Animal Physical Therapy CoalitionAPTC



August 13, 2020Justin Sotelo, Lead Administrative & Policy Analyst Timothy Rodda, Administration/Licensing ManagerVeterinary Medical Board 1747 North Market Blvd., Suite 230 Sacramento, CA 95834E-Mail Addresses: Justin.Sotelo@dca.Timothy.Rodda@dca.DCA.DirectorsOffice@dca.PT@dca.RE: VETERINARY OPPOSITION TO CVMB ANIMAL PHYSICAL REHABILITATION PROPOSED REGULATIONSDear Mr. Sotelo and Mr. Rodda,I am a licensed veterinarian in California and a member of the CVMA. I am submitting this letter to OPPOSE the proposed animal physical rehabilitation regulations. It is clear that the emerging specialty field of animal physical rehabilitation needs oversight and regulation to protect the consumer and their animals. However, the California Veterinary Medical Board’s approach to pursue regulatory language without including an exemption for licensed physical therapists who have undergone the necessary training on animals limits my ability to inter-professionally collaborate and hinders the consumer’s ability to access these professionals.Allowing the veterinarian to evaluate, diagnose, and determine the best course of treatment is appropriate. If the best course of treatment is to send my patients to an animal physical therapist, then I would like the choice to be able to do that for my patients and clients. It is unreasonable to believe that veterinarians have the same skillset as a PT, much less even want to offer specialty rehab services themselves. It would be the highest standard of professional medical care for me to be able to refer my patients out to the professionals who are competent in this specialty. I have personally seen the differences in outcomes from the services of a licensed physical therapist certified in canine rehabilitation and therefore recognize the important role these professionals play in the care and well-being of our companion animals. I urge you to put a stop to any regulatory effort that fails to include the licensed physical therapist as a legitimate provider of animal physical rehabilitation services. Specifically, allow qualified and licensed PT’s to work under the direct OR indirect supervision of a veterinarian (level of supervision to be determined by the veterinarian) and allow them to work on animals after a veterinarian has established a Veterinary-Client-Patient-Relationship (VCPR), made a diagnosis, and determined that rehab would be a safe and beneficial intervention for their animal patients. By leaving the decision up to the veterinarian and allowing qualified PT’s to practice on their own APR premises under INDIRECT supervision (after the veterinarian’s consent and order to treat), would allow increased safe access for consumers, allow veterinarians to collaborate with other licensed professionals of their choice, and allow for Board oversight to protect the consumer. This approach is consistent with the CVMB’s Stakeholder’s Task Force recommendations and is consistent with the other states that have gone before us (like Colorado, Nevada and Nebraska). Exempting properly qualified and licensed PT’s from the Veterinary Practice Act is also consistent with the pathway outlined previously by the Senior Attorney of the Department of Consumer Affairs during the CVMB’s meeting in October 2015. The issue of animal physical rehabilitation has been going on for far too long. A legislative remedy is the clear solution (akin to AB 3013—the Animal Physical Rehabilitation Bill of 2018) which would have codified the legislatively-mandated CVMB’s Animal Physical Rehabilitation Stakeholder’s Task Force language and would have properly included the physical therapists. Sincerely,NameAddressEmail addressCc: Kimberly Kirchmeyer, Director, California Department of Consumer Affairs Jessica Sieferman, Executive Officer, California Veterinary Medical BoardCalifornia Veterinary Medical Board MembersJason Kaiser, Executive Officer, Physical Therapy Board of CaliforniaPhysical Therapy Board of California Members ................
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