AB 814—ANIMAL PHYSICAL REHABILITATION
Frequently Asked Questions
Q: What is animal physical rehabilitation?
A: Animal physical rehabilitation is the treatment of injury or illness to address pain and improve function by means of physical corrective treatment. It does not include relaxation, recreational or wellness modalities, including but not limited to massage, athletic training, or exercise. (As defined by the California Veterinary Medical Board’s regulation; adopted in 2022).
Q: What is the education level of a qualified, licensed physical therapist with additional training in animal rehabilitation?
A: To work on humans, current requirements for licensure of a physical therapist in California are the completion of a bachelor’s degree followed by a 3-year clinical doctorate in physical therapy. Following completion of the doctorate, a candidate must then pass both a national and state licensing exam.
AB 814 requires those licensed as physical therapists to undergo animal-specific training to ensure competency in animal specific areas. Qualifying courses are approved by the Registry of Approved Continuing Education (RACE), a program of the American Association of Veterinary State Boards (AAVSB). In addition to coursework, physical therapists must intern with a qualified animal rehabilitation therapist or veterinarian prior to earning their authorization to work on animals.
All competency training to earn authorization in animal physical rehabilitation would be determined by the California Veterinary Medical Board (CVMB) and Physical Therapy Board of California (PTBC), working collaboratively.
Q: Why is AB 814 so important?
A: California’s statutes and regulations governing animal physical rehabilitation currently limits, rather than expands consumer choices for and access to quality animal rehabilitation.
· The Veterinary field is in crisis. There are not enough DVM's to care for all the animals in need. This bill would allow other qualified and licensed professionals (specifically, licensed physical therapists with advanced training and certification in animal rehabilitation) to help shoulder some of the burden at the referring veterinarian’s discretion. It will allow more consumers to get the care they need for their animals by removing unnecessary barriers to access.
· COVID-19 compounded the issue as did the enactment of new VMB regulations that went into effect in January 2022. Unfortunately, the VMB enacted language that significantly changed the status quo and made access to animal rehab services even worse. Because of the unintended consequences to the VMB’s recent regulatory language relating to animal physical rehabilitation, a statutory change is necessary to solve this access to rehab care issue. Two licensing Boards need legislative guidance to work collaboratively to ensure proper oversight and regulation and AB 814 solves this.
Under existing California law, qualified physical therapists are strictly prohibited from practicing unless they are directly supervised by a veterinarian and restricted to only working on a veterinary premise with a veterinarian onsite.
AB 814 allows licensed physical therapists with additional training specifically on animals to practice under indirect veterinary supervision after a referral by the veterinarian of record has been made. This expands access and choices for consumers, improves interprofessional collaboration between DVMs and PTs, promotes a more competitive marketplace and attracts qualified physical therapists to this growing profession to elevate patient care.
Q: Who has been demanding access to and choice of qualified rehabilitation practitioners?
A: According to the founder of the Canine Rehabilitation Institute, past-President of American Association of Rehabilitation Veterinarians (AARV), long-time board member and past-President of the Veterinary Orthopedic Society (VOS), and the past-Chair of the Residency and Credentials Committee for the American College of Veterinary Sports Medicine and Rehabilitation (ACVSMR), Dr. Janet Van Dyke states, “This is a client-driven industry. The veterinary field is now trying to catch up with their demand for rehabilitation services. Veterinarians recognize that physical therapists bring a skill set to our field that we need.”
The Animal Physical Therapy Coalition is a grassroots coalition comprised of DVMs, PTs, RVTs, consumers, animal welfare organizations, law enforcement/search and rescue canine handlers, and educators who have a like-minded approach for increasing safe access to rehabilitative care by qualified professionals.
Q: Could a physical therapist practice on my animal without my veterinarian’s involvement and supervision? Does this mean I get direct access to an animal PT?
A: No. A consumer may not have direct access to an animal PT.
Rather, this bill requires a veterinarian to:
Q: Physical therapists can’t carry a veterinary premise permit. How do we ensure that premises for animal rehab have oversight for consumer safety?
A: Current law prohibits a licensed PT to carry a veterinary premise permit. A veterinary premise permit is what allows the California Veterinary Medical Board to inspect premises for safety and compliance.
We share these same concerns, which is why AB 814 clearly addresses this by creating an Animal Rehab Premise Permit. This new and conditional permit will allow a qualified and licensed PT to register their animal rehab premise with the Board to allow for inspections to ensure safety for all.
Q: Will veterinarians be liable for anything that an animal physical therapist does after they make the referral given that they will also be providing indirect supervision?
A: No. AB 814 clearly addresses liability and appropriately places responsibility on the treating licensed physical therapist. A veterinarian would never be liable for what a physical therapist does at another facility. It is standard and customary that the licensee providing the care would be liable for the treatment they provide.
Q: It seems like the Veterinary Practice Act definitions of supervision wouldn’t apply to animal physical therapists. Would definitions need to be re-worked in the Practice Act?
A: No. There is a misguided thought that suggests current definitions of direct and indirect supervision would need to change or somehow don’t apply. This is incorrect. AB 814 does not change any existing definitions of direct or indirect supervision. The only aspect that changes is that the veterinarian will be allowed to provide indirect supervision to a licensed and qualified PT because these professionals would be appropriately authorized as legitimate providers within the Act.
Indirect supervision definition already codified means: (1) that the supervisor is not physically present at the location where animal health care job tasks are to be performed, but has given either written or oral instructions (“direct orders”) for treatment of the animal patient; and (2) the animal has been examined by a veterinarian at such times as good veterinary medical practice requires, consistent with the particular delegated animal health care task and the animal is not anesthetized as defined in Section 2032.4.
Q: Animals can’t say where ‘it hurts’; are physical therapists qualified to work on animals?
A: Yes. Licensed physical therapists certified in animal rehabilitation are highly qualified to treat pets, including horses. They have done so for decades and have a demonstrated record of success. To become certified, physical therapists receive training on animal pain recognition, animal behavior, animal handling, comparative animal anatomy and physiology, comparative biomechanics, animal pathology, animal infectious diseases, musculoskeletal imaging, and much more. They learn how to identify red flags for pets who would need to be referred back to their primary veterinarian. All advanced training courses available today to meet the competencies stated above are reviewed and approved by the Registry of Approved Continuing Education (RACE), a program overseen by the American Association of Veterinary State Boards (AAVSB). In addition to coursework, physical therapists are required to intern with a qualified animal rehabilitation therapist or veterinarian prior to earning their certification to work on animals. Details of this additional coursework would be determined by both the CVMB and the Physical Therapy Board of California working collaboratively.
Q: As a consumer, how would I know this proposal protects animal safety?
A: A few things point to the success and safety of animal rehabilitation provided by licensed physical therapists with advanced training/certification in animal rehabilitation. First, eight states—Colorado, Nevada, Nebraska, New Hampshire, Utah, Illinois, Oregon, and Virginia—have already adopted indirect supervision models of health care for animal physical rehabilitation. Second, after over 100 aggregate years of exposure to this model, no consumer complaints or disciplinary actions have been taken against a qualified physical therapist working in a state that operates under indirect supervision. Instead, the demand for services has grown and animal rehabilitation in states such as Colorado are flourishing as a result.
Interprofessional collaboration between DVMs and PTs will elevate patient care and is consistent with the One Health Initiative.
Q: Should I be worried if my licensed physical therapist certified in animal rehabilitation works at their own business premises, and not at the veterinarian’s office? Will AB 814 allow animal rehabilitation practice on an unregistered facility?
A: No. You should not worry any more than you would about your own physical therapist practicing at their facilities. As with our own medical care, when caring for pets it’s important for consumers to take the necessary precautions to educate themselves on the quality of services provided by an individual practitioner. AB 814 bolsters safety further by permitting licensed physical therapists certified in animal rehabilitation to only operate on premises that meet state health and safety standards determined by the CVMB. The animal physical rehabilitation premises would be subject to inspections by the Board to ensure public safety.
Q: Will AB 814 take away privileges from licensed DVM’s or RVT’s?
A: This statute makes no changes to the way RVTs currently practice. It does, however, increase the options for veterinarians looking for qualified therapists to treat their patients. Veterinarians have been asking to increase their ability to inter-professionally collaborate with animal PT’s.
Q: Would AB 814 increase job opportunities for RVTs and others?
A: Yes. RVT’s and others would be able to work under the direct supervision of a qualified physical therapist.
Q: My veterinarian has a physical therapist working on her premises; would this prevent me from obtaining physical rehabilitation services at her location?
A: No. This bill expands consumer choice; it does not restrict choice. You would still be able to receive animal physical rehabilitation on a veterinarian’s premises if offered. In the event that animal rehabilitation services are not provided at your veterinarian’s office, you could seek treatment by a licensed physical therapist certified in animal rehabilitation who is working at an animal physical rehabilitation facility that meets health and safety standards or in a mobile setting with oversight by the CVMB.
Q: Why does the California Veterinary Medical Association (CVMA) and National Veterinary Technician Association (NAVTA) oppose AB 814?
A: The CVMA and NAVTA are trade associations organized to protect the interests of veterinarians and veterinary technicians respectively. They are accustomed to hierarchal control over pet health care. Animal health care has been slow to shift toward the delivery of collaborative health care services among allied professionals and this has led to a reduction in consumer choices. Keep in mind, it is unrealistic to think that consumers and pets can get 100% of their health care needs met at their local veterinarian’s office. Instead, California consumers should be provided opportunities to access a broader array of qualified animal health care options, including animal physical rehabilitation, just as they are able to do for their own health care.
Frequently Asked Questions
Q: What is animal physical rehabilitation?
A: Animal physical rehabilitation is the treatment of injury or illness to address pain and improve function by means of physical corrective treatment. It does not include relaxation, recreational or wellness modalities, including but not limited to massage, athletic training, or exercise. (As defined by the California Veterinary Medical Board’s regulation; adopted in 2022).
Q: What is the education level of a qualified, licensed physical therapist with additional training in animal rehabilitation?
A: To work on humans, current requirements for licensure of a physical therapist in California are the completion of a bachelor’s degree followed by a 3-year clinical doctorate in physical therapy. Following completion of the doctorate, a candidate must then pass both a national and state licensing exam.
AB 814 requires those licensed as physical therapists to undergo animal-specific training to ensure competency in animal specific areas. Qualifying courses are approved by the Registry of Approved Continuing Education (RACE), a program of the American Association of Veterinary State Boards (AAVSB). In addition to coursework, physical therapists must intern with a qualified animal rehabilitation therapist or veterinarian prior to earning their authorization to work on animals.
All competency training to earn authorization in animal physical rehabilitation would be determined by the California Veterinary Medical Board (CVMB) and Physical Therapy Board of California (PTBC), working collaboratively.
Q: Why is AB 814 so important?
A: California’s statutes and regulations governing animal physical rehabilitation currently limits, rather than expands consumer choices for and access to quality animal rehabilitation.
· The Veterinary field is in crisis. There are not enough DVM's to care for all the animals in need. This bill would allow other qualified and licensed professionals (specifically, licensed physical therapists with advanced training and certification in animal rehabilitation) to help shoulder some of the burden at the referring veterinarian’s discretion. It will allow more consumers to get the care they need for their animals by removing unnecessary barriers to access.
· COVID-19 compounded the issue as did the enactment of new VMB regulations that went into effect in January 2022. Unfortunately, the VMB enacted language that significantly changed the status quo and made access to animal rehab services even worse. Because of the unintended consequences to the VMB’s recent regulatory language relating to animal physical rehabilitation, a statutory change is necessary to solve this access to rehab care issue. Two licensing Boards need legislative guidance to work collaboratively to ensure proper oversight and regulation and AB 814 solves this.
Under existing California law, qualified physical therapists are strictly prohibited from practicing unless they are directly supervised by a veterinarian and restricted to only working on a veterinary premise with a veterinarian onsite.
AB 814 allows licensed physical therapists with additional training specifically on animals to practice under indirect veterinary supervision after a referral by the veterinarian of record has been made. This expands access and choices for consumers, improves interprofessional collaboration between DVMs and PTs, promotes a more competitive marketplace and attracts qualified physical therapists to this growing profession to elevate patient care.
Q: Who has been demanding access to and choice of qualified rehabilitation practitioners?
A: According to the founder of the Canine Rehabilitation Institute, past-President of American Association of Rehabilitation Veterinarians (AARV), long-time board member and past-President of the Veterinary Orthopedic Society (VOS), and the past-Chair of the Residency and Credentials Committee for the American College of Veterinary Sports Medicine and Rehabilitation (ACVSMR), Dr. Janet Van Dyke states, “This is a client-driven industry. The veterinary field is now trying to catch up with their demand for rehabilitation services. Veterinarians recognize that physical therapists bring a skill set to our field that we need.”
The Animal Physical Therapy Coalition is a grassroots coalition comprised of DVMs, PTs, RVTs, consumers, animal welfare organizations, law enforcement/search and rescue canine handlers, and educators who have a like-minded approach for increasing safe access to rehabilitative care by qualified professionals.
Q: Could a physical therapist practice on my animal without my veterinarian’s involvement and supervision? Does this mean I get direct access to an animal PT?
A: No. A consumer may not have direct access to an animal PT.
Rather, this bill requires a veterinarian to:
- Establish a veterinary-client-patient-relationship (VCPR)
- Do a hands-on examination of the animal patient
- Diagnose injury/disease
- Determine if PT is appropriate
- Determine the appropriate level of supervision (whether that be direct or indirect)
- Refer their animal patient to a qualified animal PT who holds an APR premise permit
Q: Physical therapists can’t carry a veterinary premise permit. How do we ensure that premises for animal rehab have oversight for consumer safety?
A: Current law prohibits a licensed PT to carry a veterinary premise permit. A veterinary premise permit is what allows the California Veterinary Medical Board to inspect premises for safety and compliance.
We share these same concerns, which is why AB 814 clearly addresses this by creating an Animal Rehab Premise Permit. This new and conditional permit will allow a qualified and licensed PT to register their animal rehab premise with the Board to allow for inspections to ensure safety for all.
Q: Will veterinarians be liable for anything that an animal physical therapist does after they make the referral given that they will also be providing indirect supervision?
A: No. AB 814 clearly addresses liability and appropriately places responsibility on the treating licensed physical therapist. A veterinarian would never be liable for what a physical therapist does at another facility. It is standard and customary that the licensee providing the care would be liable for the treatment they provide.
Q: It seems like the Veterinary Practice Act definitions of supervision wouldn’t apply to animal physical therapists. Would definitions need to be re-worked in the Practice Act?
A: No. There is a misguided thought that suggests current definitions of direct and indirect supervision would need to change or somehow don’t apply. This is incorrect. AB 814 does not change any existing definitions of direct or indirect supervision. The only aspect that changes is that the veterinarian will be allowed to provide indirect supervision to a licensed and qualified PT because these professionals would be appropriately authorized as legitimate providers within the Act.
Indirect supervision definition already codified means: (1) that the supervisor is not physically present at the location where animal health care job tasks are to be performed, but has given either written or oral instructions (“direct orders”) for treatment of the animal patient; and (2) the animal has been examined by a veterinarian at such times as good veterinary medical practice requires, consistent with the particular delegated animal health care task and the animal is not anesthetized as defined in Section 2032.4.
Q: Animals can’t say where ‘it hurts’; are physical therapists qualified to work on animals?
A: Yes. Licensed physical therapists certified in animal rehabilitation are highly qualified to treat pets, including horses. They have done so for decades and have a demonstrated record of success. To become certified, physical therapists receive training on animal pain recognition, animal behavior, animal handling, comparative animal anatomy and physiology, comparative biomechanics, animal pathology, animal infectious diseases, musculoskeletal imaging, and much more. They learn how to identify red flags for pets who would need to be referred back to their primary veterinarian. All advanced training courses available today to meet the competencies stated above are reviewed and approved by the Registry of Approved Continuing Education (RACE), a program overseen by the American Association of Veterinary State Boards (AAVSB). In addition to coursework, physical therapists are required to intern with a qualified animal rehabilitation therapist or veterinarian prior to earning their certification to work on animals. Details of this additional coursework would be determined by both the CVMB and the Physical Therapy Board of California working collaboratively.
Q: As a consumer, how would I know this proposal protects animal safety?
A: A few things point to the success and safety of animal rehabilitation provided by licensed physical therapists with advanced training/certification in animal rehabilitation. First, eight states—Colorado, Nevada, Nebraska, New Hampshire, Utah, Illinois, Oregon, and Virginia—have already adopted indirect supervision models of health care for animal physical rehabilitation. Second, after over 100 aggregate years of exposure to this model, no consumer complaints or disciplinary actions have been taken against a qualified physical therapist working in a state that operates under indirect supervision. Instead, the demand for services has grown and animal rehabilitation in states such as Colorado are flourishing as a result.
Interprofessional collaboration between DVMs and PTs will elevate patient care and is consistent with the One Health Initiative.
Q: Should I be worried if my licensed physical therapist certified in animal rehabilitation works at their own business premises, and not at the veterinarian’s office? Will AB 814 allow animal rehabilitation practice on an unregistered facility?
A: No. You should not worry any more than you would about your own physical therapist practicing at their facilities. As with our own medical care, when caring for pets it’s important for consumers to take the necessary precautions to educate themselves on the quality of services provided by an individual practitioner. AB 814 bolsters safety further by permitting licensed physical therapists certified in animal rehabilitation to only operate on premises that meet state health and safety standards determined by the CVMB. The animal physical rehabilitation premises would be subject to inspections by the Board to ensure public safety.
Q: Will AB 814 take away privileges from licensed DVM’s or RVT’s?
A: This statute makes no changes to the way RVTs currently practice. It does, however, increase the options for veterinarians looking for qualified therapists to treat their patients. Veterinarians have been asking to increase their ability to inter-professionally collaborate with animal PT’s.
Q: Would AB 814 increase job opportunities for RVTs and others?
A: Yes. RVT’s and others would be able to work under the direct supervision of a qualified physical therapist.
Q: My veterinarian has a physical therapist working on her premises; would this prevent me from obtaining physical rehabilitation services at her location?
A: No. This bill expands consumer choice; it does not restrict choice. You would still be able to receive animal physical rehabilitation on a veterinarian’s premises if offered. In the event that animal rehabilitation services are not provided at your veterinarian’s office, you could seek treatment by a licensed physical therapist certified in animal rehabilitation who is working at an animal physical rehabilitation facility that meets health and safety standards or in a mobile setting with oversight by the CVMB.
Q: Why does the California Veterinary Medical Association (CVMA) and National Veterinary Technician Association (NAVTA) oppose AB 814?
A: The CVMA and NAVTA are trade associations organized to protect the interests of veterinarians and veterinary technicians respectively. They are accustomed to hierarchal control over pet health care. Animal health care has been slow to shift toward the delivery of collaborative health care services among allied professionals and this has led to a reduction in consumer choices. Keep in mind, it is unrealistic to think that consumers and pets can get 100% of their health care needs met at their local veterinarian’s office. Instead, California consumers should be provided opportunities to access a broader array of qualified animal health care options, including animal physical rehabilitation, just as they are able to do for their own health care.