May 2022 Conventional Report

This report shares short summary highlights of tracked legislative bills and rules & regulations that have seen activity in May 2022, as well as available board and state VMA updates.

The Table of Contents below is your clickable guide through this conventional monthly report. To see the report sorted by jurisdiction for a quick view, please visit May 2022 Updates by Jurisdiction.

Table of Contents

1. Legislative Activity

Note: Filtered into sections by bill status, then listed by bill topic in alphabetical order.

There are 14 passed bills, 8 introduced bills, 8 cross-overs, 1 hearing, 1 amendment, and 15 dead bills.

1.1 Passed

There are 14 passed bills.

Companion Insurance

ME LD482: An insurer transacting pet insurance shall disclose to consumers: 

A. Whether the policy excludes coverage due to any of the following: (1) A preexisting condition; (2) A hereditary disorder; (3) A congenital anomaly or disorder; or (4) A chronic condition;

B. Whether the policy includes any other exclusions and, if so, add the following statement: “Other exclusions may apply. Please refer to the exclusions section of the policy for more information.”;

C. Any policy provision that limits coverage through a waiting period or affiliation period, a deductible, coinsurance, or an annual or lifetime policy limit;

D. Whether the insurer reduces coverage or increases premiums based on the insured’s claim history, the age of the covered pet, or a change in the geographic location of the insured; and

E. Whether the underwriting company differs from the brand name used to market and sell the product.

Opioid and Opioid Antagonists

CT HB5430 adds transporting language to the controlled substances/PMP statute. 

TN HB2228: When prescribing an opioid to a patient, a healthcare prescriber shall offer a prescription for naloxone hydrochloride, or another drug approved by the FDA for the complete or partial reversal of an opioid overdose event, to the patient when one (1) or more of the following conditions are present in accordance with the federal centers for disease control and prevention opioid prescribing guidelines setting forth treatment of a known or suspected opioid overdose: (A) The prescription dosage for the patient is fifty (50) or more morphine milligram equivalents of an opioid medication per day; (B) An opioid medication is prescribed concurrently with a prescription for benzodiazepine; (C) The patient presents with an increased risk for overdose, including a history of overdose, a history of substance use disorder, or being at risk for returning to a high dose of opioid medication to which the patient is no longer tolerant; or (D) The patient is at high risk of witnessing an opioid overdose event because the individual resides or spends time with an individual who is prescribed an opioid, misuses an opioid, or has an opioid use disorder. 


ME LD1995 establishes one state veterinarian position in the bureau of agriculture program and provides funding for related all other costs associated with the position in the bureau of agriculture and office of the commissioner programs to assist with live animal risk assessment and management on farms impacted by perfluoroalkyl and polyfluoroalkyl substances, or pfas. 


CO HB1115 changes PMP query from second fill to every fill of opioids and benzos. Adds that on and after July 1, 2024, as a condition of renewal of a license, each veterinarian shall attest that the veterinarian is in compliance with section 12-280-403 (2)(a) (PMP registration) and that the veterinarian is aware of the penalties for non-compliance with that section. (Same requirement for pharmacists.)  

CO SB27 requires each licensed healthcare practitioner to query the prescription drug monitoring program prior to filling a prescription for every opioid or benzodiazepine instead of every second fill. Stipulates that only licensed practitioners with a DEA registration must register. Veterinarians are still not required to query; it is voluntary. 

State Appropriations

MO HB3006 transfers $120,000 to the department of agriculture. Funds are to be transferred out of the state treasury to the veterinary student loan payment fund from the lottery proceeds fund, $180,000 to the department of agriculture for large animal veterinary student loans in accordance with the provisions of sections 340.375 to 340.396, RSMo from veterinary student loan payment fund.

MO HB3007 transfers $109,601 to the department of commerce and insurance for the Missouri Veterinary Medical Board from veterinary medical board fund. For expense and equipment, $59,001. For payment of fees for testing services, $50,000.  

State Board Issues

KS HB2087 limits the review of certain rules and regulations by the director of the budget and requires review of rules and regulations every 5 years for each state agency. 

KY HB271: The state veterinarian shall be an agent of the board, shall enforce the administrative regulations of the board “pertaining to livestock, poultry, and fish” and, under the direction of the board, shall supervise and control the action of all deputies, inspectors, agents, and specialists within the office of the state veterinarian. He or she shall devote his or her entire time to the duties of the office. He or she shall recommend from time to time such changes in the administrative regulations of the board, as he or she deems necessary, and do all other things necessary and proper for the successful enforcement of this chapter. 

Veterinary – Immunity

LA HB842 provides liability for veterinary professionals for the reporting of animal cruelty. 

Veterinary – Microchipping

AZ HB2626 requires vet clinics to scan for microchips and make efforts to contact owners. 

Veterinary – Telemedicine

HI SB2798 reconciled differences and passed with physical exam requirement. Provides a temp license for veterinarians, as well.  

House amended it to extend the effective date to 2025 to allow for further discussion. Now moves to the conference.  

Allows for telemedicine. Defines telemedicine, teleadvice, teleconsulting, telesupervising, teletriage, and VCPR. Appears it would require a physical exam based on the definition of telemedicine. Only a board-licensed veterinarian may provide telemedicine to a patient located in the State.  

Creates a courtesy and relief permit for veterinarians. Both require a sponsor, the relief sponsor does not need to be in Hawaii. Courtesy is valid for 60 days; the relief for 30 but can be renewed once for 60 days total. The sponsor must notify the board. Other requirements. 

Adopted amendments make the following changes: 

1) Amends the VCPR definition to state:  

“‘Veterinarian-client-patient relationship’ means a relationship that exists when: 

  1. The veterinarian and client agree for the veterinarian to assume responsibility for making medical judgments regarding the health of the animal patient;
  2. The veterinarian has sufficient knowledge of the animal patient to initiate a general or preliminary diagnosis of the medical condition of the animal patient, which means that the veterinarian is personally acquainted with the keeping and care of the animal patient and has recently physically examined the animal or made timely and medically appropriate visits to the premises where the animal patient is kept;
  3. The veterinarian is readily available or provides for follow-up care and treatment in case of adverse reactions or failure of the therapy regimen; and
  4. The veterinarian maintains records that document animal patient visits, consultations, diagnosis and treatment, and other relevant information required under this chapter.” 

2) Removes the original bill’s definition of “veterinary teleconsulting”

VT H655 creates a new license for OOS practitioners who want to practice telemedicine, limited to 20 customers per 2-year period, can still get fully licensed under the current statutes.

1.2 Introduced

There are 8 introduced bills.


NY A10097/NY S08847 relates to establishing an office of antibiotic-resistance control; establishes the antibiotics education fund; includes methicillin-resistant staphylococcus aureus (MRSA) and other antibiotic-resistant infections in the definition of airborne infectious disease. 

Occupational Licensing

DE HB404: Fresh Start Act – The Delaware Fair Chance Licensing Act provides that it is the policy of this State to allow entry to professions and occupations with licensing requirements for individuals with a criminal history to the maximum extent consistent with public safety. To that end, the bill identifies certain kinds of criminal history elements that should not be considered by licensing boards: charges that are not pending and did not lead to a conviction; juvenile records; records that have been expunged, sealed, or pardoned; and convictions that are more than 10 years old. An exception is allowed to the 10-year rule to preserve existing prohibitions involving sex offense convictions. The Act also identifies factors a licensing authority should consider in determining whether a criminal history record would prohibit licensure, or whether a waiver should be granted. 

State Appropriations

AZ HB281 appropriates $601,800 to the Arizona State Veterinary Medical Examining Board. 

State Boards

DE HB425 adds 2 members to the Lyme Disease Oversight Board, including an infectious disease epidemiologist and a licensed veterinarian or entomology specialist. 

Veterinary - Licensing

MA H4745 Changes veterinary license renewal from an annual license renewed every March to a biennial license renewed every January. This bill replaces H3775. 

Veterinary - Loan Programs/ Shortages

DE HB403: The Delaware Institute of Veterinary Medicine financially supports Delaware residents who attend veterinary medical schools out of state since Delaware does not have an in-state veterinary medical school. There is currently no requirement that the recipients of financial assistance in this program practice veterinary medicine in Delaware and Delaware is facing a shortage of licensed veterinarians. This Act requires recipients of this financial assistance upon graduation to practice veterinary medicine in Delaware for a minimum of 2 years. 

Veterinary – Telemedicine

NJ S2464 clarifies that veterinarians are not within the ambit of telemedicine and telehealth law. 

1.3 Crossed Over

8 bills have crossed over. 


NY A10147 replaces the terms “alien” and “illegal alien” with the terms “noncitizen” and “undocumented non-citizen” – includes the veterinary board. 

Non-Economic Damages

DE SB258 defines “compensatory damages” and sets a total cap of $30,000, $15,000 for veterinary care, $15,000 for emotional loss. There is no veterinary exemption. 


SC H3998 adds schedule V to the PMP requirements. Veterinarians included.

State Board Issues

AZ HB2599 places extensive restrictions on state boards including:

Sec. 2.
H. Before any regulating entity takes any official action to deny a professional or occupational license that a person applies for pursuant to this section, the regulating entity shall submit the application and the reason for denial to the governor for review. The regulating entity shall notify the governor of any required time frames for approval or denial of the license application by the regulating entity.

I. Beginning July 1, 2022, all regulating entities that are required to issue occupational or professional licenses pursuant to this section shall track information about applications received in the format to be determined by the governor and annually report that information to the governor.

Sec. 3.
A. A regulating entity that issues occupational or professional licenses shall:

    1. Prominently post on its website home page all current state policies that ease licensing burdens and the exact steps applicants must complete to receive their license using such policies. policies that ease licensing burdens include the following:
      (a) Universal recognition of out-of-state licenses.
      (b) Availability of temporary licenses.
      (c) Fee waivers.
      (d) Examination exemptions.
      (e) allowing an applicant to substitute military education or experience for licensing requirements.
Sec. 8.

A. Notwithstanding any other law, a state agency may not conduct any rulemaking, including regular, expedited, informal, formal, emergency, or exempt rulemaking, without prior written approval of the governor. In seeking approval, a state agency shall address any of the following as justification for the rulemaking: 


  2. REDUCING or ameliorating a regulatory burden on the public, while achieving the same regulatory objective.
  3. Preventing a significant threat to public health, peace or safety.
  4. Avoiding violating a court order or federal law that would result in sanctions by a federal court for failure to conduct the rulemaking action.
  5. Complying with a new state statutory or regulatory requirement if the compliance is related to a condition for the receiving federal monies or participating in any federal program.
  6. Complying with a new or existing state statutory requirement.
  7. Fulfilling an obligation related to fees or any other action necessary to implement the state budget that is certified by the governor’s office of strategic planning and budgeting.
  8. adopting a rule or other item that is exempt from this chapter.
  9. Matters pertaining to the control, mitigation or eradication of waste, fraud or abuse within a state agency or wasteful, fraudulent or abusive activities perpetrated against a state agency.
  10. Eliminating rules that are antiquated, redundant or otherwise no longer necessary for the operation of state government.

Sec. 8.
C. Notwithstanding any other law, a state agency that submits a rulemaking request shall recommend for consideration by the governor at least three existing rules to eliminate for every additional rule requested by the state agency. the requirements of this subsection do not apply to rules that are necessary to secure or maintain assumption of federal regulatory programs, rules that are necessary to comply with an auditor general recommendation or rules that are necessary to address a new statutory requirement.

D. A state agency may not publicize any directives, policy statements, documents or forms on its website unless the directive, policy statement, document or form is authorized by statute or rule. a state agency shall remove material not authorized by statute or rule from its website on the effective date of this section. 

Veterinary - Technician Licensing and Regulation

CO HB1235: Sunset bill. The most significant change concerns veterinary technician licensing and regulation. 

Veterinary - Loan Programs/Shortages

OK SB776 changes the existing rural vet training program/repayment from three to five awards and removes current large animal veterinarians, restricting it only to students. Maintains preference for students focusing on large animals. This encourages students to locate their practices, upon graduation, in a rural part of the state. 

Veterinary – Prescriptions

NY A04978 requires veterinarians to provide certain information to animal owners regarding the drugs dispensed to an animal, including the name and description of the drug; the directions for use; actions to be taken in the event of a missed dose; instructions for proper storage; any common reasonably anticipated adverse effects associated with the use of such drug; and manufacturer precautions and relevant warnings. 

Veterinary – Vaccinations

DE SB228: Bill was amended to require veterinary technicians to be under indirect supervision and the animal must be owned by a shelter.  

Adds cats and ferrets to the rabies vaccination requirement. Allows veterinary technicians to administer vaccines. 

1.4 Amendments

There is 1 amendment


DE HB333 was amended. The amendment replaces the definition of “therapeutic purpose” with a more specific definition of “therapeutic purpose” in reference to the bill’s exception for declawing a cat. 

1.5 Hearings

There is 1 hearing.

Veterinary - Cannabis

CA AB1885 requires the Veterinary Board to adopt guidelines by 01/01/24, or veterinarians to follow when recommending cannabis within the veterinarian-client-patient relationship and would require the board to post the guidelines on its internet website. Heard 05/19/22.

1.6 Dead

There are 15 dead bills.

Non-Economic Damages

MD HB965 increases the cap for tortious death of a pet, not including livestock, from $10,000 to $25,000. 

MD HB1375 adds noneconomic damages to the statutes for tortious injury/death of an animal and provides for an exception to the $10,000 cap for “(Ii) subparagraph (i) of this paragraph does not apply if the tortfeasor acted with gross negligence, intent, or malice or in violation of the Maryland declaration of rights.”  

MD SB815 establishes that a person who tortiously causes an injury to or death of a pet may be liable to the owner of the pet for noneconomic damages; establishing an exception to the cap on compensatory and non-economic damages for a tortfeasor who acted with gross negligence, intent, or malice or in violation of the Maryland Declaration of Rights. 

State Appropriations

SD HB1338 appropriates $59,577 to the Board of Veterinary Medical Examiners

MD HB300 State board of veterinary medical examiners special fund appropriation of $818,555. 

State Board Issues

GA HB702 amends the statute so home addresses of licensees are treated as confidential.   

GA SB604: Administrative bill making the state veterinary board an independent agency attached to the Department of Agriculture. 

KS SB34 requires each state agency, the veterinary board included, to report on their rules and regulations every 5 years. 

Veterinary – Chiro/Massage

ID H0641 amends existing law to provide for indirect supervision and offering of services to allied health professionals. A chiropractic allied health professional shall be permitted to represent oneself through offerings, advertisements, and use of professional titles and designations if the following conditions are met: (i) The professional is certified by the American veterinary chiropractic association or the international veterinary chiropractic association; (ii) The professional is in good standing with the state board of chiropractic physicians and any other board that oversees chiropractic medicine through which the professional is licensed; and (iii) The advertisements and offerings are limited to services the professional is permitted to perform under this chapter and within the scope of the professional’s certification. 

Veterinary – Loan Programs

ID S1344 adds to existing law to establish a loan repayment program for rural veterinarians who treat large animals.  

ID S1380 creates a rural veterinarian loan repayment program. 

Veterinary – Reciprocity/Mobility

GA HB68/HB147: A professional licensing board or other board shall issue a license by endorsement to any individual that: (1) Moves from another state and establishes residency in this state; (2) Holds a current, similar license to practice such occupation or profession issued by another state  (3) Is in good standing; and (4) Passes any examination that may only be required to demonstrate knowledge of the laws and rules and regulations of this state-specific to the practice of the profession. 

GA SB45: Military spouse- A professional licensing board or other board shall issue a license by endorsement to any individual that: (1) Moves from another state and establishes residency in this state; (2) Holds a current, similar license to practice such occupation or profession issued by another state  (3) Is in good standing; and (4) Passes any examination that may only be required to demonstrate knowledge of the laws and rules and regulations of this state-specific to the practice of the profession. 

Veterinary - Vaccinations

GA HB1000 allows vets to exempt animals from rabies vaccine and allows the use of titer to exempt the animal indefinitely.   

(b) “If a licensed veterinarian determines in writing that a rabies inoculation would compromise an animal’s health, then the animal shall be exempt from the rabies vaccination requirement until such time as a licensed veterinarian determines that such inoculation would not compromise such animal’s health. If a rabies inoculation is shown through the results of a vaccine titer to be medically unnecessary for said animal, then the animal shall be exempt from the rabies vaccination requirement indefinitely.” 

2. Rules & Regulations Activity

Rules and Regulation changes that have been filed to take effect.

PROCEDURAL RULES OF THE COMMISSION AND THE DEPARTMENT 16 TAC §§60.501, 60.510, 60.512, 60.514, 60.518, 60.519 

The Texas Commission of Licensing and Regulation (Commission) adopts amendments to existing rules at 16 Texas Administrative Code (TAC), Chapter 60, Subchapter K, §§60.501, 60.510, 60.512, 60.514 and 60.518, and the proposed new rule at Subchapter K, §60.519, regarding the Procedural Rules of the Commission and the Department, without changes to the proposed text as published in the January 28, 2022, issue of the Texas Register (47 TexReg 224). These rules will not be republished.  


The proposed rules under 16 TAC, Chapter 60, Subchapter K, implement Texas Occupations Code, Chapter 51, General Provisions Related to Licensing, and Chapter 55, Licensing of Military Service Members, Military Veterans, and Military Spouses. 

The proposed rules are necessary to implement House Bill (HB) 139, 87th Legislature, Regular Session (2021) by updating current definitions in Chapter 55, Occupations Code, and provide for a mandated procedure in rule to allow a non-resident military spouse to obtain license eligibility for occupational licenses that have an in-state residency prerequisite; and to update and remove obsolete references to past bills no longer needed in the current rule subchapter due to subsequent redesignations and reenactments that corrected duplicative statutes passed over the years in separate bills. 

Effective June 8, 2022, WV licensed or registered veterinarians will be allowed to offer telehealth.  

(a) For purposes of this section, these terms have the following meaning:  

  1. “Interstate telehealth services” means the provision of telehealth services to a patient located in West Virginia by a registered veterinary care professional located in any other state or commonwealth of the United States.

  2. “Personal examination” is a face-to-face, in-person, examination of the patient.

  3. “Registration” means an authorization to practice veterinary medicine in the State of West Virginia pursuant to §30-10-1 et seq. of this code, which authorization is limited to providing interstate telehealth services within the registrant’s scope of practice.

  4. “Registrant” means an individual who holds a valid registration with the board.

  5. “Telehealth services” means the use of synchronous or asynchronous telecommunications technology or audio only telephone calls by a veterinary care professional to provide veterinary care services, including, but not limited to, assessment, diagnosis, consultation, treatment, and monitoring of a patient; maintenance of medical data; patient and professional health-related education; public health services; and health administration. The term does not include internet questionnaires, email messages, or facsimile transmissions.

  6. Veterinary care professional means the official authorization by the board to engage in the practice of veterinary medicine.  

(b) Telehealth Practice.  

  1. The practice of veterinary medicine occurs where the patient is located at the time telehealth services are provided.


  2. To provide veterinary care in the State of West Virginia via interstate telehealth services, an individual not otherwise licensed by the board must first apply for and obtain registration with the board using the application materials provided by the board and paying a fee of $300.


  3. To obtain registration with the board, an individual must be a licensed veterinarian in good standing in all other states in which he or she is licensed and not currently under investigation or subject to an administrative complaint.

  4. A registration with the board is subject to annual renewal on or before December 31 including, but not limited to, the renewal fee of $250 and the submission of at least three patient records of West Virginia patients, if applicable.


  5. A veterinarian-client-patient relationship is required for providing veterinary care in the State of West Virginia via telehealth services. The veterinary care professional shall perform an in-person exam within the 12 months prior, and at least every 12 months thereafter or the telehealth service shall no longer be available to the patient. Such relationship exists when:

    A) A veterinarian assumes responsibility for medical judgments regarding the health of an animal and the client who is the owner or owner’s advocate of the animal consents to the veterinarian’s treatment plan, and

    B) A veterinarian, through personal examination of an animal or a representative sample of a herd or flock, obtains sufficient information to make at least a general or preliminary diagnosis of the medical condition of the animal, herd or flock, which diagnosis is expanded through medically appropriate visits to the premises where the animal, herd or flock is kept.  

    C) In the event of an imminent, life-threatening emergency veterinary care may be provided in this State via telehealth services without an existing veterinarian-client- patient relationship or without an in-person visit within 12 months.

  6. The standard of care for providing veterinary care in the State of West Virginia via telehealth services by a registrant or licensed veterinarian shall be the same as for in-person care. Such standard of care shall require that a veterinarian-client-patient relationship first exist before telehealth services are provided and that a patient visit a veterinarian licensed in another jurisdiction or licensed by the board, in-person and within 12 months of using the initial telemedicine service, or the telemedicine service shall no longer be available to the patient. Only in the event of an imminent, life-threatening emergency may veterinary care be provided in this state via telehealth services without an existing veterinarian-client-patient relationship or without an in-person visit within 12 months.


  7. A provider of telehealth services must ensure that the client is aware of the veterinarian’s identity, location, and license number and licensure status and should provide to the client a clear mechanism to:

    A) Access, supplement, and amend client-provided contact information and health information about the patient;

    B) Register complaints with the board;

    C) Provide consent for the use of telemedicine and, 

    D) Patient medical records must meet the requirements as specified in the Standard of Practice Rules.

  8. A registrant shall not prescribe any controlled substance listed in Schedule II of the Uniform Controlled Substance Act via interstate telehealth services.

  9. By registering to provide interstate telehealth services to patients in this state, a registrant is subject to:

    A. The laws, rules, and regulations regarding the practice of veterinary medicine in this state, including the state judicial system and all rules and standards of professional conduct contained within §30-10-1 et seq. of this code and the rules promulgated thereunder; and  

    B. The standard of care for providing veterinary care in the State of West Virginia via telehealth services by a registrant or licensed veterinarian shall be the same as for in-person care. and

    C) The jurisdiction of the board, including, but not limited to, the board’s complaint, investigation, and hearing processes. 

  10. A registrant shall notify the board within 30 days of any restrictions placed upon, or actions taken against, his or her license to practice in any other state or jurisdiction.

  11. Registration with the board does not authorize a veterinary care professional to practice from a physical location within the State of West Virginia without first obtaining appropriate facility registration.

  12. A person currently licensed by the board is not subject to registration but shall practice telehealth in accordance with the provisions of §30-10-1 et seq. and the rules promulgated thereunder.  

3. Board Watch

Update: Euthanasia Drug Supply
May 6, 2022

On March 10, 2022, Health Canada posted this update to its “Recall and Safety Alerts” webpage regarding forecasted availability of euthanasia drugs in Canada following the previously-announced anticipated shortage of pentobarbital sodium.

At their May meeting, the Delaware Board of Veterinary Medicine informed that the following emergency order, which extended the VCPR from 12 to 18 months at the start of the pandemic, is no longer in effect: Statement from the Delaware Board of Veterinary Medicine Re: Covid-19 Emergency Order extending VPCR to 18 months. 

The Administrative Rules Review Committee voted for a 70-day delay relating to the Valid Veterinarian/Client/Patient Relationship regarding concerns expressed about pork producers being provided with large quantities of medications without a prescription or an adequate valid veterinarian/client/patient relationship, or without involvement of a veterinarian at all. The Board and the stakeholders are working together for a mutual agreement. The status of the effective date of the rule was April 1, 2022, and the new effective date will be June 10, 2022.

Policy, Procedure, and Rules 

2022-A  ~  NAVLE Waiver, VTNE Waiver, & RVT State Jurisprudence Requirement was rolled into Regulatory Proposal 2022-01  

Public Hearing scheduled for May 26, 2022 at 9:30 am 

Amends Rule 303 regarding the satisfactory requirements for the waiver of retaking the national examination, allowing greater discretion by the Board in examining the work history of the applicant to determine whether a five-year period of full-time employment has been maintained. Additionally, amends Rule 803 to create consistency among the board’s two largest licensing groups in providing applicants for RVT licensure a possible waiver for retaking the national examination if the score is older than three years. This will also strike the practical state board examination requirement for applicants for RVT licensure and allow the board to administer the written state board examination as required by statute. 

Board discussion of possible need to amend language of NAVLE waiver; No vote. 
[Source: Meeting Minutes – 12-10-20] 

Rule amendments discussed at Board meeting; No vote.  

Continued discussion of rule amendments at Board meeting; No vote. 
[Source: Meeting Minutes – 10-14-21] 

Final discussion of NAVLE waiver language; Discussion of necessity for VTNE waiver language and amendments to give a viable pathway for state jurisprudence exam for RVTs; Legal Counsel instructed to draft proposed amendment to be presented to Board at its 02-03-22 meeting. 
[Source: Meeting Minutes – 12-02-21] 

Board approved proposed rule amendment for promulgation.
[Source: Meeting Minutes – 02-03-22] 

Incorporated into 
Regulatory Project 2022-01. 

2022-01  ~  LAC 46LXXXV.303.803 – NAVLE Waiver, VTNE Waiver, & RVT State Jurisprudence Requirement  [Source: Regulatory Proposal 2022-A] 

  • 02-23-2022     Proposed rule submitted to Occupational Licensing Review Commission (OLRC). 
  • 03-10-2022     OLRC approved the continuation of promulgation process. 
  • 04-08-2022     Legislative Fiscal Office approved fiscal and economic impact statement. 
  • 04-08-2022     First Report submitted to Joint Legislative Oversight Committee on Agriculture, Forestry, Aquaculture, and Rural Development. 
  • 04-13-2022     Distributed electronic Notice of Rulemaking Activity. 
  • 04-20-2022     Notice of Intent(with revisions) scheduled for publication in 2022 Louisiana Register, Volume 48, April Edition. 
  • 05-10-2022     Deadline for submission of written comments to Board.*See instructions for submitting comments in Notice of Intent. 
  • 05-13-2022     Notice and Agenda of Public Hearing distributed electronically 
  • 05-26-2022     Public Hearing scheduled for May 26, 2022 at 9:30am 

Timing for VCPRReverts to 12 Monthson July 1, 2022 

As the pandemic subsides, the Board’s extension of time allowed for a valid veterinarian-client-patient relationship will cease as of July 1, 2022. Once again, a valid VCPR will require a physical examination or visit to the premises within the preceding 12 months. Please contact the Board with any questions. 

Board of Veterinary Medicine Proposed Rules:  

Vet 400 various Continued Status 

Public Hearing:  Wednesday, June 15, 2022, at 9:00 AM in the Hearing Room at the OPLC offices at 7 Eagle Square, Concord NH 

**You do not need to attend the hearing to submit written comments.** 

Deadline for Submitting Written Comment:  Monday, June 27, 2022, at 4:00 pm. Please submit comments to 

2022-88 Vet 400 – Continued Status (full text): 
The intended action of adopting Vet 400, expired 1/28/20, is to re-establish rules about renewal of licenses, continuing education, disciplinary actions and outcomes, unauthorized practice, continuing education, continuing education audit procedures, responsibility for the action of veterinary nurse technicians, and assistants, and reinstatement of expired license procedures.  

Vet 500 various    Registration or Licensing Requirements 

Public Hearing:  Wednesday, June 15, 2022, at 9:00 AM in the Hearing Room at the OPLC offices at 7 Eagle Square, Concord NH. 

**You do not need to attend the hearing to submit written comments.** 

Deadline for Submitting Written Comment:  Monday, June 27, 2022, at 4:00 pm. 
Please submit comments to 

2022-90 Vet 500 (Various) – Ethical Standards (full text): 
Vet 501.01 incorporates by reference and requires compliance with the “Principles of Veterinary Medical Ethics of the AVMA” and is being readopted with an amendment to change the revision date to the most current document and to clarify that the license is required to adhere to the ethics except when the Vet rules have a stricter requirement.  

Vet 501.03 and Vet 501.04 are being adopted to set requirements regarding any veterinarian identifying himself or herself as a specialist and the use of a designation of specialty in the naming of a facility.  

PART Vet 502 heading “Emergency Coverage” is being changed to “Emergency Coverage and After Hours Care”  

Vet 502.01 describes emergency coverage and is being readopted with amendment to clarify the availability of a veterinarian for follow-up evaluation, emergency coverage, continuing care and treatment, and the disclosure of customary business hours.  

Vet 502.02 is being adopted to set requirements for after-hours care requiring the licensed veterinarians to disclose to the client the level of care the patient will have at any time the patient is on the premises including for overnight hospitalizations.  

Vet 503 is being adopted to set the requirements for euthanasia requiring the veterinarian to comply with the AVMA Guidelines for the Euthanasia of Animals: 2020 Edition except where Bet rules have a stricter requirement.  

Vet 600 various    Registration or Licensing Requirements 

Public Hearing:  Wednesday, June 15, 2022, at 9:00 AM in the Hearing Room at the OPLC offices at 7 Eagle Square, Concord NH. 

**You do not need to attend the hearing to submit written comments.** 

Deadline for Submitting Written Comment:  Monday, June 27, 2022, at 4:00 pm. 
Please submit comments to 

2022-89 Vet 600 (Various) – Practice of Veterinary Medicine (full text): 
Vet 601 is being adopted after having expired on 1/28/20 to define the term acupuncture and describe acupuncture use in veterinary medicine as the application and technique of  
acupuncture is performed on an animal as part of the practice of veterinary medicine.  

Vet 602 is being adopted after having expired on 1/28/20 and is being adopted to describe embryo transfers on animals as the practice of veterinary medicine and shall be performed only by persons authorized to practice under RSA 332-B.  

Vet 603 is being adopted to define the telemedicine performed on an animal(s) located in the State of NH. The telemedicine services are only authorized by a provider holding a NH veterinary license. The rule further defines when and how the services may be provided by the NH licensed veterinarian.  


Office of Professional Licensure and Certification – Proposed Regulation 

Plc 1002 – Application-Related Fees Specific to Each Profession 

Plc 1002.44 Application Fees for Professions Regulated by the Board of Veterinary Medicine. The following application processing fees shall apply to the professions regulated by the board of veterinary medicine under RSA 332-B:  

Table 1002.44 Application Fees for Professions Regulated by the Board of Veterinary Medicine  

Application processing: initial, renewal, or reinstatement of veterinarian 2 years $155 license  

Public Hearing:  Thursday, May 26, 2022, at 1:30 PM in the Board Room at the OPLC offices at 7 Eagle Square, Concord NH 

  • Plc 1002.44 Application Fees for Professions Regulated by the Board of Veterinary Medicine. The following application processing fees shall apply to the professions regulated by the board of veterinary medicine under RSA 332-B: Table 1002.44 Application Fees for Professions Regulated by the Board of Veterinary Medicine Application processing: initial, renewal, or reinstatement of veterinarian 2 years $155 license   

**You do not need to attend the hearing to submit written comments.** 

Deadline for Submitting Written Comment:  4:00 PM on Friday, June 10, 2022 
Please submit comments to 

Nevada State Board of Veterinary Medical Examiners has proposed a regulation relating to veterinary medicine; interpreting the term “physical examination” for the purposes of provisions relating to the establishment of a veterinarian-client-patient relationship; increasing certain fees relating to licenses, registrations, and permits issued by the Nevada State Board of Veterinary Medical Examiners in accordance with newly established biennial licensing and registration periods; providing for the reduction of such fees in certain circumstances; establishing biennial registration periods for a permit to operate a veterinary facility and certificates of registration to practice animal physical therapy or animal chiropractic; revising certain continuing education requirements to conform with biennial licensing and registration periods; removing the requirement that certain applications submitted to the Board be notarized; and providing other matters properly relating thereto. (R074-21P – full text in link)  

Legislative Counsel’s Digest:  

Existing law authorizes the Nevada State Board of Veterinary Medical Examiners to adopt regulations to carry out the provisions of existing law governing the practice of veterinary medicine. (NRS 638.070, as amended by section 10 of Assembly Bill No. 200, chapter 186, Statutes of Nevada 2021, at page 875) Assembly Bill No. 200 of the 2021 Legislative Session (A.B. 200), which became effective on October 1, 2021, establishes the requirements that a veterinarian must satisfy for the purpose of having a veterinarian-client-patient relationship with an animal, including having adequate knowledge of the present care and health of the animal in order to provide a general or preliminary diagnosis of the medical condition of the animal. A veterinarian is authorized to acquire such knowledge by conducting a physical examination of the animal. (Section 3 of Assembly Bill No. 200, chapter 186, Statutes of Nevada 2021, at page 872 (NRS 638.1521)) Section 1 of this regulation interprets the term “physical examination” for the purpose of such provisions. Section 2 of this regulation removes the requirements for establishing a veterinarian-client-patient relationship that are set forth in existing regulations. (NAC 638.0197)  

A.B. 200 eliminates the requirement that an application for a license to practice veterinary medicine, surgery, obstetrics or dentistry in this State be notarized. (NRS 638.100, as amended by section 11 of Assembly Bill No. 200, chapter 186, Statutes of Nevada 2021, at page 876)  

Existing regulations require that certain other applications submitted to the Board be notarized. (NAC 638.0445, 638.0447, 638.0603, 638.0605, 638.760, 638.810, section 1 of LCB File No. R099-19) Sections 5-9, 11 and 13 of this regulation remove such a requirement.  

A.B. 200 newly establishes a biennial renewal period for licenses issued pursuant to chapter 638 of NRS and requires a licensee to submit an application for the renewal of his or her license on or before May 15 of each odd-numbered year. (NRS 638.127, as amended by section 12 of Assembly Bill No. 200, chapter 186, Statutes of Nevada 2021, at page 877) Existing regulations currently establish an annual renewal period for each permit to operate a veterinary facility and each certificate of registration to practice animal physical therapy or animal chiropractic and provide that such a permit and each such certificate of registration expires on January 1 of each year. (NAC 638.0605, 638.770, 638.820) Sections 8, 10 and 12 of this regulation, respectively, instead establish a biennial registration period and provide that such a permit and each such certificate of registration expires on June 30 of each odd-numbered year.  

Existing regulations establish various fees relating to licenses, registrations and permits issued by the Board. (NAC 638.035) Section 3 of this regulation doubles the amount of certain existing fees in accordance with the newly established biennial licensing and registration periods. Section 3 also provides that if a license, registration or permit was issued on or after June 30 of the immediately preceding even-numbered year, the Board will reduce the renewal fee charged and collected for the license, registration or permit by 50 percent. Section 3 further provides that fees charged and collected by the Board are not refundable.  

Existing law authorizes the Board to adopt regulations concerning requirements for continuing education. (NRS 638.070, as amended by section 10 of Assembly Bill No. 200, chapter 186, Statutes of Nevada 2021, at page 875) Existing regulations establish continuing education requirements for persons licensed to practice veterinary medicine or veterinary medicine as a diplomate and licensed veterinary technicians who wish to renew their licenses. (NAC 638.041) Section 4 of this regulation maintains such continuing education requirements for a person whose license was issued after October 1 of the immediately preceding even-numbered year, but otherwise doubles such continuing education requirements in accordance with the newly established biennial licensing period.  

Existing regulations require that an application for the renewal of a certificate of registration to practice animal physical therapy or animal chiropractic include proof that the applicant satisfied certain continuing education requirements during the 12-month period immediately preceding the beginning of the new registration year. (NAC 638.770, 638.820) Sections 10 and 12, respectively, maintain such continuing education requirements for any such applicant whose license was issued after October 1 of the immediately preceding even-numbered year, but otherwise double the hours of continuing education that any such applicant must complete during the 24-month period immediately preceding the beginning of the new period of registration.  

A.B. 200 revises the definition of the term “practice of veterinary medicine” to specify conduct that the term does not include. (NRS 638.008, as amended by section 6 of Assembly Bill No. 200, chapter 186, Statutes of Nevada 2021, at page 873) Section 14 of this regulation accordingly repeals the section of existing regulations that specifies the conduct that the term does not include. (NAC 638.0195) 

NSVMA Policy Statement on Telemedicine 

“This policy statement has been adopted from the National Policy Statement on Telemedicine developed by the Canadian Council of Veterinary Registrars (CCVR) and is designed to promote consistency, transparency, and fairness in the development of similar guidelines on telemedicine across Canada. 

Definition: Telemedicine is the provision of specific veterinary medical advice and veterinary treatment of an animal(s) based on the remote diagnosis of disease and injury by means of telecommunications technology where no physical examination of the animal(s) by the veterinarian takes place. It does not include consultation between veterinarians where colleagues in different physical locations consult remotely with each other or the provision of general, non-specific, advice.”

Click on the hyperlinked document above to see the full policy statement, which has been broken down into the following three sections: 

A) Expectations for NSVMA Licensed Veterinarians practising Telemedicine within the Province of Nova Scotia
B) Expectations for a NSVMA Licensed Veterinarian practising Telemedicine across Borders
C) Expectations for a Veterinarian not licenced in Nova Scotia while practicing telemedicine in Nova Scotia

The Vermont Board of Veterinary Medicine posted Proposed Administrative Rules for Veterinarians on May 1, 2022.  

Administrative Rules for Veterinarians   


1-1 “Client” means a person seeking veterinary care on behalf of a patient. 
1-2 “Companion animal” means an animal for which a client has assumed responsibility and ownership as an individual companion or service animal.  
1-3 “Direct Supervision” means oversight by a licensed veterinarian available to physically intervene in the care of an animal.  
1-4 “Director” means the Director of Professional Regulation. 
1-5 “Foreign” means emanating from or existing within a governmental jurisdiction other than the State of Vermont.  
1-6 “License” or “licensure” refers to any credential issued by the Office under these rules, including a certification or registration, except where context clearly indicates reference to a foreign or other professional license.  
1-7 “Licensee” means a person or entity seeking or holding a license under these rules.  
1-8 “Non-companion animal” means an animal raised for economic or agricultural purposes.  
1-9 “Office” means the Office of Professional Regulation.  
1-10 “Office website” means  
1-11 “Patient” means an animal that is the subject of veterinary care.  
1-12 “Veterinarian-Client-Patient Relationship” or “VCPR” is defined at 26 V.S.A. § 2433. See Rule 8-3, infra  


2-1 Applicable Law. The practice of veterinary medicine is defined and regulated pursuant to 26 V.S.A. § 2401 et seq. Copies of these and other statutes are available online at The Office administers licensure in conformity with these and other Vermont laws, to include the Administrative Procedure Act, 3 V.S.A. § 800 et seq.; the Public Records Act, 1 V.S.A. § 315 et seq.; and the Laws of Professional Regulation, 3 V.S.A. § 121 et seq.  

2-2 Resources for Applicants and Licensees. The Office maintains a website at with information and links relevant to all licensed professionals. Information specific to veterinarians is available from 

2-3 U.S. Armed Forces. The Director may accept the requirements of these rules relevant military education, training, or service completed by a member of the U.S. Armed Forces and may expedite licensure of a person who left licensed employment in another state secondary to a spouse’s military transfer to Vermont. 3 V.S.A. § 123(g). Service members and the spouses of service members should visit the Office website for details.  


3-1 Applications. Online license applications must be completed through the Office website. 

  • (a) Incomplete applications will not be processed. Applications are complete only when all required questions have been answered fully, all attestations made, all required documentation and materials provided, and all fees paid. 
  • (b) When the Board, or the Office on the Board’s behalf, intends to deny an application, notice stating the reasons for the action shall be given to the applicant by certified mail, whereupon the applicant shall have 30 days to petition for a hearing before an administrative law officer. 
  • (c) The Board may refuse to accept any application found to be redundant with a denied or in-process application.
  • (d) The Board may deem expired any application that is left pending for six months.  

3-2 Complaints. Complaints against licensees, applicants for licensure, or persons practicing without a license may be submitted through the Office website, at 

3-3 Contested Cases. Procedures in contested cases relating to licensure or discipline are governed by the Office of Professional Regulation Administrative Rules of Practice, CVR 04-030- 005, as those rules may from time to time be modified.  

3-4 Declaratory Rulings. Petitions for declaratory rulings as to the applicability of any statutory provision or of any rule or order of the Board or Office may be made pursuant to 3 V.S.A. § 808 and Office procedure.  

3-5 Conflict of Standards. Where a standard of unprofessional conduct set forth in statute conflicts with a standard set forth in rule, the standard that is most protective of the public shall govern. See 3 V.S.A. § 129a(e).  

3-6 Determination of Equivalency. Where the Board or Director is permitted by law or rule to accept certain training or experience on the basis of equivalence to a fixed standard, it is the burden of the applicant or licensee to establish equivalence to the Board or Director’s satisfaction, by producing credible, clear, and convincing evidence of the same. The Board and the Office have no obligation to research the bona fides of any institution, program, course, degree, certification, practicum, fellowship, or examination.  

3-7 Waiver or Variance. The Board will not grant routine waivers or variances from any provisions of these rules without amending the rules. See 3 V.S.A. § 845. Where, in extraordinary circumstances, application of a rule would result in manifest unfairness, an absurd result, unjustifiable inefficiency, or an outcome otherwise inimical to the public health, safety, and welfare, the Board may, upon written request of an interested party, so find, grant a waiver with or without particular conditions and limitations, and record the action. 

3-8 Inspection. All veterinary hospitals and other non-residential premises used by licensees in relation to the provision of veterinary services shall be open to announced or unannounced visits by Office inspectors during regular business hours.  

3-9 Contacting the Board. See the Office website for contact details. Send mail to: 
Office of Professional Regulation, ATTN: Board of Veterinary Medicine, 89 Main Street, 3rd Floor, Montpelier, VT 05620-3402.  


4-1 Core requirements. An applicant is eligible for licensure who has: 

  • (a) reached the age of majority;
  • (b) graduated from a school of veterinary medicine accredited by the American Veterinary Medical Association or the Canadian Veterinary Medical Association; and
  • (c) passed the North American Veterinary Licensing Examination (NAVLE), or any subsequent licensing examinations prepared under the authority of the National Board of Veterinary Medical Examiners (NBVME) or its successor organization, within two years preceding application.  

4-2 International Veterinary Graduates not Licensed in the United States or Canada. In lieu of the graduation requirement of Rule 4-1(b), an applicant may present a certificate issued by the Educational Commission for Foreign Veterinary Graduates (ECFVG), its successor organization, or an organization acceptable to the Board.  

4-3 Veterinary Graduates Licensed Elsewhere in the United States or Canada. A person licensed or certified in good standing under the laws of another jurisdiction may be eligible for licensure without examination as specified by 26 V.S.A. § 2424.  

4-4 State Laws & Rules. Examination on Vermont-specific laws and rules is not required. All veterinarians are responsible to maintain ongoing familiarity with State and Federal laws and rules governing the practice of the profession, just as all veterinarians are responsible to follow evolving practice standards. Ignorance of regulatory requirements does not excuse non-compliance. Means of ensuring orientation to regulatory obligations include participation in professional associations, consultation with qualified legal counsel, subscription to professional publications, and periodic online monitoring of legislative and regulatory developments.  

4-5 Consultation Exemption. Board licensure is not required of a veterinarian regularly licensed in another jurisdiction consulting with a licensed veterinarian in this State. Accord 26 V.S.A. § 2403(5). Exempt consultation is limited to the provision of specialized professional advice or assessment or the demonstration of clinical practices. A consulting veterinarian is, for purposes of professional responsibility, a delegate of the Vermont veterinarian with whom he or she consults and may provide veterinary services only to animals with which the Vermont veterinarian has a valid VCPR and as requested by the Vermont veterinarian.  

4-6 Livestock Management and Husbandry Exemption. Board licensure is not required of persons engaged in accepted livestock management practices and animal husbandry practices. See 26 V.S.A. § 2403(2). Embryo transfer is not exempt as an accepted livestock management practice and may be performed only by or under the direct supervision of a Vermont-licensed veterinarian.  


5-1 Biennial Licensing Period. Licenses are valid for fixed, two-year periods. Expiration dates are printed on licenses. A license expires if not renewed by midnight on the date of expiry. Practice under an expired license is prohibited. An initial license issued fewer than 90 days prior to the beginning of the fixed biennial period shall be valid through the end of the full biennial licensing period following initial licensure. A lookup tool on the Office website may be considered a primary source verification as to license status and expiration.  

5-2 License Renewal. Online license renewal applications must be completed through the Office website. The Office transmits email reminders to licensees at the end of each biennial licensing period; however, non-receipt of such reminders shall not excuse a licensee from the obligation to maintain continuous licensure or the consequences of failing to do so. Practicing while a license is lapsed is a violation of 3 V.S.A. § 127.  

5-3 Late Renewal Penalties. Late renewal applications are subject to reinstatement fees, which may be waived in certain circumstances. See 3 V.S.A. § 127(d). Reinstatement waivers may be requested through the online licensing system.  

5-4 Extended License Lapse. A license expired for five or fewer years may be reactivated as of right upon proof of continuous veterinary practice elsewhere, or if veterinary practice ceased, upon completion of the continuing education required in the preceding biennial licensing period. When a license has been expired for five or more years, a licensee’s preparation to return to practice will be assessed on a case-by-case basis. After consultation with the Board, the Director may require re-training, testing, or re-application. See 3 V.S.A. § 135; 26 V.S.A. § 2426.  


6-1 Continuing Education 

Requirement. All licensees have a duty to maintain professional competence through conscientious pursuit of professional learning opportunities, interaction with peers, and continual review of relevant scientific and professional literature. In each biennial licensing period, a licensee shall devote at least 24 hours to such pursuits and shall attest to having done so as a condition of renewal.  

Relevance. Licensees are expected to identify and pursue appropriate learning opportunities in good faith. Activities claimed under this rule shall be reasonably calculated to improve the particular professional practice of the licensee, shall be relevant, and shall be oriented toward an evidence-based practice or the improvement of technical skill. Express approval of continuing learning opportunities is not required.

Documentation. A licensee shall document participation in professional learning activities. For courses, a licensee shall retain completion certificates. For non-course activities, such as reading, research, presentation, or curriculum development, a licensee shall maintain a contemporaneous log of pertinent details, such as journal citations; presentation titles, locations, dates, sponsors, and host institutions; the length of time spent on the activity; and a brief, written summary of the substantive reading, research, presentation, or curriculum developed. A form log is available at the Board website. Certificates and logs must be retained for four years. The Board may audit continuing education compliance at any time.  


7-1 Duty to Update and Self-Report. Applicants and licensees owe a duty of candor to the Board and shall disclose circumstances that may call for further investigation to protect the public. That a matter is reportable does not imply that the matter necessarily is a basis for discipline. A licensee, including an applicant for licensure, shall report to the Office, in writing, within 30 days:  

  1. any change of name, e-mail, or mailing address;
  2. any material inaccuracy or change in circumstance relative to any application question, where the changed circumstance arises between submission of a license application and issuance of the license sought;
  3. any arrest or charge for conduct occurring in the course of, or in direct relation to, the practice of veterinary medicine;
  4. any conviction for any criminal act;
  5. any injunction or other order of a court or regulatory authority, including an assurance of discontinuance, limiting the licensee’s ability to practice;
  6. any legal claim, settlement, or judgment arising from alleged professional negligence, misconduct, or malpractice; and
  7. any adverse action against a foreign professional license, where the adverse action relates to an allegation of misconduct, substandard practice, or unethical conduct.
    1. Pursuant to 6 V.S.A. § 1162, a veterinarian shall immediately report to the State Veterinarian:  

7-2 Duty to Report Disease.  

  1. the discovery of any domestic animal that is infected with, is suspected of being infected with, or has been exposed to a disease reportable under 6 V.S.A. ch. 102; 
  2. any sudden unexplained morbidity or mortality in a herd or flock.
  3. A veterinarian shall report to the Secretary of Agriculture, Food & Markets any horse that has tested positive for equine infectious anemia and shall see that the animal is quarantined if required by 6 V.S.A. § 1182(c).
    1. A veterinarian shall report to the Commissioner of Health any animal or animals having or suspected of having any disease that can result from bioterrorism, epidemic or pandemic disease, or novel and highly fatal infectious agents or biological toxins, and those that might pose a risk of a significant number of human and animal fatalities or incidents of permanent or long-term disability. 13 V.S.A. § 3504(d).  


8-1 Ethical Conduct. The Board may consider the Principles of Veterinary Medical Ethics of the AVMA a recognized source of professional standards when determining “the essential standards of acceptable and prevailing practice” for purposes of 26 V.S.A. § 129a(b). This section shall not be construed as imposing any mandatory-reporting obligation not otherwise present under Vermont law.  

8-2 Compliance with Other Law. Licensees must comply with all federal, state and local laws, governing the practice of the profession. 3 V.S.A. 129a(a)(3).  

8-3 The Veterinarian-Client-Patient Relationship. The three elements of a VCPR—assumption of responsibility for care, sufficient knowledge of the patient, and availability – are defined more particularly at 26 V.S.A. § 2433, together with important related principles not restated in these Rules. A valid VCPR:  

  1. must exist prior to the provision of any veterinary care, other than in a rabies clinic or an emergency; and 
  2. must exist prior to issuance of a veterinary feed directive or any activity relative to the provision, administration, authorization, or prescribing of veterinary prescription drugs. 

8-4 Telepractice. When determining whether a valid VCPR has been established, the Board will inquire into the sufficiency, reliability, and validity of the veterinarian’s knowledge, not the means or modality by which that knowledge was obtained. Veterinarians are authorized to use their reasoned clinical judgment to determine when and how telemedicine modalities may be used.  

  • Common standard of care. A Veterinarian using telemedicine must take appropriate steps to establish a VCPR, obtain informed consent from the client, and conduct all necessary patient evaluations consistent with currently acceptable standards of care. Some patient presentations are appropriate for the use of telemedicine as a component of, or in lieu of, hands-on medical care, while others are not. 
  • Federal laws and rules. This rule shall not be construed as superseding any contrary law or rule of the United States Food & Drug Administration.  

8-5 Veterinary Records: Companion Animals. For each companion animal with which a veterinarian has a VCPR, the veterinarian shall retain a distinct file including:  

  • (a) client and patient information;
  • (b) a competent history;
  • (c) individualized entries recording each assessment, treatment, consultation, procedure, intervention, diagnosis, and plan; and
  • (d) the identity of each person providing such service.  

8-6 Veterinary Records: Non-companion animals. Group records are acceptable for non- companion animals; provided, however, that an individual record shall be initiated when indicated by the health status of the animal.  

8-7 Records Retention and Production. A veterinarian shall retain patient records for not fewer than seven years from last contact with an animal, or in contexts where other law requires longer retention, for the longer period. Failure to keep appropriate records may constitute unprofessional conduct. 3 V.S.A. § 129a(a)(3). Records shall be typed when practicable under the circumstances, legible, reasonably protected from inadvertent destruction, and fit to transmit relevant content to a subsequent provider of care. Records shall be made available promptly upon written request of a client and may not be withheld for non-payment; provided, however, that a veterinarian may require that a client pay actual costs of production of transmissions, such as copying and postage. See 3 V.S.A. § 129a(a)(8).  

8-8 Records Disposition. A veterinarian shall have in place a plan for the responsible disposition of patient veterinary records in the event the veterinarian should become incapacitated or unexpectedly discontinue practice. 3 V.S.A. § 129a(a)(25). Group practices may satisfy this requirement through a written agreement among partners that contemplates dissolution of the partnership or separation of a partner. Any veterinarian may satisfy this requirement through written agreement with a professional peer, attorney, or other person or organization credibly capable of seeing to appropriate disposition of records. A veterinarian’s records-disposition plan shall be available upon request of a client or the Board, but need not be filed with the Board unless requested.  

8-9 Delegation. A licensee shall delegate professional responsibilities only to those whom the licensed professional knows, or has reason to know, is qualified by training, experience, education, or licensing credentials to perform them. Diagnosis, prescription, and surgery are not delegable by a veterinarian to a non-veterinarian.  

8-10 Alternative Therapies. Alternative therapies may be provided in conformity with accepted principles of veterinary ethics; provided, however, that a veterinarian shall not advertise, promote, or recommend a therapy or treatment in a manner tending to deceive the public or to suggest a degree of reliability or efficacy unsupported by competent evidence and professional judgment. See 26 V.S.A. § 129a(a)(17).  

8-11 Integration of Complementary Care Providers. Vermont law does not authorize any non-veterinarian licensed under Title 26 to undertake any act within the scope of veterinary medical practice. Non-veterinarian providers may be skilled in certain modalities that may be safely applied for therapeutic benefit to animals under the supervision of a veterinarian. A veterinarian may delegate veterinary treatments to such providers if:  

  • (a) the veterinarian has a valid VCPR;
  • (b) the requirements of Rule 8-9 are satisfied;
  • (c) the veterinarian has verified that the provider is oriented to the unique anatomy, physiology, and behavior of the animal to be treated by documented training additional to that required for the provider to practice his or her care modality on humans;
  • (d) the veterinarian has a competent clinical and evidential basis to believe the service will be of therapeutic benefit;
  • (e) the veterinarian has prescribed in writing the treatment or act to be performed;
  • (f) the veterinarian and delegate provider have established a written plan of care recorded in the veterinary record;
  • (g) an appropriately qualified veterinarian is available to consult and arrange for intervention in the event of complications; and
  • (h) the informed consent of the client is obtained and recorded in the veterinary record, including as to any compensation exchanged between veterinarian and delegate provider.  

8-12 Rabies Vaccination; VCPR Not Required; Minimal Recordkeeping. It is in the interest of the public health, safety, and welfare that veterinarians participate in rabies vaccination clinics and offer office-based rabies vaccination. A VCPR is not required. A veterinarian participating in a vaccination clinic may do so in conformity with the Agency of Agriculture, Food & Markets’ Rabies Vaccination Clinic Rule, CVR 20-022-018, or successor rules. For purposes of those rules, “examination” means such assessment as may be necessary to determine whether the animal is fit for vaccination and does not mean a comprehensive evaluation of health. A veterinarian participating in a rabies vaccination clinic, who complies with records requirements specified in CVR 20-022-018 or successor rules, is excused from the patient recordkeeping requirements in these Rules  


9-1 Unprofessional Conduct. Unprofessional conduct includes those acts set out at 3 V.S.A. § 129a (applicable to all professional licensees). Violation of these rules is cognizable as unprofessional conduct pursuant to 3 V.S.A. § 129a(a)(3).  

9-2 Remedies. Upon a finding by the Board that a licensee, applicant, or person who later becomes an applicant has committed unprofessional conduct, within or without this State, or has had a license application denied or a license revoked, suspended, limited, conditioned, or otherwise disciplined by a licensing agency in another jurisdiction for conduct which would constitute unprofessional conduct in this State, or has surrendered a license while under investigation for unprofessional conduct, the Board may warn, reprimand, suspend, revoke, limit, condition, deny, or prevent the renewal of a license. See 3 V.S.A. § 129(a). A license may be summarily suspended pending further proceedings, consistent with 3 V.S.A. § 814(c), upon a finding that public health, safety, or welfare imperatively requires emergency action.   

At their April meeting, The Virginia Board of Veterinary Medicine discussed the following items and took the following action:  

  • Draft Guidance Document for VIC:  The Board unanimously voted to amend the draft VIC Guidance Document and present it to the Committee at its next meeting.


  • 18 VAC 150-20-195(B) Recordkeeping and 18 VAC 150-20-10 Definitions: The Board discussed the drafted amendment on medical recordkeeping for “agricultural” animals, and definitions of animal classifications to clarify recordkeeping requirements. The proposed amendments to the definitions of different classifications of animals under 18 VAC 150-20-10 were presented for the Committee’s consideration to include updating “companion” and “agricultural” animals and adding a separate classification for Equidae. The Board voted to accept the definitions of agricultural animals, companion animals, and Equidae under 18 VAC 150-20-10, as presented. The Committee then considered the drafted amendments to recordkeeping requirements and discussed minor changes needed for clarification. The Board voted to accept the changes as presented with the Committee’s changes. The motion was seconded by Ms. Ashworth and carried unanimously. 


  • 18 VAC 150-20-201(A): The Board voted to allow staff additional time to research and draft proposed amendments.


  • Inspection Guidelines: Preliminary findings that identified logistical and safety concerns with conducting virtual or focused inspections of veterinary establishments were presented. Additional time to gather more data before presenting guidelines for inspection frequency and type for the Committee’s consideration was requested. The Committee agreed that the staff will continue research on the practicality of focused and virtual inspections. 


  • Guidance Document 76-21.2.1 Veterinary Establishment Inspection Report: Corrections were accepted and three additional categories for proposed changes to this report, including consolidating related regulations, adding guidance to regulations where none currently exists and amending the point values to more accurately reflect deficiencies were presented. Changes will be presented at the next Committee meeting. The Committee agreed that the categories as presented are appropriate to amend and directed staff to present the proposed changes at its next meeting. 


  • Guidance Document 150-8 Disposition of Cases Involving Practicing on an Expired License or Registration: The Board voted to extend the grace period for renewal of veterinary establishment registrations, and direct staff to present an amended document at its next meeting. 

At their May 5 special meeting, the Veterinary Board of Governors (VBOG) voted to endorse a proposed apprenticeship program for veterinary technicians: 

Veterinary Technician Apprenticeship Program Proposal 
SkillSource, the North Central Workforce Development Board (NCWDB), and Cascade Veterinary Clinic (CVC) have provided the board finalized program materials for their veterinary technician apprenticeship program. The board will discuss materials, ask for stakeholder input, and decide whether to support, oppose, or remain neutral on the finalized program. SkillSource/NCWDB/ CVC need to submit materials to the Washington State Apprenticeship and Training Council no later than June 6th for review and approval at their July 20th meeting. (Full Materials) 

Summary of veterinary board work with the SkillSource/NCWDB and CVC:  

  • Oct 15th, 2021 Special meeting – The chair summarized what was shared at the September 13th meeting, then opened the floor to stakeholders. Several stakeholders spoke about issues with the program proposal related to appropriate oversight and accountability, teachers who are veterinarians and not also credentialed educators, and variety of other concerns that a program of this nature is not able to demonstrate it meets national standards. The outstanding concern is that without going through the AVMA’s CVTEA accreditation, the program cannot show that it has all the program components in place to ensure the program produces competent and successful LVTs. A couple of attendees spoke in support of apprenticeship programs and provided information about oversight, other health professions going this route, and that this is a proven methodology for producing competent workers in some demanding and challenging professions with robust and difficult curriculum. Supporters spoke of increased opportunities in rural areas and for students who could not otherwise afford the education. Program proponents summarized their efforts over the past several years to develop an apprenticeship program for the Cascade Veterinary Clinics. They believe apprenticeships are a proven training and educational model that can be highly successful in the veterinary setting. As a private clinic group, they are not eligible to apply for AVMA accreditation, and don’t believe that accreditation is necessary for them to develop a successful program. They feel they have developed a very robust and thorough program that represents an innovative solution to the critical shortage of LVTs in the state. They are open to a cost-effect approach to partner with an accredited institution to make the program work. The board asked the proponents some clarifying questions and there was discussion about how the LVT apprenticeship program works in Colorado. The program partners with the community college and has AVMA accreditation. The program is still about 6 months out from its revised program documents, so the board is going to put a hold on this agenda item until there is more information for the board to review, discuss and understand. The subcommittee will meet as needed, and once the subcommittee has updates, it will bring this topic to the next available public board meeting. 


  • September 2021 meeting – Information was shared about background of the proposal and why the board has taken its current position of endorsing further development of the program so that it meets national educational standards. The chair recapped major areas of concern that the board has heard previously, and the board’s response and thoughts on those concerns that has led them to supporting continued development. 


  • June 2021 meeting – Program proponents provided an update that they are in the process of realigning the OJT and RSI to align with CVTEA standards. The program is still 9-12 months from being in final draft form. Stakeholders reiterated some of their concerns, such as missing educational resources to support the program, and the ability to fund and sustain the program. Stakeholders would like to see the program go through AVMA’s CVTEA accreditation process. The board approved a motion to schedule a special meeting in October and to involve L&I and the AVMA in the discussion. 


  • May 2021 special meeting of the board – The apprenticeship program provided a presentation about the program, standards, and supplemental instruction. Board members asked questions, then opened to public comment. There was a lengthy discussion between the board, program proponents, and concerned members of the veterinary community. The board approved an action to “endorse further development of the program” for the Washington State Apprenticeship and Training Council (WSATC) to consider review of program documents. The board will compile information about the WSATC process, the board’s legal authorities to approval an apprenticeship program, a cross-walk between CVTEA and apprenticeship program standards, summary of board actions to date, addressed concerns, and outstanding concerns. 


  • March 2021 meeting – The board reviewed an additional letter of concern from NAVTA, as well as a draft letter of support from the board to the WTECB that was written after the board reviewed updated program materials and before stakeholder outreach. The volume of comments that need to be discussed prompted the board to plan a special meeting on this topic prior to the June business meeting. 


  • December 2020 meeting – The board reviewed letters of concern from LVT program directors, WSAVT, and WSVMA and discussed themes of the concerns. Apprenticeship program staff expressed ongoing willingness to adjust curriculum to meet concerns about standards. The board determined that more in-depth discussion would be needed at the March meeting. The board will hold off on a rulemaking proposal until concerns are discussed in more detail. 


  • September 2020 meeting – The subcommittee provided the board an update based on the August 2020 meeting. The board also review information about the requirements of the Washington Workforce Training & Education Coordinating Board (WTECB), which is the accrediting board for the program. The program exceeds WTECB requirements. The board expressed support for the program and the desire to send a letter of support to the WTECB and consider rulemaking to add the option for apprenticeship educational programs. Before taking up rulemaking to allow apprenticeships as a qualifying educational pathway, the board asked LVT board member Kim Morgan to reach out to community college program directors. 


  • August 2020 subcommittee meeting – The subcommittee reviewed and supported the updated standards and curriculum. Veterinary technician requirements for exam eligibility were reviewed to see if existing rules permit the board to approve this program, or if the board would need to do rulemaking to add an additional qualifying pathway to licensure. It is feasible that the board could approve it through existing rules, but doing rulemaking for clarity and transparency would be a good option.
  • June 2020 meeting – Apprenticeship program staff presented its education and training program proposal with the board at its June 2020 meeting. The board formed a subcommittee to continue work with apprenticeship program staff. The subcommittee met and asked apprenticeship program staff to adjust program standards and curriculum to be more robust. 


  • March 2020 meeting – Apprenticeship program staff first connected with the board about the shortage of veterinary technicians in January 2020 and discussed this issue with the board at its March 2020 meeting.  

Effective June 8, 2022, WV licensed or registered veterinarians will be allowed to offer telehealth.  The complete law can be found on the Board’s website at this link.  Please contact the Board office at or 304-776-8032 should you have any questions. 

Below are important facts to consider when practicing telehealth:  

  • Personal examination is a face-to-face, in-person, examination of the patient. 
  • The practice of veterinary medicine occurs where the patient is located at the time telehealth services are provided. 
  • A veterinarian-client-patient relationship is required for providing veterinary care via telehealth services. The veterinarian shall perform an in-person exam within the 12 months prior, and at least every 12 months thereafter or the telehealth service shall no longer be available to the patient. 
  • In the event of an imminent, life-threatening emergency veterinary care may be provided via telehealth services without an existing veterinarian-client-patient relationship or without an in-person visit within 12 months. 
  • The standard of care for providing veterinary care in the State of West Virginia via telehealth services by a registered or licensed veterinarian shall be the same as for in-person care. 
  • A provider of telehealth services must ensure that the client is aware of the veterinarian’s identity, location, and license number and licensure status and should provide to the client a clear mechanism to: 
  • Access, supplement, and amend client-provided contact information and health information about the patient; 
  • Register complaints with the Board; 
  • Provide consent for the use of telemedicine and, 
  • Patient medical records must meet the requirements as specified in the Standard of Practice Rules. 
  • Shall not prescribe any controlled substance listed in Schedule II of the Uniform Controlled Substance Act via interstate telehealth services 

Below is information regarding Veterinary Telehealth Registration: 

  • A veterinarian not licensed by the Board must apply for and obtain registration with the Board using the application materials provided by the Board and paying a fee of $300. 
  • A veterinarian that currently holds a WV veterinary license is not subject to registration but shall practice telehealth in accordance with the Board’s laws and the rules. 
  • A registrant is subject to the laws, rules, and regulations regarding the practice of veterinary medicine in this state, including the state judicial system and all rules and standards of professional conduct contained within §30-10-1 et seq. of this code and the rules promulgated thereunder. 
  • A registrant shall notify the Board within 30 days of any restrictions placed upon, or actions taken against, his or her license to practice in any other state or jurisdiction. 
  • A registration with the Board does not authorize a veterinary care professional to practice from a physical location within the State of West Virginia without first obtaining appropriate facility registration. 

4. VMA Updates

The 2022 Legislative cycle is well underway, with bills currently being heard in policy committees at the Capitol. Out of those hundreds of bills, the CVMA legislative team flagged approximately 25 of them as being potentially impactful to veterinary medicine, animal health and welfare, and/or employer-employee relations. Ultimately, after several levels of review and discussion, the CVMA Board of Governors took official positions on all of those bills at its April 2 meeting.  

While the CVMA legislative team is following all bills closely, a few bills rise to a priority level due to their subject matter. Below are summaries of critical bills being addressed by the CVMA.  

AB 2606 (Carrillo) Cats: declawing procedures: prohibition  
CVMA Position: Oppose  

This bill would restrict veterinarians from performing a declawing procedure on cats unless it is being performed for 
a therapeutic purpose. The bill would impose a civil penalty 
that increases for each violation when a declawing procedure 
is performed. While not expressly written into this bill, the law—if enacted—would also subject veterinarians to regulatory enforcement by the Veterinary Medical Board, as it would create a legal prohibition of a veterinary medical procedure.  

The CVMA opposes this bill because it would outlaw a procedure falling within the scope of veterinary medical practice. While 
the CVMA institutionally discourages the use of declawing as an elective procedure and supports non-surgical alternatives, the CVMA works to preserve the profession’s right to govern itself, and believes that veterinarians must be permitted to interact with clients and patients on a case-by-case basis to ensure that the best individual decisions are made in a given situation.  

This bill was recently heard in the Assembly Business and Professions Committee on April 26. The CVMA submitted an opposition letter and testified alongside the Veterinary Medical Board in opposition to the bill. The bill passed the committee and will now go to the Assembly Appropriations Committee. The CVMA will continue to fight for the interests of the veterinary profession as this bill continues through the legislative process.  

AB 1881 (Santiago) Animal welfare: Dog and Cat Bill of Rights  
CVMA Position: Neutral, as amended  

In its original format, this bill presented a number of issues for the CVMA due to the legal implications of its statements. While the intentions of the bill are ostensibly to educate the public about the obligations of pet ownership, there were several statements in the original bill that caused the CVMA concern. One example included use of the term “guardian” in reference to pet ownership. This term carries legal implications that invite litigation regarding non-economic damages and third-party representation of pets in legal proceedings. Additionally, the bill listed a number of dog and cat “rights”—such as the right “to a life of comfort, free of fear and anxiety”—that stakeholders felt impossible to achieve.  

The CVMA joined a coalition with the Animal Health Institute and the American Kennel Club and signed onto two comment letters that suggested amendments to AB 1881 addressing the unintended legal consequences referenced above. The bill was amended in  

the Assembly Business and Professions Committee on April 26 to remove the term “guardian” and also added more aspirational (but non-binding) language to declare what animals “deserve.”  

AB 1885 (Kalra) Cannabis and cannabis products: animals: veterinary medicine
CVMA Position: Support  

Current law permits veterinarians to discuss with clients the use of medicinal cannabis for animal patients but prohibits cannabis recommendation. Over the past two years, unsuccessful attempts were made in the form of AB 384 (Kalra) and SB 627 (Galgiani) to permit veterinarians to recommend cannabis.  

This year, Assemblymember Ash Kalra submitted AB 1885 
in another attempt to permit cannabis recommendation by veterinarians. The CVMA has a strong working relationship with Mr. Kalra and his staff and is grateful that they recognize that veterinarians need to have complete and effective conversations with clients about cannabis. Permitting cannabis recommendation to clients will help to legally enable the profession to do so.  

This bill passed the Assembly Business and Professions Committee on April 19. The CVMA submitted a letter in support of the bill to all committee members and CVMA lobbyists testified in support of the bill during the meeting. It will now go to the Assembly Appropriations Committee.  

AB 2764 (Nazarian/Lee) Animals: commercial animal feeding operations and slaughterhouses 
CVMA Position: Pending neutral, if amended  

In its original format, this bill would have prohibited the development or expansion of commercial animal feeding operations and slaughterhouses in California, including the addition of new businesses. This includes feedlots, broiler farms, aquatic farms, and other commercial agriculture production operations that sell animal-based products or byproducts.  

The CVMA was opposed to this bill due to its impact on food production in the state, among other reasons. The CVMA submitted an opposition letter to the authors early on in the legislative cycle. Due to the significant opposition expressed by several agriculture lobbying groups as well as the CVMA, the authors are currently working with legislative consultants to incorporate a number of amendments into the bill. If those amendments are incorporated, the CVMA will be able to lift its opposition.  

This bill is pending hearing in the Assembly Agriculture Committee.  

See chart on page 12 for CVMA positions on all legislation currently being monitored by the CVMA. 

Colorado Veterinary Practice Act passes out of legislature, goes to Governor for signature 

On to the Governor! On Thursday, May 5, the Veterinary Practice Act (HB 22-1235) Sunset Continue Regulation of Veterinary Practice, passed the third reading in the Colorado Senate, and began the last leg of its journey by moving to the Governor for signature. 

Three highly respected, thoughtful, and dedicated legislators have been working with CVMA to guide HB22-1235 through the 2022 legislative session. We invite Colorado veterinarians to extend warm thanks to these elected leaders. 

CVMA is very appreciative for the House of Representatives leadership of our prime sponsors Rep. Karen McCormick, DVM, who represents District 11 in Boulder County, and Rep. Marc Catlin, who represents District 58, including Dolores, Montezuma, Montrose, and San Miguel counties. 

In the Senate, CVMA appreciates working with prime sponsor Sen. Joann Ginal, who represents District 14 in Larimer County. 

CVMA is quite pleased that HB22-1235 was approved this week, before the extremely busy last few days of the legislative session that ends on Wednesday, May 11. This week, the bill passed three final hearings (out of some fourteen total hearings) — the Senate Appropriations Committee, and on the floor of the Senate for 2nd and 3rd readings. Listen to clips of the April 8, 2022, House Second Reading, and the May 4, 2022, Senate Second Reading. 

The bill now goes to Governor Polis for signature. It will take effect at 12:01 AM on August 9, 2022. 

Travel With Care 

Pets Traveling Abroad 
International travel with your pet can be a wonderful experience for both of you. However, it is very important that you are aware of the requirements for your intended destination. Early planning is the key to ensure a stress-‐free and cost-‐effective journey!  

Step 1: Determine the requirements for your pet in the country of destination. These requirements can vary based on the type of pet you have (dog, cat, etc) and the type of diseases that are absent or present in the country of destination. Some countries have their own health certificate, others only require a US-‐origin International Health Certificate (APHIS form 7001) and some require both. The USDA Animal & Plant, Health Inspection Service (APHIS) website has a user-‐friendly list of all of the countries and their requirements that make it easy for you to use: 

Step 2: Consult with your family veterinarian. All international health certificates will have to be signed by a USDA accredited veterinarian (who should be your local family veterinarian). Your vet will have to perform a physical exam and give any necessary vaccinations, dewormers and any other preventatives that are necessary for entry into the country of destination. Your family veterinarian will then have to sign the health certificates, ensuring that your pet was examined within a certain time frame prior to travel and has met all the requirements for that country. Your family veterinarian should also be able to assist you, should you have any questions about timelines, correct forms, etc.  

Step 3: Make an appointment at your state’s federal Veterinary Services office for federal endorsement. Once your family veterinarian has signed the health certificates you must make an appointment with your state Veterinary Services office for federal endorsement (or you can send the documents through the mail). A federal, USDA veterinarian will look over all your documentation to make sure you have met all the requirements for that country. The forms will be signed, stamped, and endorsed with a federal seal. FORMS CAN NOT BE ALTERED ONCE THEY ARE FEDERALLY ENDORSED. 

Important Things to Remember:  

Should you or your family vet have any questions, contact your local Federal Veterinary Services Import/Export Office to help you!

Keep in mind the timeline for everything! Vaccines, physical exams, and endorsed health certificates all have a shelf life and this can vary.

Contact airline carriers to determine their requirements for foreign pet travel. Not all airlines transport pets internationally!

Understand that things can vary depending on if you are traveling with your pet or if your pet is traveling alone 

There are several pet travel companies that will handle all the paperwork for you if you do not want the hassle! You can take a look at their websites if you are interested. But, be careful as they can be expensive and some are far better than others. 

Other helpful links:

Pet Passports:

Center for Disease Control:

US Department of State: 

International Pet & Animal Transportation Association (IPATA): 

Administrative Rules Are Paused – April 21, 2022 

The Legislative Committee on Administrative Rules reviewed the Board of Veterinary Medicine’s draft administrative rules at a hearing on April 7, 2022.  Due to an administrative glitch, the process has been temporarily paused.  Members, please check your inbox for updates. 

Veterinary Board of Governors approves technician program opposed by the veterinary profession 

At their May 5 special meeting, the Veterinary Board of Governors (VBOG) voted to endorse a proposed apprenticeship program for veterinary technicians, a decision that has upset several state and national veterinary associations. The proposal was brought forward by Cascade Veterinary Clinics (CVC) in central Washington and the North Central Workforce Development Council (NCWDC) as an answer to the local shortage of veterinary technicians. The Board’s vote concluded a two-year process. 

Lack of accreditation 

The main reason for the opposition from veterinary leaders is the program’s lack of accreditation by the AVMA Committee on Veterinary Technician Education & Activities (CVTEA), the gold standard in veterinary technician education. The CVTEA requires that graduates of accredited programs must demonstrate proficiency in over 300 essential skills and guarantees a rigorous education where graduates are fully capable of performing in a wide variety of professional roles across all sectors of veterinary medicine. The apprenticeship program does not meet these stringent requirements and focuses mainly on small companion animal medicine. 

In addition to educational requirements, accreditation ensures proper physical facilities, equipment, and student safety, ensures sustainable financial support, maintenance of animal welfare requirements, adequate library and information resources, and fair admission policies. 

The lack of accreditation also means there will be no outside, independent oversight by the AVMA CVTEA or an agency that has veterinary expertise. The program will be monitored by non-veterinary personnel with no experience in veterinary medicine at the WA Dept. of Labor & Industries and the Washington State Apprenticeship and Training Council (WSATC). 

License portability 

A lesser reason but still one of concern is that the program will make it more difficult for graduates to leave Washington and work in other states. The American Association of Veterinary State Boards has promoted the idea of standardized licensure requirements across the U.S to allow for easier movement between states, but VBOG maintains that what happens in other states is not their purview. That may be true, but putting up more roadblocks for veterinary professionals in a highly mobile society can add to the stress and burnout already being experienced by our Washington technicians. 

The veterinary organizations opposed to the program reads like alphabet soup. Both the WSVMA and the Washington State Association of Veterinary Technicians (WSAVT) opposed the program. The National Association of Veterinary Technicians in America (NAVTA), the American Veterinary Medical Association (AVMA), the Association of Veterinary Technician Educators (AVTE), and the Registered Veterinary Technologists and Technicians of Canada (RVTTC) also actively opposed it. 

CVC’s answer to the veterinary technician shortage is countered by the many realities already documented in the profession. Veterinary technicians are leaving the profession in high numbers from not being able to make an affordable living, from a lack of respect, from not being utilized in the skills and tasks for which they’ve been educated and can legally perform, and from burnout. Half the number of veterinary technicians leave within their first five years. The problem isn’t the number of technicians entering the profession, it’s the number exiting. 

Some within the Washington veterinary community believe that outlawing Washington’s on-the-job training as a pathway to veterinary technician licensure in 2010 is the reason for creating the shortage, but the data gathered across the country indicate otherwise. 

Washington state is big on apprenticeships and is working to get more of them established. During meetings with VBOG, NCWDC representatives frequently cited how if it works for cosmetology, it will work for veterinary technicians, comments that drew the ire of many. They cited programs for certified nursing assistants (CNA) and medical assistants (MA) that are coming online soon as proof that medical professionals can be apprentice-trained. However, the required skills and tasks for CNAs and MAs can hardly be compared to those of a licensed veterinary technician whose skills are equivalent to nurses. 

Next, the WSATC will consider whether to support the program. Since the state considers apprenticeship programs to be important to getting people to work, it’s expected that it will be approved. This will open the door for the program to be replicated elsewhere in the state. 

The VBOG is comprised of five veterinarians, one veterinary technician, and one public member. Three new members joined last month to fill vacant positions. Two of them, former state legislator and WSVMA past president Dr. Kathy Haigh and WSU/CVM faculty and former Teaching Hospital Director Dr. Debra Sellon, opposed the program, but it wasn’t enough to prevent it from moving forward. 

During the meeting, CVC portrayed the veterinary profession as being protectionist and resistant to change, but let’s remember a big reason why the 2010 law was put into place eliminating OTJ style training. Rapid medical and scientific advances require educational experts to train technicians with the most up-to-date information. The change elevated technicians. This new apprenticeship program is a giant step backward. 

5. AVMA Updates

AVMA launches certificate program for first responders 

The AVMA started to release courses in mid-April as part of the Association’s new Veterinary First Responder Certificate Program, which is the nation’s first standardized training program for veterinary disaster and emergency planning and response.  

“There is a lot of excitement in the animal disaster community for this program,” said Dr. Warren Hess, an assistant director in the AVMA Division of Animal and Public Health who is overseeing the program. “While it may take some time before there is a larger number of courses, the excitement comes from the fact that there is finally a standard for veterinary responders, and we look forward to it becoming a national standard.” 

The AVMA Veterinary First Responder Certificate Program is designed to verify that veterinary professionals have been trained to respond efficiently and effectively to disasters by directing individuals to pre-evaluated courses that teach valuable disaster and emergency response material. The American Veterinary Medical Foundation provided $80,000 in funding to create the certificate program.  

The program is available via AVMA Axon, the Association’s online platform for continuing education. An individual will need to take enough courses to satisfy all core competencies. There are eight core competencies—each with sub-competencies—that must be satisfied in order to gain certification. 

The AVMA Committee on Disaster and Emergency Issues continues to accept submissions from organizations to have their training courses approved to be part of the certificate program. 

Three courses offered through the Federal Emergency Management Agency’s Independent Study Program have been approved. Dr. Hess said, “These are not related to animals or veterinary medicine; they introduce responders to how incidents should be managed.” 

The first two courses introduce the Incident Command System, which relates to local response and how it is structured, he explained. The third course introduces the National Incident Management System and how larger events involving federal resources are managed between local responders and federal agencies. 

“It is important that veterinary responders understand the system under which they may be asked to function, how reporting and assignments are done,” Dr. Hess said. “This is learning how to play nicely in the sandbox.” 

The AVMA Disaster Business Continuity Certificate Program is among coursework approved to be part of the new certificate program for veterinary first responders. The modules focus on planning for business survival during a disaster, developing a business continuity plan, and implementing the business continuity plan. 

A course from the Texas A&M Veterinary Emergency Team available to Texas A&M veterinary students also has been approved to be part of the AVMA Veterinary First Responder Certificate Program.  

The team was established in 2009 as a deployable veterinary response team at the Texas A&M University College of Veterinary Medicine & Biomedical Sciences, said Dr. Deb Zoran, a teaching and leadership member of the team and a professor at the veterinary college. Following the first major deployment, the team leadership recognized the need for education of future veterinarians in this field and developed a curriculum for a required two-week clinical rotation for fourth-year veterinary students in disaster preparedness and response. 

The Texas A&M curriculum covers most of the core competencies in the AVMA certificate program during the rotation. 

Dr. Zoran said the members of the Texas A&M Veterinary Emergency Team believe that veterinarians should have at least an awareness-level understanding of the Incident Command System and how to integrate into it, understand the importance of personal and practice preparedness, and be able to assist their community through preparedness or response activities that not only protect their practices but also provide for the health and welfare of animals impacted by a disaster. 

“Disasters, whether they be large or small, will impact people and therefore animals,” Dr. Zoran said. “As veterinarians, it is critically important that we are effectively able to integrate into the system of disaster response—for the benefit of animals, for the benefit of their humans, for the protection of your practice and personnel, and for the safety and health of all of us.” 

6. Pharmacy Updates

The Controlled Substances Bard submitted proposed rules to the Legislative Council Clearing House: 

CR 22-032Scheduling serdexmethylphenidate 

CR 22-033Scheduling ten (10) fentanyl-related substances 

CR 22-034Scheduling alfaxalone 

CR 22-035Excluding 6-beta-naltrexol 

CR 22-036Scheduling fospropofol 

DEA hopes to obtain a better understanding of how telepharmacy’s currently working, and what measures DEA must take to ensure that any heightened risks of diversion posed by telepharmacy practice are adequately addressed in our federal regulations.

DEA seeks to work collaboratively with industry, states, and other stakeholders, and would greatly appreciate your input in submitting comments to the Federal Register. If you have any further questions, please contact Scott A. Brinks or Heather Achbach, Regulatory Drafting and Policy Support Section, Diversion Control Division (DPW) at