A couple years ago, we published blog post entitled, “Veterinary Medical Board Taboo: ‘Veterinary Technician.’” (https://simasgovlaw.com/media/blog/veterinary_technician/) In that, we discussed Business and Professions Code section 4893.5 which states:
No person shall use the title “registered veterinary technician” or “veterinary technician,” or any other words, letters, or symbols, including, but not limited to, the abbreviation “R.V.T.,” with the intent to represent that the person is authorized to act as a registered veterinary technician, unless that person meets the requirements of Section 4839.
This code section became effective January 1, 2011, and yet we still see so much misuse of the title by veterinarians and by the people claiming to be “technicians” themselves, despite the risk of disciplinary action by the Veterinary Medical Board (“Board”).
Section 2034 of Article 4 of Division 20 of the California Code of Regulations, defines an “R.V.T.” as a “registered veterinary technician certified by the Board.” A person who is not an R.V.T. is an “unregistered assistant.” These titles delineate the authority granted to the person by the Board, and the differentiate the types of tasks each position is legally allowed to perform.
Tasks for Unregistered Assistants
Under section 2036.5 of the California Code of Regulations, an unregistered assistant is prohibited from performing surgery, diagnosis and prognosis of animal diseases, or proscribing drugs, medicines or appliances. An unregistered assistant may administer a controlled substance, but only under the direct supervision of a licensed veterinarian or registered technician. In addition, unregistered assistants may perform “auxiliary animal health care tasks,” under the direct or indirect supervision of a licensed veterinarian or the direct supervision of an R.V.T.
“Auxiliary animal health care tasks” is not defined in the regulations, but the Board has explicitly stated unregistered assistants are allowed to perform micro-chipping and rabies vaccination administration under the above specified supervision.
To avoid unlicensed practice violations, you should speak to an attorney at Simas & Associates, Ltd. regarding staff titles, duties, and job descriptions.