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The selection of the American Association of Veterinary State Boards, headquartered in Kansas, to manage credentialing and administer the licensing exam for Colorado's new midlevel role will be under review at a public meeting of the state veterinary medical board next week.
When Colorado veterinary regulators meet on June 11, they won't be hammering out scope-of-practice rules or supervision requirements for what will be the first midlevel position in the United States. Instead, they'll revisit their decision on who will manage credentialing and administer the licensing exam — a determination they thought was settled nearly a year ago.
The U-turn comes as the Colorado State Board of Veterinary Medicine is in the middle of a multi-year process of creating rules for the veterinary professional associate (VPA). Colorado voters passed a citizen initiative in 2024 authorizing the creation of the novel practitioner role, a position that operates under a veterinarian, with a wider scope of practice than that of a veterinary technician. The measure was promoted as a way to make veterinary care more accessible and affordable.
The measure faced opposition from much of the veterinary establishment, including the American Veterinary Medical Association, which argued that delegating veterinarians' tasks to less educated and less experienced individuals would put animals at risk and devalue the role of veterinarians.
While Proposition 129 established the position and follow-up legislation instituted some guidelines, specifics, including veterinarian supervision requirements, scope of practice and a credentialing framework, are to be worked out by veterinary regulators.
In one of their early moves, Colorado regulators last August selected the American Association of Veterinary State Boards (AAVSB) as the entity that would create a means for credentialing and design and administer a licensing exam for what could conceivably apply to VPAs in multiple U.S. states and Canadian provinces, should the position roll out further.
The AAVSB is a nonprofit association comprised of veterinary regulatory boards in the U.S., its territories and Canada. It administers the Veterinary Technician National Exam, which is used by most states and provinces that credential technicians.
After the announcement, the AAVSB moved forward on developing an exam and credentialing process, according to AAVSB CEO James Penrod. A group of individuals was identified to meet in January. They were to perform a job analysis to ensure a future exam is testing relevant practice, a standard step in exam creation, Penrod said.
That effort was disrupted when representatives of member boards voted 42 to 4 to pass Resolution 2025-2 stating that the association would refrain from endorsing the VPA position unless and until sufficient regulatory infrastructure was in place and "broad consensus among member board jurisdictions supports the role as necessary, effective and protective of public and animal interests." The vote was held at an annual member meeting last September.
The resolution did not put constraints on what AAVSB staff could do to assist Colorado in implementing the VPA. However, to some minds, it revealed an anti-VPA bias that should disqualify the organization from serving as a partner.
The AAVSB paused its efforts.
In response to the resolution and complaints, the state veterinary board invited comments and held a meeting in late April to gather input on whether to continue the course with AAVSB or change direction.
The AAVSB resolution "raises serious concerns about its ability to fulfill this role in an objective and supportive manner," Dr. Ali Mickelson, senior director of advocacy and education at Humane Colorado, wrote in a comment submitted to the veterinary board. "This position calls into question whether AAVSB can develop and administer a fair, transparent, and constructive credentialing process."
Letters
Mickelson, who was one of two people to file Proposition 129, was among 36 individuals who submitted comments to regulators about the selection. In a sign of the national interest in the topic, nearly half of the commenters were located outside the state. Support for and opposition to the selection of the AAVSB were roughly equal.
To some, particularly critics of the midlevel role, the AAVSB resolution was a reason to stay the course. "A board to accredit and set standards should not be cherry-picked to have only favorable opinions on [the] VPA," Dr. Sarah Carter, a small animal veterinarian in Michigan, said in a comment.
Penrod, the AAVSB CEO, noted at the meeting in April that there are financial considerations. He said the association had begun the expensive work of creating an exam at no cost to Colorado last summer. "Any other organization," he said, "will need to recover at least a quarter million dollars to take on this task."
Several people said that the selection process needs to be public and deliberate, including by issuing formal requests for proposals, and that the AAVSB could still rise to the top of that more transparent process.
The International Council for Veterinary Assessment, which develops and administers the North American Veterinary Licensing Examination, was suggested as an alternative to, or exam partner for, the AAVSB. Also floated was the North American Veterinary Community. The NAVC is a nonprofit organization that produces online and in-person continuing educational events, including the annual Veterinary Meeting and Expo, better known as VMX, in Florida.
A spokesperson for the NAVC told VIN News last week: "At this time, NAVC will not pursue being the credentialing body for the VPA."
Another strain in public feedback was the idea that the focus on the exam is premature. So far, the veterinary board has yet to settle the prickly questions of scope and supervision. Judging from public comments and responses to early redline drafts of the rules, surgery, prescribing and liability will be hotly contested.
"Scope of practice should be informed by patient care standards, team-based practice, and input from veterinary professionals, rather than being shaped primarily through curriculum or examination design," Erin Henninger, executive director of the Colorado Association of Certified Veterinary Technicians, said in a comment.
A handful of people also used the latest public comment opportunity to express continued antipathy for the VPA.
"If this program goes ahead, I will not spend another red cent on anything from the state of Colorado and will dedicate the rest of my life to tearing down VPAs publicly and privately," Dr. Kennedy Brooks, a veterinarian in Alberta, Canada, wrote.
Who will accredit education?
Mostly absent from the credentialing discussion has been the accreditation of VPA education programs. Colorado statute requires that a VPA must have a master's degree in veterinary clinical care or its equivalent. In the immediate term, the degree-granting program must be approved by the state veterinary board. For those who earn the degree after September 2033, programs must be accredited by a nationally recognized organization that is approved by the board.
Two hybrid (combination online and in-person) master's programs exist. One is at Colorado State University and the other at Lincoln Memorial University, which has campuses in Tennessee and Florida. Both schools will begin their first classes later this year, with the graduates entering the job market in 2027.
The American Veterinary Medical Association, the only accreditor of veterinary education — for veterinarians and veterinary technicians alike — isn't in the mix. Neither CSU nor LMU has approached the AVMA with a request to consider accrediting their respective master's programs, Dr. Jim Weisman, AVMA's chief of academic affairs, research and accreditation, told VIN News by email.
It's probably not an oversight. The AVMA has been an outspoken critic of CSU's master's degree curriculum, including recently in a letter to VIN News from the AVMA president, Dr. Michael Q. Bailey. More generally, the AVMA has actively opposed the adoption of the midlevel role. The organization was by far the top contributor to efforts to defeat Proposition 129, donating more than $2 million in cash and in-kind contributions, according to Ballotpedia, a website that aggregates information on American politics and elections.
Meanwhile, the Coalition for Veterinary Professional Associates, a nonprofit group advocating for the midlevel practitioner role, is working with an accreditor outside the profession, the Commission on Accreditation of Allied Health Education Programs.
"We're in line with CAAHEP for the accreditation process to move fully forward," Dr. Robert Murtaugh, the coalition chair, said recently. CAAHEP, which is recognized by the Council on Higher Education, accredits 31 health science education programs at postsecondary institutions, including in anesthesia, art therapy, cardiovascular technology, diagnostic medical sonography, kinesiotherapy, perfusion, respiratory care, and surgical assisting and technology.
Beyond Colorado
As rulemaking moves forward in the state, questions persist about whether graduates of the CSU and LMU master's programs will be able to find work commensurate with the VPA outside the state.
In various public forums and on its website, CSU has said that veterinary practice acts "in many states" have "exemptions for shelters, allowing a VPA to practice in a shelter hospital."
The claim has been questioned or challenged by practitioners.
In his letter to VIN News, AVMA President Bailey refuted the claim. "Although it has been suggested that the VPA could provide services freely in animal shelters, veterinary practice in shelters or animal control facilities is generally not exempt from state practice acts. While some staff actions may carry limited immunity in certain states, activities constituting the practice of veterinary medicine — such as diagnosis, surgery and prescribing — must still be performed by a licensed veterinarian."
Dr. Miranda Spindel, a Colorado-based shelter medicine consultant at the Veterinary Information Network, parent of VIN News, takes issue with CSU's statement. Although she agrees that shelter staff need to be able to provide medical care under indirect supervision, Spindel said, "Saying that many states have specific exemptions is misleading. A handful mention shelters, but mostly for narrow things like euthanasia or vaccination, not for letting a VPA practice clinically. The role a VPA can play, and under what supervision, will need to be defined state by state."
VIN News reviewed all 50 state practice acts and found that while a number of states let nonveterinarians perform limited tasks in shelters — vaccination, microchipping, administering medication, euthanasia — only Colorado has a provision broad enough to conceivably let a VPA practice clinically. Even states with relatively broad shelter-delegation provisions, such as California and Georgia, expressly bar nonveterinarians from diagnosis, prescribing and performing surgery.
Asked if she could provide more information about state practice acts with "exemptions," CSU master's program director Dr. Shari Lanning did not provide specific examples.
"It is our understanding that other states may already contain partial legal allowances that may allow for VPAs in shelter practices if those practices are operating in jurisdictions that have both provisions for shelters to acquire ownership or legal custody of animals and veterinary practice rules that allow broad supervised delegation," she said in an email response.
In addition, Lanning pointed to "holding period" laws. Such laws give shelters, typically municipal shelters, sole decision-making authority for animals that have been impounded once a holding period has passed. Approximately 38 states and the District of Columbia have holding period laws, according to the Animal Legal and Historical Center at Michigan State University. The laws can vary in terms of species covered, and some local jurisdictions have their own rules.
"A small number of these states also permit varying degrees of veterinary delegation under veterinarian supervision," Lanning told VIN News, "and, of those, Georgia and North Carolina have shelter-specific exemptions for elective sterilization surgery and medical care (e.g., vaccination, euthanasia or emergency treatment).
"These states would likely allow VPAs to practice within eligible shelters, but it is best to check with them directly to confirm."
The Georgia Animal Protection Act provides for nonveterinarians to administer euthanasia with no veterinarian present. The state's veterinary practice act also does "not prohibit" employees of rescues and shelters from administering prescription drugs under the direct or indirect supervision of a licensed veterinarian if they are performing the tasks in compliance with a veterinarian's written protocol and the person has proper training.
In North Carolina, Dr. Patricia Norris, director of that state's Department of Agriculture and Consumer Services animal welfare section, told VIN News there is no allowance for delegating veterinary tasks to nonveterinarians in regard to shelter animals, particularly not surgery. As an example of what is allowed, Norris said a shelter employee could administer antibiotics for an upper respiratory infection in a cat under a veterinarian's standing order.
A different take on the issue of exemptions for shelter animals — whether they should even exist — has shown up in several comments submitted to state veterinary regulators early in the process.
"There should be no special accommodation/designation regarding shelter animals," wrote Dr. Rebecca W. Monahan, a shelter medicine and general practice veterinarian in Colorado. "Animals are animals regardless of who owns them. Whether an animal is owned by a shelter, rescue group, laboratory, military, police force or private client, it deserves to be treated by a qualified professional."
Update: On June 11, the state veterinary medical board voted 6-3 to continue with the AAVSB as the examination entity and to create a memorandum of understanding on expectations for the AAVSB in that role. The MOU, to be drafted by a board subcommittee, is scheduled to be presented for full board review in August. The board also determined that, should the AAVSB not accept the terms of the MOU, it can seek a different licensing partner for the VPA. The regulators pushed the selection of a credentialing body to their August meeting. There was no public comment.