Physical Therapy and Animal Rehabilitation - CALIFORNIA

The consumers, most vets in attendance, physical therapists, and other healing arts professionals spoke loud and clear in today's public hearing in Sacramento. There was clear majority of opposition which cannot be ignored!

Thank you everyone for your support! The petition will be submitted to the CA VMB tomorrow morning and will formally close by 4:49:49pm 9/10/15. A final copy of signatures will be emailed to the CA VMB by the 5:00pm deadline.

Hell no!!!!!!! Where's the other petition to sign for this NOT to happen? Time to leave California if this is the case. Especially in the case where pets are "property" in this state-there should be no governance here in where I take my pet family member to be treated.

Since 2010 the VMB Multi Disciplinary Committee has been working with the CVMA task force to establish guidelines and evaluate Animal Rehabilitation in California. They have reported several times to the VMB of their findings, including two public meetings in January and April of this year, 2015. For a detailed and accurate representation of information please visit the page: http://www.vmb.ca.gov/laws_regs/arehab_isr.pdf This will give you factual information regarding what has transpired over the last 5 years and reasons behind the decisions we see in Title 16. division 20. article 4 CCR section 2038.5 Thank you for the support of this important legislation to safeguard the direct role of the veterinarian in Animal Rehabilitation.

DO NOT SUPPORT THIS PETITION. The proposed dialog exhibits no clarification regarding qualifications of persons, RVTs, PTs, and Veterinarians, performing animal rehabilitation. Thus, the proposed language does nothing to offer more to protection for the consumer and patient. Effectively, the proposed language would condemn many licensed professionals who have been working in the arena of AR - without being supervised by a veterinarian – for many years. Citing AR as being “harmful if not supervised by a veterinarian”, but not clarifying the AR qualifications of the supervising veterinarian, NOR accepting the competency of the RVT/PT, does not make sense for the purpose intended. Citing that AR can only be performed by a California licensed Veterinarian, Registered Veterinary Technician, Physical Therapist, but not clarifying the competency requirements – also does not make sense for the intended purpose.

If my name shows up in support of this ipetition, do not count it! I do not support this petition. I support the freedom to choose your own healthcare practitioner for your pet with regulations that make sense to protect the consumer from "bad actors". Monopolization of animal healthcare is not the answer. I urge people to understand this issue before signing and consider this petition instead. Please be informed first instead of giving up your right to choose. http://www.ipetitions.com/petition/physicaltherapyforanimals/

I do not agree or support this as it would severely restrict cheaper access to alternative health care and also affect thousands of jobs. Do NOT support as I stated in my comment but clearly that does not show up as a negative when you sign this petition. DON'T SIGN IT!

According to Business and Professions Code 4826 "treatment of whatever nature for the prevention...or relief...of animals” falls under the practice of Veterinary Medicine. If the Animal Rehabilitation (AR) proposed regulations pass, with the current language, many jobs will be eliminated in California. Has the California Veterinary Medical Board (CVMB) consider the impact this will have on many other working professionals that provide services to animals? The regulations specifically state that no one can exercise an animal or massage them, even for prevention, unless a veterinarian, or RVT or PT provides those services and only if the veterinarian is present. There are many forms of active exercise administered by trainers in the canine and equine world (Ok bunny, rat and pig world too since they are participating in formal exercise in some places as well ☺). Some examples include agility, flyball, dressage, core strengthening, balance and body awareness training, and even activities performed by pet sitters/walkers, would be included and illegal unless the ‘trainers’ were of the above listed licensed professionals and of course a vet was present. What will happen with any professional that “administers an appliance” (also considered part of Veterinary Medicine) like an orthotist that makes a brace for a dog’s joint problem? What about practitioners like massage therapists that utilize hands on techniques like Reiki, Healing Touch and Acupressure since they are used for prevention or relief? "The Veterinary Medical Board does not have the power to require any specific training of PTs.” The CVMB has the authority to require whatever training it considers to be appropriate for anyone practicing veterinary medicine. They may not be able to require training for PTs practicing outside that framework, but they can absolutely make a certain level of competency a requirement for certification under their authority. Oversight is very important. The pr

Perhaps my statement about untrained vets was not clear. I absolutely did NOT intend to communicate that ALL vets were untrained in rehab. Some vets have been trained in rehab, but since rehab is not part of the veterinary curriculum, it means that the vast majority of vets are untrained in this specialty niche of animal care. Those that have committed their careers and taken coursework to learn some of what physical therapy is about is wonderful! The problem is, most vets are untrained in rehab, so it does not make sense that they supervise an area of animal care that they have not been taught. The solution is quite simple...and we have brought it up numerous times before...set competency standards to allow qualified practitioners to practice under indirect supervision. Leaders in the field are saying the same thing. The leaders in the field recognize the importance for collaboration. Colorado and Nevada have already done it. The trend has been set, and this is inconsistent with the trend of how animal rehab should be regulated. My responses are to provide information to the public...there is a better way to protect the public than this regulation which will take PT's out of the field altogether, limit consumer choice, and drive up rehab costs.

I have been working in the field of animal rehabilitation and veterinary medicine for nearly 15 years and have been able to watch the field grow exponentially. As a registered veterinarian technician I have a unique role in the rehabilitation and veterinary care team, which can often times include a multitude of professionals - but it always starts and ends with the veterinarian. As much as I would like to say the physical therapist and veterinary technician should be granted indirect access to Animal Rehabilitation patients, I just cannot. The magnitude of responsibility to the clients and the patient is so enormous that the veterinarian that should remain on the premises. Through my experience over the years I have had a multitude of patients on a daily basis that require some form of veterinary care immediately. It may not always have been an emergency, but in veterinary medicine the pet owner expects all concerns with their animals to be treated as an emergency no matter how small. For example a patient may arrive at the rehabilitation facility and the client casually mentions their pets urine smells and they have not eaten well yesterday, but seems totally fine today. That same pet owner expects the scheduled treatment to carry on as planned. Most professionals would be alerted that this could indicate a potential urinary tract infection or some other physical abnormality and should be addressed immediately. The patient should not participate in any animal rehabilitation therapy that until a cause of the reported abnormalities from the pet owner are addressed by a veterinarian at the time of visit. By stating the client can simply go to their regular veterinarian as a referral from a rehabilitation provider to follow up on the problems is unacceptable. The referring veterinarian probably would not have a appointment slot the same day or even the next day which could result in a catastrophic situation. In addition, the client would have to pay another ph

Erin Troy's comments would be accurate if we were asking the VMB to allow any PT or RVT to practice AR, and just wanting to do away with 'direct supervision.' But in fact, the VMB is failing to its job of protecting consumers precisely because it is currently saying that any DVM, RVT or PT can do AR EVEN IF THEY HAVE NO TRAINING IN THE FIELD. That is simply unacceptable. We would not want this model either! The parallel to human medicine is the best model, in that only trained and certified PTs are allowed to practice it -- not MDs (the equivalent of DVMs), not RNs (the equivalent of RVTs). As a consumer, I want to be protected from unqualified practitioners, not handed over to someone who has training in a parallel field but not in the area of specialty that I need! So the VMB needs to IDENTIFY THE APPROPRIATE COMPETENCY FOR SOMEONE TO SAFELY PRACTICE AR. This they have failed to do, and in so doing, have failed in their responsibility as an arm of the Dept of Consumer Affairs. What the CAAPT is proposing is that only PTs with ADDITIONAL TRAINING IN AR be allowed to practice AR. This would be the equivalent to what we have in human medicine. And, because those practitioners would have training equivalent to a human PT, they would not require direct supervision by a vet, any more than my physical therapist needs direct supervision by my surgeon. Indirect supervision, referral, consultation: these are the appropriate relationship, and what the VMB should require ALONG WITH IDENTIFIED COMPETENCIES FOR SPECIALIST PRACTITIONERS IN AR. What you should also know is that the US Supreme Court recently ruled that regulatory bodies, like the VMB, that are dominated by people with a vested interest in the economics of the field they are regulating, who then promulgate regulations that reflect those interests, are violating anti-trust law and imposing restraint of trade, and as such are at risk of lawsuits and even felony prosecution. This is a huge new area

The practice of veterinary medicine should not be paralleled to the practice of human medicine. There are a few similarities but many many differences that are lost on most people. The list of differences between species and disease processes and treatments and medications is quite long and the expectations of how veterinary professionals practice is quite different from how human medical professionals practice. To suggest that veterinarians who are providing rehabilitation services are untrained is an insult to those of us who have dedicated our career to this area of care. Veterinarians are charged with establishing a professional competency in areas of veterinary medicine before we take on that level of care. Whether it be a complicated dental extraction, a TPLO surgery or providing physical rehabilitation therapies we are required by our oath and our practice act to be educated and trained before we practice at that level and we take on that challenge with pride. If indirect supervision is accepted any PT or RVT will be allowed to practice rehabilitative services on your pet with NO training what so ever. The Veterinary Medical Board does not have the power to require any specific training of PTs. Under direct supervision the veterinarian in charge of the case is required to be sure any and all practitioners are appropriately trained and supervised before they can work with your pet. Doesn't this make the most sense? I can't imagine the PTs that have worked so hard to achieve their certifications in animal rehabilitation would want an untrained colleague to provide care to your pet. Following the "expertise of training" argument that has been given by multiple individuals then we should have DDS working on pets teeth and MD surgeons doing an exploratory laparotomy on our pets and MD internal medicine specialists managing our pets with diabetes and Cushings disease. Clearly that would not be appropriate on any level. As in most areas

BEFORE SIGNING, please consider an alternative petition or read my below comments so you are fully informed: http://www.ipetitions.com/petition/physicaltherapyforanimals/ We need regulation, but not monopolization. You could use the same address as stated in the below post to demand the California Veterinary Medical Board to establish competency for qualified practitioners (rehab is not part of the standard vet curriculum, so why would vets be allowed to practice something they have never had training in?), allow the consumer the right to choose their own qualified healthcare provider for their pet, allow for competition and collaboration within this specialty field, and have inclusive language for licensed physical therapist with advanced training (certification) in canine rehab to practice under indirect supervision. Again, MD's don't supervise PT's. In the human medical model, there is not the need for onsite medication adjustment or onsite emergent services by a MD. Why would it make sense to mandate that for our pets? Medication adjustments can be made over the phone by the referring veterinarian (not onsite), and if an emergency came up, they could be sent to the emergency vet clinic (just like we do in human medicine!). If a medication has not already been prescribed, then they can return to their referring vet for an exam and get the appropriate medical care they need. This is NOT justification to mandate a vet to be onsite (who may be untrained in rehab) to directly supervise a competent licensed physical therapist who has advanced training (certification) in rehab. This will needlessly drive up costs to the consumer and create a monopoly! Look to Colorado regulations...they got it right...and their rehab industry is thriving there (and they have had no complaints of harm or negligence by an advanced trained and licensed PT). As a consumer, do you want to pay more for rehab services, not be guaranteed that your vet is compete

This is posted on The Canine Rehabilitation Center's Blog Site Dr. Erin Troy leads a fabulous collaborative team of professionals and is a leader in the field . Proposed Veterinary Rehabilitation Regulations – We Need Your Support! August 31, 2015 by crc · On September 10, 2015 the California Veterinary Medical Board will be holding a hearing to present and discuss the proposed regulations that will govern those of us who provide physical rehabilitation to our veterinary patients. The proposed wording of the regulations designates Veterinarians, Registered Veterinary Technicians and Physical Therapists as the only professionals who can perform therapies involved in physical rehabilitation. In addition, the regulations require a veterinarian to be on the premises when the therapies are provided. This is defined as direct supervision. After more than 14 years of providing physical rehabilitation therapies to our patients, we believe that these regulations are appropriate and provide for the safe and professional care of your pet. We support the proposed regulations as they are written. There are some individuals who feel it is not necessary to have a veterinarian on the premises when your pet is receiving therapy, and as such, these individuals will be objecting to the wording of the proposed regulations. This could mean if your pet needs to have his medications adjusted, medical care provided or has an emergency while receiving physical rehabilitation therapy, a Veterinarian would not be there to help. We do not feel that this meets the standard of care you should expect and your pet deserves. We are asking for you help and support in notifying the California Veterinary Medical Board that it is important to your pet’s safety to have his or her care overseen by a veterinarian while receiving physical rehabilitation. There are a number of ways to support the proposed regulations: 1) We are presenting a packet of letters to the Veterinary Medi

DO NOT SIGN UNLESS YOU UNDERSTAND THE IMPLICATIONS BEHIND THIS REGULATION! I appreciate the discussion, Mr. Moschella. I have read and re-read the language in detail. The language allows ANY vet REGARDLESS of training and competency to do rehab! How does that serve to protect the public? You have me puzzled as to why you make the comparison of doctors and nurses. Why are you not comparing the actual professions in question here...doctors and physical therapists? Doctors don't supervise PTs...at any level anymore. California is a direct access state in human healthcare. Vets shouldn't need to directly supervise a licensed PT with advanced training (certification) in canine rehab. There is no justification to form this type of monopolistic restraint of trade and take away consumers rights to choose a rehab provider for their pet. So you're right, PT's aren't vets. Just like vets are not PT's! Why would a vet be allowed to practice a specialty niche like rehab when they have not had any training? That would be unsafe! Competency standards are essential to protect the public and this regulation does not address competency at all. Having an untrained vet be physically present for something that they do not understand is illogical and passes more costs on to the consumer. Many of the vets I work with say "I don't even know what I would be supervising." Again: I agree with the other post...let the consumers voice whether they need and want this type of "protection" by the government and let's hope the Board listens. They have not asked to give up their rights to choose their own healthcare provider for their pet! This is not a consumer-driven regulation. It is a veterinarian-driven regulation. We do need regulation, but not monopolization. I urge everyone to read this alternative petition and then make an informed decision: www.ipetitions.com/petition/physicaltherapyforanimals/

Karen Atlas you are completely missing the point. You state above "All this regulation states is that as long as you are a vet, you can practice rehab...even if you don't know anything about rehab!" By saying this, you clearly have not read the language. The language state that a Veterinarian be PHYSICALLY present at the facility and in direct supervision of the care of the animal. A PT is not a vet.....just like a nurse is not a doctor. Your child goes to visit the Dr.'s office when they sick, not a nurse. The child's primary care physician is the main coordinator of the overall care for your child. An animal receiving therapy for a catastrophic injury or chronic care that requires ongoing Veterinarian monitoring must receive treatment under the direct PHYSICAL supervision of a Vet to ensure a proper level of care.

This very emotionally charged topic can go round and round, but we (a collective of rehabilitation veterinary professionals) will say this. The practice of veterinary medicine should not be paralleled to the practice of human medicine. There are a few similarities but many many differences that are lost on most people. The list of differences between species and disease processes and treatments and medications is quite long and the expectations of how veterinary professionals practice is quite different from how human medical professionals practice. Following the "expertise of training" argument that has been given by multiple individuals then we should have DDS working on pets teeth and MD surgeons doing an exploratory laparotomy on our pets and MD internal medicine specialists managing our pets with diabetes and Cushings disease. Clearly that would not be appropriate on any level. As in most areas of veterinary medicine, veterinary rehabilitation is not unidimensional and requires a different approach with each patient and sometimes with the same patient at different visits. Many patients have complicating co-morbidities and are taking a variety of medications. Many present for care in an uncontrolled state of pain requiring multimodal pain management including prescription drugs. It would not be fair to the client, the patient or a non DVM rehabilitation practitioner to be out in the position of balancing these patients care without the oversight of a DVM. We have never undervalued or shown disrespect to the skills of a Physical Therapist. I wish I could say the reverse is true. A collaborative relationship is ideal and encouraged. The sole purpose of the CA VMB is to maintain the highest standard of care to the veterinary patient and the family with whom it lives. Having direct supervision by a DVM provides such care and who would not want to provide or receive the highest standard of care for their pet or patient?

Actually, you ARE disputing the skills and expertise of a PT if you are saying we can only practice under the direct supervision of a vet that has no training in rehab themselves. As an experienced and licensed physical therapist with a certification in canine rehabilitation, I can tell you that this regulation is NOT the answer. DO NOT SIGN BEFORE UNDERSTANDING THE IMPLICATIONS! We need regulation, not monopolization!! Let's leave it to the consumer to decide who they want to treat their own pet and put competency standards in place to protect them! Why monopolize the field and take away choice, drive up prices, and limit access even more? THIS HELPS NO ONE BESIDES THE VETS WHO OWN PRACTICES. Now to address your points again (thanks for this discussion, by the way...it is very instructive for all to truly understand what is happening here so the people can make an informed decision.) 1. Yes, vets are responsible for knowing what they do and why they prescribe, but that doesn't mean they DO know each nuance about an area of specialty care they were never taught in school! Especially a brand new niche of animal care. I know very few vets that really understand rehab...and its no wonder, because they have no experience in it and have never been taught (which is why they rightfully refer to me)! So why have them directly supervise something they have no idea or understanding about? They don't know what they are even supervising, so it is not logical to have someone supervise something they don't understand. How does indirect supervision (meaning the animal still needs a vet referral to make sure they are medically appropriate to undergo rehab--i.e. to make sure it is safe!) increase separation between practitioners? I am well accustomed to working in collaboration with vets and MD's. It's my job. As an expert in the rehab field (both in human and canine), I am in communication with the vet or doctor by phone, email, and fax. It is our du

To your points, and no one is disputing the skills and expertise the PT brings to the field, no one. 1. As part of the practice act - veterinarians are responsible for understanding what thy are performing and PRESCRIBING. Even if they prescribe AR, they still must understand it. With indirect supervision this increases the separation between practitioners. 2. Because there are no complaints does not mean there has no harm done. Pet owners are not accustomed to filing complaints for specialty services and often seek assistance elsewhere to make their pet better if the first practitioner doesn't help. And just because one has additional credentials after their name does not make them an expert. 3. The market can only bear so much and maybe coming into the veterinary profession the PT shouldn't expect to be paid the same wages they are paid in the human field. Veterinarians don't make as much as an MD. It's not a fair comparison. There is nothing wrong with a general practitioner veterinarian becoming more educated and trained on AR techniques and employing a PT in their general practice. That model works and will not drive up prices because the GP can still continue on their regular family practice duties. 4. Access is already limited, it is not uncommon for clients to drive an hour for a specialist (and even drive by a few they don't care for to see their preferred provider). A family veterinarian would likely embrace the skills a PT can offer to their practice, it only enhances what they already offer. This would strengthen the collaborative team approach. 5. If someone feels strongly about seeing a practitioner without a vet around they likely will figure out a way to continue care, likely illegally. The bottom line is a responsible and ethical vet will not perform AR unless they are trained to do so. A responsible and ethical vet only performs dental procedures, orthopedic procedures, internal medicine, reproduction medicine, neurology, cardiology, r

Please DO NOT SIGN this petition until you really understand the implications. I urge you to read my below comments before signing!! We do need regulation, but not monopolization.