It is important for all members in an animal health care team to understand and know their roles. Often a Registered Veterinary Technician (“RVT”) and an unregistered veterinary assistant’s (“assistant”) roles can overlap but a veterinarian or a RVT, may be subject to discipline by the Veterinary Medical Board (“VMB”) for unprofessional conduct if a member of the health care team is performing duties they are otherwise not licensed to perform.

Knowing the Law on Duties of a RVT Versus Unlicensed Assistants

A RVT is an individual that has completed an accredited two or four year program in veterinary technology and has passed a state board examination. Job responsibilities range from technical duties such as nursing care, collection and processing of lab samples, induction and monitoring anesthesia, and radiography, to managerial duties such as ordering and inventory, personnel management, record keeping and client education.

The law varies state to state regarding the tasks a RVT can perform and tasks an assistant can perform. In California, the term “unregistered assistant” means any individual who is not an RVT or a licensed veterinarian,[i] and the term “RVT” means a registered veterinary technician certified by the Board.[ii] Any other employee, regardless of what their title may be, is an unregistered assistant.

    1. Specific Tasks a RVT May Perform

 
Under the Veterinary Medical Board Act, a RVT shall not perform the following functions or any other activity which represents the practice of veterinary medicine or requires the knowledge, skill and training of a licensed veterinarian:

    1. Surgery;
    2. Diagnosis and prognosis
      of animal diseases;
    3. Prescription of drugs, medicines or appliances.[iii]

 
A RVT may perform the following procedures only under the direct supervision of a licensed veterinarian:

    1. Induce anesthesia;
    2. Apply casts and splints;
    3. Perform dental extractions;
    4. Suture cutaneous and subcutaneous tissues, gingiva and oral mucous membranes,
    5. Create a relief hole in the skin to facilitate placement of an intravascular catheter.[iv]

 
A RVT may perform the following procedures under indirect supervision of a licensed veterinarian:

    • Administer controlled substances.[v]

 
Subject to the above-specified tasks, a RVT may perform animal health care tasks under the direct or indirect supervision of a licensed veterinarian. The degree of supervision by a licensed veterinarian over a RVT shall be consistent with standards of good veterinary medical practices.[vi]

    1. Specific Tasks an Unlicensed Assistant May Perform

 
Unregistered assistants are prohibited from performing any of the functions or activities specified in Section 1 above, except that an unregistered assistant under the direct supervision of a licensed veterinarian or RVT may administer a controlled substance.[vii] Unregistered assistants in an animal hospital setting may perform auxiliary animal health care tasks under the direct or indirect supervision of a licensed veterinarian or the direct supervision of an RVT. The degree of supervision by a licensed veterinarian over an unregistered assistant shall be higher than or equal to the degree of supervision required when a RVT performs the same task and shall be consistent with standards of good veterinary medical practices.[viii]

Problem Areas for Unlicensed Assistants

One of the most frequently recurring problems, especially in small veterinary practices, involves the induction of anesthesia before surgery on a patient. Only a RVT may induce anesthesia under the supervision of a veterinarian. But in many cases, when the Board is reviewing the medical records of a case, the RVT was absent that day or an unlicensed assistant is the one left alone in the room to induce anesthesia. Regardless of the experience level or training of the unlicensed assistant or technician, or even if the technician is only a month away from completion of the RVT program, the Board finds the induction of anesthesia by an unlicensed person to violate the Veterinary Practice Act. Further, when faced with a Board investigation or other review of a veterinarian’s practice, the unlicensed person’s training, experience, or job title does not serve as a defense to these requirements. When looking at the scope of practice, supervision of RVTs, and permissible actions of an unlicensed assistant, the Board means what it says in its regulations. Veterinary practices are encouraged to review the job functions, duties and practice protocols regarding unlicensed assistants on a regular basis to avoid charges from the Board of unprofessional conduct, especially since the one case with a bad outcome is the one the Board will review.


[i] Bus. & Prof. Code, § 2034, subsection (c).
[ii] Id., at subsection (b).
[iii] Bus. & Prof. Code, § 2036, subsection (a)(1)-(3).
[iv] Id., at subsection (b)(1)-(5).
[v] Id., at subsection (c)(1).
[vi] Id., at subsection (d).
[vii] Bus. & Prof. Code, § 2036.5, subsection (a).
[viii] Id., at subsection (b).