California veterinarian Dr. Sarah Gottschalk regularly provides health certificates for small animals traveling out of state. She does it for clients who are traveling with their pets and for rescue groups and breeders.
The process is routine: One of her technicians obtains a U.S. Department of Agriculture Certificate of Veterinary Inspection (CVI), known as Form 7001. Gottschalk examines the animal, and if everything looks good, she completes and issues the CVI.
This simple system hit a snag in January when Gottschalk learned that some states aren’t accepting the forms anymore. The problem is that the forms, originally developed in a multi-page carbon-copy format available only to state-licensed, USDA-accredited veterinarians, now can be downloaded from the internet by anyone. State veterinarians cite concerns that the PDF forms are vulnerable to unauthorized and fraudulent use.
In the first three months of this year, Washington, Colorado, Georgia, Nebraska, Illinois and Nevada announced they would no longer accept 7001s, bringing the total number of states disallowing the forms to 16. At least eight other states are poised to discontinue the practice, or are considering discontinuing the practice, the VIN News Service determined. Three states do not require CVIs for most small domestic animals brought into the state.
Even in the 23 states that technically accept the forms, many state veterinarians discourage their use and encourage veterinarians to embrace more secure alternatives.
The disallowance of the once ubiquitous form leaves some veterinarians with questions and frustrations.
“My experience from the ground floor is that the states who aren’t recognizing 7001s have legitimate security concerns,” Gottschalk said. “But the transition to a more secure form of health certificate is spectacularly disorganized.”
In part, that’s because each state sets its own rules and standards. Forty-eight require some sort of CVI for some small animals (such as dogs, cats, ferrets, rodents and others) entering the state. CVIs affirm that a state-licensed, USDA-accredited veterinarian has examined an animal and found it healthy for travel in the United States.
That’s not to say that all pet owners actually go through the process of getting a CVI when they take their animals over state lines, especially when traveling by car. (Livestock is a whole other category. Covered by the USDA’s Animal Disease Traceability rule, livestock is not affected by these recent developments.)
The USDA form is still the most common document used for the interstate transport of companion animals, according to Joelle Hayden, a spokesperson for USDA Animal and Plant Health Inspection Service.
“The original 7001 form was developed in 1989 for use in typewriters or to fill in by hand,” Hayden said. Only licensed, USDA-accredited veterinarians could order these paper forms, each of which was printed with a unique identifying number. But with the rise of digital technology, Hayden said, the agency “received many requests to provide a fillable, electronic form.” This unnumbered, downloadable PDF is now commonly used. APHIS stopped printing the multi-page forms in 2011, although they are still in circulation.
“It is up to the States to determine what documentation they will accept for interstate transport of companion/small animals,” Hayden said.
The main reason states say they have turned against the 7001 is that everyone — veterinarians or not — can get their hands on it.
In January, Washington state veterinarian Dr. Brian Joseph sent a letter to his counterparts in every other state. “The APHIS Form 7001 will no longer be accepted by the Department due to the free access to the public for download off the internet without any accountability as to who receives or uses the form,” he wrote.
Other states have been concerned for a while and even seen fraud in action.
“There have been cases where puppy-mill owners downloaded the form, filled it out, and forged a veterinarian’s name on it as a way to ship puppies or dogs that had not been examined by a veterinarian,” said Dr. Rod Hall, Oklahoma state veterinarian. Oklahoma has discouraged the use of 7001 forms for at least five years.
Because they are not subject to interstate animal disease traceability rules like livestock, tracking the movement of pets across state lines has not been a priority for governments. That's changing. “Due to the mass movement of rescue animals, we are concerned about transmission of diseases, such as canine influenza,” said Dr. Diane Stacy, assistant state veterinarian for Louisiana, “and we need to be certain that a veterinarian has examined the animals and determined that they are healthy for travel into our state.” Louisiana will stop accepting the 7001 in the near future.
As an alternative to the USDA form, nearly all states provide accredited veterinarians with paper CVIs for small animals. These are accepted by all the other states that require CVIs. Depending on the state, these can be ordered by phone, fax or online, which is not nearly as easy as simply downloading and printing out a form. Some are provided for free, some for the cost of shipping and others for a fee. Some states, such as Hawaii, traditionally have offered free paper forms to in-state vets but may start charging if demand increases as more states stop accepting the 7001. In addition, several states have developed web-based eCVIs, available to licensed, USDA-accredited in-state veterinarians.
A few states are outliers. Texas, for example, has never required CVIs for small animals coming into the state, nor does it provide CVIs for companion animals leaving the state, according to Dr. Susan Culp, staff veterinarian for the Texas Animal Health Commission.
North Carolina historically depended upon USDA 7001 forms for in-state vets to use for small animal CVIs. But during a review of its rules and regulations last year, North Carolina determined it did not have the authority under state statutes to require health certificates for domestic dogs, cats and ferrets coming into the state nor the authority to provide CVIs to in-state veterinarians for small animals traveling elsewhere in the country.
Neither Montana nor Massachusetts nor New York provides a paper CVI for small animals. “We made the decision years ago that the APHIS Form 7001 was widely available, and we didn’t need to duplicate that effort,” said Dr. David Smith, New York’s state veterinarian. “Now that several states do not recognize the APHIS Form 7001, veterinarians sending animals to those states should avail themselves of one of the electronic options, some of which are available at no charge.”
That suggestion was repeated by many state veterinarians. They argue that eCVIs are a better option: With authentication and unique identifying numbers, they are secure, offer faster dissemination of information (automatically sending copies to appropriate state veterinarians in seconds), and also streamline data-collection and -handling on the state’s end. In addition to state CVIs, there are at least four eCVIs for large and small animals available to accredited veterinarians and in widespread use. One free option is AgConnect mCVI, a mobile application developed by the Institute for Infectious Animal Diseases in partnership with the Texas Center for Applied Technology, a part of the Texas A&M Engineering Experiment Station. Other options are commercially available on a subscription or fee-per-form basis.
California Bay Area veterinarian Dr. Maureen Dorsey recently signed up for the mCVI service but hasn’t put it to use yet. She said that even though she doesn’t do a lot of health certificates, she does enough for the changes to be “a pain.” In the short term, she is taking another tack to avoid the hassle: She’s just not doing health certificates for now.
Editor's note: New Jersey accepts USDA Form 7001 for dogs and cats brought into the state. Based on incorrect information from the state, an earlier version of this article reported New Jersey as among those that do not accept the form.
VIN News Service commentaries are opinion pieces presenting insights, personal experiences and/or perspectives on topical issues by members of the veterinary community. To submit a commentary for consideration, email firstname.lastname@example.org.