In the VIN News Service article CSU readies to train first veterinary midlevel practitioners (Feb. 18), Colorado State University representatives describe opposition to CSU's Master's in Veterinary Clinical Care and the Veterinary Professional Associate (VPA) as rooted in "misperceptions." That characterization is inaccurate. The concerns raised by the American Veterinary Medical Association, the Colorado Veterinary Medical Association and an overwhelming majority of veterinarians (95% in Colorado) and veterinary technicians are not based on confusion. They reflect substantial deficiencies in the program's justification, scope and design.

After a careful review of the curriculum, regulatory frameworks and defined scopes of practice for veterinary professionals, we concluded that the VPA role overlaps existing skill sets without delivering the access-to-care benefits its proponents promise while introducing considerable risk.

Despite the suggestion by the master's program director Dr. Shari Lanning that we have not engaged, at our request, AVMA leadership traveled to Colorado to meet in person with CSU's president, provost and the dean of the College of Veterinary Medicine and Biomedical Sciences in April 2024, alongside Colorado VMA representatives and veterinarian-legislator Dr. Karen McCormick. We also provided detailed written analyses for them and the CSU Board of Governors outlining our specific concerns.

The concerns we raised, summarized below, remain unresolved.

The VPA cannot establish a VCPR and cannot prescribe.

A VPA cannot establish a veterinarian-client-patient relationship (VCPR) and does not have independent prescribing authority. These are not minor technicalities — they are foundational to veterinary practice. The VCPR is the legal and ethical basis for diagnosis, treatment and prescribing. Without it, a clinician cannot manage a case.

Because a VPA cannot establish a VCPR or prescribe medications, every patient encounter ultimately requires a licensed veterinarian to authorize care. That reality fundamentally contradicts claims that this role will meaningfully expand access to care. It does not create independent clinical capacity; it creates a dependent role that cannot function without a veterinarian's involvement.

In underserved areas where veterinarians are already scarce, this model offers no practical solution. Moreover, rural shortages are most acute for large animal and mixed animal practice. Training a new midlevel provider focused on cats and dogs does not address these workforce gaps.

The program lacks sufficient educational depth.

The proposed curriculum comprises approximately 65 credit hours — roughly half the academic preparation of a DVM program and fewer than many veterinary technology programs. It includes a mere three semesters of online, lecture-only instruction, conducted across three half-days a week with no in-person laboratory, which is followed by one semester of highly condensed clinical skills training at CSU (everything from completing a basic physical exam to delivering anesthesia and performing surgery) and a short off-site practicum. Students are introduced to clinical subjects before mastering core biomedical sciences such as anatomy, physiology and pharmacology. Sound clinical judgment depends on deep integration of foundational sciences with hands-on experience. Compressing and accelerating that preparation does not create a competent practitioner — it produces gaps.

Proponents suggest the VPA will handle "routine" or "uncomplicated" conditions. In real-world practice, there is no bright line between routine and complex. Wellness visits frequently uncover systemic disease or anesthetic risk. Even "routine" surgery can become life-threatening within minutes. The ability to anticipate, recognize and manage complications is not an optional add-on; it is central to safe practice and patient welfare.

Supervision does not eliminate risk — it transfers it.

Supporters emphasize that VPAs would work under veterinary supervision. Given that VPAs cannot establish a VCPR or prescribe, supervision would not be occasional; it would be structurally required for every case. The supervising veterinarian would retain responsibility for diagnosis confirmation, treatment authorization, prescribing and outcomes.

In practice, this means veterinarians — already facing workforce pressures — would assume expanded liability for decisions made by individuals with inadequate training. That is not workforce relief; it is amplified risk.

In rural or underserved communities, where recruiting veterinarians is already difficult, a supervisory model that presumes the availability of veterinarians cannot solve a shortage of them.

Portability, professional viability and advancement remain limited.

The VPA role does not exist elsewhere in the United States. Graduates would not be eligible for licensure outside Colorado under current regulatory systems. 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.

Furthermore, the program is described as expanding opportunity for veterinary technicians, yet most credentialed veterinary technicians do not hold a bachelor's degree, the stated prerequisite for entry. Therefore, this is not a viable advancement pathway for the vast majority of veterinary technicians.

There are better, evidence-based alternatives.

Access-to-care challenges are real and deserve serious solutions. Creating a new veterinary practitioner with overlapping but restricted authority (meaning, unable to create a VCPR or prescribe) does not resolve access-to-care challenges. Instead, it introduces unnecessary complexity and regulatory ambiguity, significant risks for veterinary patients and additional liability for veterinarians.

We support thoughtful, data-driven solutions that expand access and strengthen the veterinary workforce, while maintaining an uncompromising commitment to patient safety and quality of service. More than 200 accredited veterinary technology programs graduate approximately 5,500 veterinary technicians each year. Fully integrating these professionals more effectively into team-based care models and creating meaningful advancement pathways can improve practice efficiency, support recruitment and retention, and improve access to care without fragmenting clinical authority, diluting accountability or placing patients and client trust at risk. Additional constructive strategies are already underway, including expanding class sizes at accredited colleges of veterinary medicine and supporting the development of new programs through established accreditation pathways addressing economic and geographic barriers to practice.

Veterinarians take an oath to protect animal health and welfare, promote public health and relieve animal suffering. That obligation demands rigorous education, clear accountability and unambiguous clinical authority. The VPA weakens these guardrails while offering no demonstrable benefit.

The profession's concerns are not rooted in misperception. They are rooted in patient safety, legal clarity and responsible workforce policy. Proposals that alter who may diagnose, treat or perform surgery must meet the highest evidentiary and educational standards. The VPA, as currently structured, does not.

Michael Q. Bailey, DVM, DACVR, is president of the American Veterinary Medical Association.