The Veterinary Medical Board (VMB) has proposed a regulatory action to adopt a new section that they believe will better protect animal patients and California consumers.  The proposed regulation will allow licensed physical therapists and registered veterinarian technicians to perform animal rehabilitation under the direct supervision of a veterinarian.
Currently, Animal Rehabilitation is considered a subset of the practice of veterinary medicine, and may only be performed by a licensed veterinarian.  You may be wondering, what exactly is animal rehabilitation?  In short, it’s physical therapy for pets.  This type of therapy may be prescribed to help animals recover from injuries or manage other ailments.
The Veterinary Medical Board defines Animal Rehabilitation as:

The use of the physical, chemical, and other properties of thermal, magnetic, biofeedback technology, hydrotherapy (such as underwater treadmills), electricity, sound, therapeutic massage, manual therapy, and active, passive, and resistant exercise for the prevention, cure, or relief of a wound, fracture, bodily injury, or disease of animals.  AR [animal rehabilitation] includes evaluation, treatment, instruction, and consultative services.

The adoption of the new provision will set forth requirements for veterinarians to remain responsible for the clinical judgment of a patient where Animal Rehabilitation is advised or recommended.  The veterinarian must first have examined the animal, and have sufficient information to make a diagnosis, and form a treatment plan.  The treatment plan must include making a determination that the rehabilitation therapy will not harm the animal or exacerbate its condition. Only then may the veterinarian work with a physical therapist or registered veterinarian to set out a treatment plan.  The new provision requires a veterinarian to be physically present while the treatment is administered.
Proponents of the new provision feel that the imposition of this regulation limits the type of care available to pet owners.  Some fear that by expanding the definition of animal rehabilitation to include services such as pet massage, pet owners will be less likely, and less able, to provide relief for their suffering pets.  Some feel the provision allows the VMB to overreach, causing a negative effect on pet owners who would like to receive care for their pets, but may not be able to afford to pay a veterinarian’s office to perform these services.  Suggestions have been made that the VMB modify the language of the provision to omit certain types of treatments, such as massage, so that other properly trained professionals may provide these services at a more affordable cost.
The VMB feels that this subsection enhances public safety by limiting the professionals that may engage in animal rehabilitation to only those who are qualitied to do so.  The VMB purports to be expanding the availability of these types of services, but are they really just expanding the types of services they can regulate?  The VMB feels that it is crucial that a veterinarian be physically present at all animal rehabilitation sessions in case an animal has an adverse reaction to the therapy, or proves hard to control; but also to ensure that the treatments are properly documented.  Should there also be provisions allowing for other properly trained professionals to administer physical therapy for your pet, effectually creating a veterinary counterpart for Physical Therapists?
According to the VMB, they feel that there is a grave danger to the public and the animals by many unlicensed and unauthorized individuals and groups practicing Animal Rehabilitation.  They feel that there is a lack of oversight of the activity and therefore no check on the quality of services offered.  The VMB does not say whether this has been an issue, or if it is a perceived problem that may or may not arise.  The VMB claims to be acting out of concern that an animal could be injured or killed by an unlicensed practitioner and the owner would have little recourse, whereas as a licensed professional would face discipline through their licensing agency if they were not to take the appropriate steps in providing Animal Rehabilitation.
To date, the provision has not been codified, but it has the support of the VMB, as well as the California Veterinary Medical Association, and we can expect to hear more about this issue in the future.
Helpful links:

  • https://www.vmb.ca.gov/laws_regs/arehab_notice.pdf
  • https://www.change.org/p/california-veterinary-medical-board-allow-pet-massage-redefine-animal-rehabilitation
  • https://cvma.net/wp-content/uploads/2015/08/FinalARlettertoVMB_8_2015.pdf
  • https://govt.westlaw.com/calregs/Browse/Home/California/CaliforniaCodeofRegulations?guid=I8EB03CE0D48F11DEBC02831C6D6C108E&originationContext=documenttoc&transitionType=Default&contextData=(sc.Default)