 452. I support requiring all individuals in Virginia who administer ionizing radiation in the practice of patient care, to be registered by the American Registry of Radiologic Technologists and to be licensed by the state of Virginia as appropriate.

I am speaking on behalf of HB452. As a graduating senior and future radiologic technologist, I find it very important to require state licensure in Virginia to practice in medical imaging. Yes, there are states that do practice this; however, that is not the standard the Commonwealth upholds. As a future resident this coming May, I find it very important for me and others to practice in a state that requires a state radiography license. By taking that privilege away from us, it discredits us all as imaging professionals. There are many shortages in the healthcare field, and that is ok, but it is important to protect all that we have worked for in our respective radiography and radiation therapy programs.

Comments Document

The Virginia Society of Radiologic Technologists (VSRT) opposes HB 452 (Radiologic Personnel Licensure Exemptions). Please find our official position statement attached to this submission.

The Virginia Alliance for Animal Shelters represents 300 shelter personnel and animal control officers across the Commonwealth. While we appreciate the patron's interest in the matter of veterinarians of record for shelters, this bill will not assist shelters in alleviating that deficit. Every shelter must already have a vet of record listed ,so putting a checkbox on a license application does not expand the pool. Those familiar with shelters know that the problem is that many shelters do not have the financial resources to pay a veterinarian for more than a name which permits the shelter to perform euthanasia. If the outside organization which suggested the bill wants to help shelters, then providing funding to under resourced shelters so actually services can be provided to animals is the genuine answer. Sharon Quilllen Adams, VAAS

The Virginia Association for Home Care and Hospice opposes this bill.

The Virginia Association for Home Care and Hospice opposes this legislation.

My name is Theresa Gaffney, PhD, MPA, RN, CNE. I am a nursing professor and serve as the Commissioner for Nursing Education for the Virginia Nurses Association. I am writing today in strong support of House Bill (HB) 815. Virginia currently lacks a consistent, comprehensive lens through which to understand and plan for its nursing workforce. As a result, the Commonwealth is perpetually in a reactive posture—constantly playing catch-up as workforce gaps deepen. Projections indicate that Virginia will face a shortage of more than 20,000 registered nurses in the coming years, compounded by serious maldistribution challenges, both geographically and across care settings. At the same time, national data show that 30 to 50 percent of newly licensed nurses leave the profession within their first two years. This level of attrition threatens not only workforce stability, but the health and safety of Virginians who rely on timely access to quality care. To meet the healthcare needs of every resident, Virginia must shift from a reactive approach to a proactive, data-driven strategy—one that aligns nursing education capacity with workforce demand. The Nursing Workforce Center established in HB 815 provides exactly that: a centralized hub to collect, analyze, and act on workforce data. This infrastructure is essential to building and sustaining a stable, well-prepared, and resilient nursing workforce. For these reasons, I respectfully urge your support of House Bill 815. Thank you for your time and consideration.

I am a Doctor of Acupuncture and licensed by the state of Virginia as well as Nationally board-certified. I strongly oppose HB841 allowing Athletic Trainers to use dry needling to their scope of practice. This would bypass measures integral to maintaining patient safety and proper oversight in the medical field. Dry Needling is an Aggressive Acupuncture Technique The opinion that dry needling is not acupuncture is incorrect. While the term “dry needling” is a western term and translation, the technique is clearly described in many ancient acupuncture texts dating back thousands of years. It is a technique that is taught in every acupuncture school and routinely utilized when treating patients with musculoskeletal concerns. That said, dry needling is a very aggressive acupuncture technique and is often not the best choice for a patient. Dry needling generally uses acupuncture needles that are much thicker than ones used in other acupuncture techniques. When dry needling, sometimes it is necessary to use very long needles (4”) and go through layers of muscles and navigate around vital organs. This is a very delicate procedure and carries a risk of side effects including local and systemic infection, organ puncture, excessive bruising and bleeding, fainting, dizziness, nausea, reduction in energy and the inability to participate in activities of daily living. A properly trained and licensed acupuncturist has the knowledge to avoid and reduce these risks. Athletic trainers would only have this needling technique at their disposal (which they learn in an inadequately short course) and the likelihood of applying this invasive procedure to patients for whom it is contraindicated, is very high. We are already beginning to hear reports of athletes and other patients being harmed by dry needling at the hands of trainers. Inadequate Training & Oversight Acupuncturists are required to undergo a minimum of over 2000 hours of training including almost 700 hours of clinical training directly involving needles. Acupuncturists are required to pass rigorous national (and in some cases state) board exams and have very strict oversight and continuing education requirements. Medical Doctors who perform dry needling and other acupuncture techniques have to undergo 300 hours of training in addition to their medical school education. Allowing a short course in an invasive acupuncture technique to be deemed adequate training is dangerous and poses a grave risk to public safety The American Medical Association’s Policy H-410.949: Dry Needling is an Invasive Procedure The American Medical Association has a policy on dry needling and recognizes the invasive nature of this acupuncture technique. “Our AMA recognizes dry needling as an invasive procedure and maintains that dry needling should only be performed by practitioners with standard training and familiarity with routine use of needles in their practice, such as licensed medical physicians and licensed acupuncturists.” https://policysearch.ama-assn.org/policyfinder/detail/dry%20needling?uri=%2FAMADoc%2FHOD-410.949.xml The current training and regulations in place for Athletic Trainers does not provide the proper education or oversight for this invasive treatment. This bill undermines medical safety, erodes public trust and endangers patient health while offering little in return.

Dear Honorable Delegates, Please consider my opposition to HB841, which would add dry needling (DN) to the scope of Athletic Trainers. I am speaking as a Doctor of Acupuncture and Oriental Medicine, licensed in Virginia (2022) and California (2003), Board Certified in Acupuncture Orthopedics (2006), Certified Myofascial Trigger Point Therapist (DN--gold standard for Physical Therapists, 2017), Diplomate and Continuing Education Provider for the National Certification Board for Acupuncture and Herbal Medicine (NCBAHM, 2021), founder of the Sports Acupuncture Clinic (2003). I have also served continuously since 2005 as a Professor at the Masters, Doctoral, and Continuing Education levels for 4 nationally-accredited colleges and universities of acupuncture, including the Virginia University of Integrative Medicine, on topics including sports and orthopedic acupuncture, professional ethics and risk management, dry/trigger point needling, and clinical safety, as a guest speaker for the RAMP Program (acupuncture training for US Air Force Physicians), and as a Guest Editor in Sports Acupuncture for Medical Acupuncture. I am also speaking as a professional who has served as an Expert Witness on over 30 civil and criminal medical malpractice and regulatory board investigation cases involving injuries resulting from dry needling and acupuncture performed by Physical Therapists, Physicians, and Licensed Acupuncturists. My professional experience also includes serving as an Athletic Training Assistant and Physical Therapy Aide. I have worked in Physician-lead orthopedics and pain management clinics, and in my current clinical practice at the Sports Acupuncture Clinic of Charlottesville, I treat many primary school, college, and professional athletes. I thus oppose adding DN to the scope of any additional professions unless it includes training requirements comparable to those required for licensure in acupuncture: 4-year Masters or First Professional Doctorate degree, and passage of a rigorous examination covering safety, competence and ethics, such as is administered by the NCBAHM: There is no public necessity to add dry needling to the scope of practice for Athletic Trainers. This modality is already widely available in Virginia through the services of over 500 Licensed Acupuncturists, as well as Physical Therapists and Physicians. Under-trained, under-regulated and unexamined providers present a high risk to public health and safety. Witness a pneumothorax (collapsed lung) injury suffered in 2025 by Pro Football player TJ Watt from dry needling. I have personally served as a consultant in litigation and regulatory investigations on 8 pneumothorax injuries caused by dry needling (including 1 death, and several resulting in permanent loss of lung function), as well as injuries to the brain stem and peripheral nerves resulting from dry needling. Even a cursory search of high-quality, peer-reviewed published case reports and literature reviews documents the risks of needling, that are thoroughly documented by the Clean Needle Technique Manual, Council of Colleges of Acupuncture and Herbal Medicine and available on public databases such as the NIH’s PubMed. For these reasons, I strongly oppose HB 841. Thank you for your consideration of my experience and recommendations. Sincerely, Anthony Von der Muhll, LAc, DAOM, DNBAO, FAIPM

If you need any further proof of the dangers of allowing non-acupuncture professionals to dry needle after just 50 to 100 hours of training (versus our minimum of 1,905 hours to practice), look no further than the recent emergency surgery that Pittsburgh Steeler's TJ Watt had to undergo on December 10, 2025 for a pneumothorax induced by an AT/PT for the Steeler's. From an ESPN article on Dec 12, 2025 : "Steelers inside linebacker Patrick Queen said he prefers to utilize acupuncture. 'Kind of two different things,' Queen said of the practices. 'One [acupuncture], you got to go to school for a longer period of time. There's a whole much more scientific thing that goes into it.'....Queen said the extra education required to administer acupuncture is why he uses it." That's directly from the mouth of the type of person who would be treated by an AT. Stop legislating legal loop holes around the current requirements for needling! These loop holes for AT's and PT's create life threatening circumstances for unwitting clients who don't understand the difference in training required amongst these professionals.

Athletic trainers have neither the background nor training to put needles into people. The practice of acupuncture, from which this "dry needling" nonsense has derived, is a precise and exquisite medical intervention. It is now being plundered by ignorant people just looking to cash in on the latest thing. Real harm can come from "dry needling" if the person does not have the proper training and licensure. Do not pass this bill, please

I am a licensed acupuncturist and a doctor of acupuncture and Chinese medicine licensed and practicing for 26 years. I am shocked and concerned to learn that athletic trainers are requesting to have dry needling in their scope of practice. Dry needling can be a hazard to public safety if done by unskilled providers. It can cause organ injury and even death by pneumothorax. This is not a technique that should be allowed for people with minimal medical training. I strongly recommend the committee not allow dry needling in the scope of practice of athletic trainers who may have minimal training in high-level anatomy and minimal needling training. Acupuncturists are trained in a four year professional (post graduate) training in order to be able to perform skills such as dry needling. Please for public safety reasons deny this request. - Tamara Brown, Licensed Acupuncturist, Doctor of Acupuncture and Chinese Medicine Licensed in Virginia and California

The ASVA asks that legislators do not advance SB728/HB841 as written. We believe that it’s important to keep invasive needling within professions that meet medical-level standards. At the very least, we request a formal safety review with Board of Medicine representatives, licensed acupuncturists, and other medical experts where training hours and competencies are considered. Dry Needling Is an Invasive Medical Procedure Dry needlining is not superficial. It penetrates muscle, fascia, and tissue near vital structures. Calling it “dry needling” does not change the anatomy, risk, or medical reality - it is acupuncture by another name. Training Standards Are Not Comparable Licensed acupuncturists in Virginia complete 1,900-3,000 hours of post- graduate clinical training. Includes anatomy, internal organ mapping, sterile technique, depth and angle of insertion, and hundreds of supervised treatments. Athletic trainers do not receive equivalent invasive-needle training as part of licensure. Proposed “certifications” may be as little as a weekend course. Risks Improper needling can cause: Collapsed lung (pneumothorax) Nerve damage Infection Vascular injury and bleeding Legal & Regulatory Conflicts The Board of Medicine recently reviewed this issue brought forth via petition, and voted to take no action, concluding that dry needling does not fall within the statutory scope of athletic training (§54.1-2900). Virginia regulations classify dry needling as an advanced invasive procedure, rather than an entry-level skill, requiring post-graduate training. Existing regulations, specifically 18VAC112-20-121, mandate that such procedures require rigorous post-graduate training, including didactic and hands-on laboratory education. SB728/HB841 bypasses those standards and weakens existing medical safeguards. Consumer Protection & Informed Consent Patients cannot tell the difference between: A provider with thousands of hours of needle training A provider with a short certification SB728/HB841 allows the same invasive act to be performed under dramatically different standards - undermining informed consent and public trust. Virginians deserve to know that invasive procedures meet consistent safety standards. Legal and Liability Risk Lower training thresholds increase malpractice exposure, weakens the standard of care, and places the Commonwealth in the position of defending preventable injuries The Commonwealth may be asked why it allowed invasive medical procedures without medical-level education. This bill lowers the bar for what constitutes negligence.

As a mom, I oppose this bill. This is not safe for our children who are being cared for by athletic trainers. As written, there are no education requirements for Dry Needling education in Virginia. Dry Needling is an invasive needle procedure using Acupuncture needles. As we all recently saw in December 2025 with TJ Watt, outside linebacker for the Pittsburg Steelers, dry Needling can cause life threatening conditions. His pneumothorax (lunch collapse) was caused by a well trained professional. Please require specific education requirements for Dry Needling, consumer education about dry Needling versus acupuncture, and supervision of ATs by people who have been trained in this modality before this bill is passed. Thank you.

It is disturbing and disheartening to read that a VCU nurse thinks it’s okay to hurt people like law enforcement officers like because they are abiding by the laws and/or have different political views. President Obama was a big supporter of ICE.

Good morning, Unconscious bias is a human condition (Mihal Emberton, 2021). Not one of us, no matter how loving, kind, empathetic, educated, and self-aware we are, isn’t impacted by our biases. Bias doesn’t make us bad, it makes us human. But, what separates humans from the rest of the animal world is our ability to reason and expand our consciousness. Understanding our biases, then, becomes a way to create a more loving, kind, and equitable society. An important part of our society is our healthcare workers, specifically our nurses. Nurses are the heart of healthcare, saving lives every day with skill, compassion, and unwavering dedication. Bias reduction training is essential for nurses because it directly affects the quality, safety, and equity of patient care. Nurses interact with patients from diverse backgrounds every day, often in high-pressure environments where quick judgments are required. Without awareness, unconscious biases related to race, gender, age, disability, or socioeconomic status can influence clinical decisions, communication, and levels of empathy, leading to unequal care outcomes. Through bias reduction training, nurses learn to recognize their own implicit assumptions and understand how these biases can shape behavior. This awareness promotes more objective clinical reasoning and encourages respectful, patient-centered communication. When nurses are trained to pause, reflect, and question their assumptions, they are better equipped to provide care that is based on evidence rather than stereotypes. Bias reduction training also strengthens trust between nurses and patients. Patients who feel seen, heard, and respected are more likely to share accurate health information, follow treatment plans, and engage in their care. In healthcare settings where disparities persist, fostering this trust is especially critical for improving outcomes among marginalized populations. Ultimately, bias reduction training supports ethical nursing practice and advances health equity. By cultivating cultural humility and self-reflection, nurses can help create a healthcare environment where all patients receive fair, compassionate, and high-quality care. I believe supporting HB1147 will directly empower Virginia’s outstanding nurse workforce to be the best it can be. Nurses sit right at the intersection of healthcare and everyday life—nurses don’t stop being nurses when they leave work. Bias-reduction skills like perspective-taking and inclusive communication often carry into families, schools, and communities, providing Virginia with an even stronger social cohesion and commitment to human rights-values.

The attached letter is on behalf of March of Dimes in support of HB 1147. We provide comments in support of the bill as well as recommendations to support sustainable and effective implementation.

To the Members of the Committee: I am a Certified Nurse Midwife and the Inaugural Board Chair for the National Black Midwives Alliance. I am writing in strong support of House Bill 1147, which would require the Virginia Board of Medicine and the Board of Nursing to mandate continuing education in bias reduction for certain healthcare licensees. As a Certified Nurse-Midwife providing maternal healthcare for twenty years, I see daily how bias in clinical settings directly affects pregnancy, birth, and postpartum outcomes. Studies show that implicit bias affects how clinicians interpret symptoms, assess pain, and engage with patients who may not fit the clinician’s own cultural or racial background—ultimately undermining trust and quality of care. These dynamics persist even when access to care exists. Virginia continues to face unacceptable racial disparities in maternal morbidity and mortality, with Black women and birthing people experiencing significantly higher rates of severe complications and preventable deaths. These disparities persist regardless of education or income, pointing to systemic bias within healthcare delivery as a critical contributor. Bias reduction education is an evidence-based, patient-safety intervention. Requiring this training as part of licensure supports clinical excellence, strengthens provider-patient relationships, and improves decision-making during high-risk and time-sensitive maternal health events. Continuing education is already a professional expectation; HB 1147 complements clinical competence with the relational and ethical skills needed to truly improve maternal outcomes — especially for women of color who experience disproportionate risk. This bill is not punitive—it is preventive. It affirms that improving maternal outcomes requires both clinical competence and ongoing self-reflection. House Bill 1147 is a necessary step toward safer births, healthier families, and a more accountable healthcare system in Virginia. I respectfully urge you to support House Bill 1147 as a necessary step toward reducing racial disparities, especially in maternal health, by strengthening trust between clinicians and communities, and fulfilling Virginia’s commitment to equitable, life-affirming care for all families.

My name is Karen Kelly, and I am the president of The Virginia Affiliate of the American College of Nurse-Midwives. I’m writing to voice support of implementation of the bias reduction continuing education requirements This policy appropriately recognizes bias in health care as a system-wide issue and establishes shared responsibility among maternal health clinicians regulated by the Boards of Nursing and Medicine. Implicit and structural bias, particularly racial bias, continues to affect clinical decision-making during pregnancy and the postpartum period and contributes to persistent disparities in maternal and neonatal outcomes. Requiring evidence-based bias reduction training as part of license renewal is a reasonable and necessary mechanism to promote individualized clinical assessment and reduce reliance on race-based assumptions. VA ACNM believes this policy supports Virginia’s broader efforts to reduce preventable maternal morbidity and mortality and eliminate disparities in care. We urge full implementation and continued collaboration to ensure these requirements result in measurable improvements in maternal and neonatal health across the Commonwealth.

As a physician, we are taught and take an oath to do no harm. We pledge to be advocates for our patients. Sadly as physicians, health care providers we are taught to accept and beliefs that are untrue simply because of an unconscious bias that we all carry and often times are unaware that we posses. Asking us to take a moment to reflect on what we may believe true and not true will allow us to identify where we can improve in the care of patients. Without reflection there is no growth And without growth we cannot improve.

Good morning Senators, Delegates, and members of the subcommittee, thank you for the opportunity to provide testimony today. My name is Dr. Jamela M. Martin, Associate Professor and Chair of Nursing and Allied Health at Norfolk State University. I am here today to speak in support of House Bill No 1147, which directs the Virginia Board of Medicine and the Virginia Board of Nursing to require bias reduction training as part of existing continuing education and continuing competency requirements. In 2020, I spoke on Virginia Humanities’ show “With Good Reason” about health inequities and the need for targeted policy action in the Commonwealth. I understand that conversation resonated with Senator Head and helped bring attention to the need for policy action in this area. I testify today not only as a healthcare professional, but as a patient whose mismanaged care in Virginia resulted in permanent blindness in my left eye at age 42. This legislation represents a full-circle moment—where lived experience, evidence, and policy intersect. I appreciate the bipartisan support for this bill, particularly because its focus is ultimately about saving lives. Bias reduction training should be understood as an expected professional competency—no different in purpose than annual training on ethics, patient safety, or infection control—because it shapes clinical judgment, communication, and decision-making. This bill directly advances priorities already embedded in Virginia’s licensure framework- Patient Safety, Quality of Care, and Workforce Standards-each supported by clear evidence. Bias in healthcare is not a matter of technical skill. It influences how symptoms are interpreted and how clinical decisions are made— areas that patient safety data consistently link to adverse events. High-quality care requires clinicians to deliver consistent, evidence-informed care across all patient populations. Differences in communication and clinical interpretation—not access alone—contribute to measurable differences in outcomes, even among similarly insured patients. Patient trust and adherence—two of the strongest predictors of clinical outcomes—rise or fall based on whether patients feel heard and understood during care encounters. Finally, this bill does not create undue hardship for practitioners. It modernizes existing continuing education requirements to reflect the current evidence on a factor that directly affects safety, quality, and professional performance. House Bill 1147 strengthens Virginia’s licensure framework by aligning continuing competency requirements with what the evidence tells us about safe, high-quality care. I strongly urge the subcommittee to support its passage.

My name is Teresita Hammond. I am a nurse in Virginia, and I am writing in support of HB1147. I once cared for a pregnant patient who was in recovery from substance use. She had done the hard work. She was attending treatment, staying sober, and preparing to bring her baby home. But instead of feeling supported, she felt judged. She told me she felt watched, whispered about, and assumed to be an unfit mother before anyone took the time to hear her story. She worried constantly that one wrong word, one misunderstood moment, or one biased assumption could cost her the chance to take her baby home. That fear shaped her entire hospital experience. She hesitated to ask questions. She downplayed her pain. She felt like she had to prove she deserved compassion. This is what implicit bias looks like in real life. It is not always loud or intentional. Sometimes it shows up in tone, body language, rushed decisions, or assumptions about who is “responsible” or “trustworthy.” But the impact is heavy. It affects trust. It affects care. It affects outcomes. And it affects families at their most vulnerable moments. Implicit bias training is not about blame. It is about awareness. It gives professionals the tools to pause, reflect, and treat every patient with dignity, fairness, and respect. It helps ensure that recovery is seen as strength, not suspicion, and that motherhood is not judged through the lens of stigma. Patients should feel safe, not shamed. Supported, not stereotyped. Heard, not dismissed. HB1147 is an important step toward more equitable, compassionate, and accountable care in Virginia. I urge you to support this bill. Thank you for your time and consideration.

See attached

On behalf of the NAACP, we support HB 1147 as an important step toward advancing health equity in the Commonwealth. The bill helps address systemic barriers that contribute to health disparities and promotes fair, equitable access to health-related resources and protections for all Virginians.

This topic is already covered in medical school and most physician ACGME and AOA residency programs in their curriculum. Is there excellent evidence that the proposed implicit bias curriculum effective? Is the proponent of this bill have a bias? Do we need to be piling on more on overworked physicians?

It is disturbing and disheartening to read that a VCU nurse thinks it’s okay to hurt people like law enforcement officers like because they are abiding by the laws and/or have different political views. President Obama was a big supporter of ICE.

It is important for physicians and nurses to receive training on bias reduction if we are to effectively address discrepancies in the provision of healthcare due to implicit bias. Most immediately this will help address discrepancies in maternal morbidity and mortality linked to pregnancy. Black women continue to have increased morbidity and mortality linked to pregnancy. While many factors contribute to this increased mortality, physicians and nurses can have an immediate impact by addressing implicit bias in the provision of healthcare.

As a member of the PUSH coalition, Voices for Virginia's Children supports this bill to better address disparities in maternal health. -Liz Nigro, Voices for Virginia's Children

I write in strong support of HB 1357, which directs the Virginia Department for Aging and Rehabilitative Services to conduct a comprehensive study of nursing facilities across the Commonwealth. This legislation is both timely and necessary to ensure that our seniors and individuals with disabilities receive care that is safe, dignified, and centered on their well-being. Nursing facilities serve some of Virginia’s most vulnerable residents. Families entrust these institutions with the care of their loved ones, often during the most fragile stages of life. HB 1357 acknowledges this responsibility by calling for a thorough review of quality of care, resident safety, staffing, and operational practices. A comprehensive study paired with the formation of a knowledgeable work group -creates an opportunity to identify gaps, highlight best practices, and recommend meaningful improvements grounded in real data and lived experiences. This legislation also reflects a commitment to accountability and transparency. By requiring a formal report, HB 1357 ensures that findings are shared with policymakers, advocates, and the public, fostering informed decision-making and long-term systemic improvements. It moves the Commonwealth beyond reactive responses toward proactive oversight and continuous quality improvement. Importantly, HB 1357 brings multiple stakeholders to the table, recognizing that improving nursing facility care requires collaboration among providers, regulators, advocates, residents, and families. This inclusive approach strengthens trust and encourages solutions that are practical, compassionate, and sustainable. Virginia’s aging population is growing, and with it comes an increased demand for high-quality long-term care. HB 1357 positions the Commonwealth to meet this demand responsibly by examining what is working, what is not, and how we can do better. Supporting this bill is a clear statement that Virginia values the safety, dignity, and quality of life of its older adults and individuals receiving rehabilitative services. For these reasons, I urge support for HB 1357 and commend the General Assembly for prioritizing the care and protection of some of our most vulnerable residents.

I write in strong support of HB 1357, which directs the Virginia Department for Aging and Rehabilitative Services to conduct a comprehensive study of nursing facilities across the Commonwealth. This legislation is both timely and necessary to ensure that our seniors and individuals with disabilities receive care that is safe, dignified, and centered on their well-being. Nursing facilities serve some of Virginia’s most vulnerable residents. Families entrust these institutions with the care of their loved ones, often during the most fragile stages of life. HB 1357 acknowledges this responsibility by calling for a thorough review of quality of care, resident safety, staffing, and operational practices. A comprehensive study paired with the formation of a knowledgeable work group -creates an opportunity to identify gaps, highlight best practices, and recommend meaningful improvements grounded in real data and lived experiences. This legislation also reflects a commitment to accountability and transparency. By requiring a formal report, HB 1357 ensures that findings are shared with policymakers, advocates, and the public, fostering informed decision-making and long-term systemic improvements. It moves the Commonwealth beyond reactive responses toward proactive oversight and continuous quality improvement. Importantly, HB 1357 brings multiple stakeholders to the table, recognizing that improving nursing facility care requires collaboration among providers, regulators, advocates, residents, and families. This inclusive approach strengthens trust and encourages solutions that are practical, compassionate, and sustainable. Virginia’s aging population is growing, and with it comes an increased demand for high-quality long-term care. HB 1357 positions the Commonwealth to meet this demand responsibly by examining what is working, what is not, and how we can do better. Supporting this bill is a clear statement that Virginia values the safety, dignity, and quality of life of its older adults and individuals receiving rehabilitative services. For these reasons, I urge support for HB 1357 and commend the General Assembly for prioritizing the care and protection of some of our most vulnerable residents.