Senate Standing Committee on Business, Professions and Economic Development

...and economic development. Thank you all for being here. I'm sure colleagues will come and go during the hearing, and I know I have received messages from several who are in the building but watching and paying attention to what's happening here, so wanna thank everyone for your participation.

Today's hearing is about animal medical care provided by allied practitioners who serve predominantly human patients and clients, but seek to integrate their training and education into the treatment of animals.

One of the important factors in this conversation is the level of animal specific training that may be necessary for healthcare practitioners who practice on humans but would like to transition to doing some care for animals. The speech—sorry, I've spent three days in Disneyland with my kids, and I am on my last bit of energy here.

We'll see how many words I can spit out in the right order. Blame Mickey Mouse. All right. One of the important factors in this conversation is the level of animal-specific training that may be necessary for our practitioner.

The featured speakers today will help us understand as well as provide insight about the balance between veterinarian and allied health professional practices, including whether or not there should be certain limitations on crossover care. We'll also hear about frameworks for defining the professional relationship between various licensees to ensure both animal and human health wellbeing.

While pathways currently exist for non-veterinarians to provide services to animal patients, one goal for this hearing is to help identify any challenges with the current model of integration or barriers to full practice and vibrant small business opportunities throughout the State of California.

It's also important to understand what role licensing boards should play, not the ones they do play, but what should they play, in authorizing practice outside of a regulated area and who should be vested with the accountability for any violations of a standard of care or any other unprofessional conduct that may occur.

This informational hearing is focused on the facts and should help the Committee Members and members of the public gain insight into the new world of animal health care and treatment. I recognize that legislation is pending in this area, part of why we're having the hearing today.

This hearing, though, will not focus solely on the merits of any one piece of legislation, but rather, present an opportunity for us to listen, learn, and understand the evolving model of animal medical care.

Many members in both houses have expressed an interest in this topic, so doing things like this hearing help inform future potential pieces of legislation as well. The goal in any discussion about practice authority is to maintain strong patient and public safety parameters, in this case, prioritizing the wellbeing of patients.

I'd like to thank our panelists for joining us today, and I look forward to hearing from you all. We will accept public comment after the final panel. So, we're going to move through the panels kind of quickly, if that's okay with everybody, and then public comment testimony will be limited to two minutes. Two minutes, right?

And please, if somebody else has already made your comment, feel free to stand up and say that you agree with that point that has already been made. We're going to get started right away.

My hope here is to keep this under two hours by as much as we can, but also substantively talk about the materials which we have all come here to discuss today. All right, so our first panel, if I can welcome them up. And please help me with your names. We have some, some interesting names today. We—what's that?

They're coming remotely.

Oh, oh, that's right. That's right. Some of these folks are remotely with us today. We have Jennifer Pedigo, who is the Executive Director of the Nevada Board of Veterinary Medical Examiners, and we have Michelle Shane, who's the Executive Director of Kentucky's Board of Veterinary Examiners. I think they're both on Zoom. Is that right? Okay, great.

So, we're going to have some technical help with us today and we'll hear from both of these ladies as soon as we can pull them, them up. Bear with us for a second. Okay, this—I think we have Jennifer with us. Jennifer, you want to see if we can hear you?

Is there a delay? I'm not sure.

Okay, we gotcha.

Okay, great.

Go right ahead.

Thank you. So, essentially, I am here to mostly answer questions. I will share my screen on. I did provide, although I apologize for the late provision—sorry, it's opening now—just some documentation on what Nevada does essentially in the allied area. So, we do License 3 Allied Health Care providers, animal chiropractor.

Can you see that document?

Yep.

Okay, great. So, we license animal chiropractors, animal physical therapists, as well as equine dental providers, and those were at the request of industry primarily. We do also work in concert with the Chiropractic Board and the Physical Therapy Board in processing complaints. We essentially each hold responsibility for whichever type of practice.

So, whether it be human or veterinary, if part of our scope, such as an ethical question for a practitioner comes up during a complaint, that would go to the chiropractic board as well. So, we do share those responsibilities for processing complaints and developing those.

So, I won't go into too much detail, essentially, but if there are questions, we do license them, each individual type, so animal chiropractic or animal physical therapist. With the standard application, we require a chiropractor or an animal physical therapist be licensed as the human adjunct with their respective boards for at least a year.

And that's just to ensure that they are well equipped with the school and not with the knowledge coming out in their own primary training. And then, they do have to be with the animal chiropractors. There is a certifying body with the AVCA, the American Veterinary Chiropractic Association, that certifies them.

They're required to provide renewals every two years and as well as continuing education supervision requirements for both chiropractors, animal chiropractors and animal physical therapists, as well as equine dental providers. They do have to be under the veterinary client patient relationship.

So, that's the sort of door under which care is opened between the specialty or the allied professional animal chiropractor, animal physical therapist. The veterinarian typically makes the primary diagnosis or for instance is under, has a, has a surgical procedure that's done and then refers them to the physical, the animal physical therapist, the animal.

In general, each participant holds responsibility for their own services. So, the animal chiropractor, the animal physical therapist would be liable under their scope, and the same for the veterinarian. There is a requirement to exchange medical records and what those must contain. And then, essentially, for each type of disciplinary action is the same for all licensees.

So, in terms of numbers, the animal physical therapists are required to obtain 100 hours of coursework in animal physical therapy and then have 125 hours of clinical work under the supervision of a veterinarian, and that's just because specifically there are no certifying bodies of animal physical therapy, but there are board reviewed programs.

And I believe there are a couple specific ones that, for the most part, the Board sees primarily. I have that information I just don't have in front of me at this moment. And then the same reporting for the medical records is required as well.

For equine dental providers, a certificate is required from a professional dentistry organization, as well as a statement that they're working with a licensed veterinarian. I know that might not be related to today's presentation specifically, but that is the general parameters. So, I'd be happy to answer any questions, but that's the general licensing structure that Nevada undertakes.

Okay, thank you so much. We are going to go to our next panelists. We will come back with questions. So, if you can hang out with us, that would be great. We're going to do them at the end of the panel here. So, do we have Michelle Shane on the call? I think we do. Yep.

All right, great. Thank you. Go ahead when you're ready.

Yes. I'm going to share a slide presentation with you.

If we can turn her volume up, that'd probably be helpful.

Okay, can you hear me now?

Yeah, we can hear you fine. It's on our end. We'll get the volume up a little higher.

Okay, great.

Go right ahead when you're ready.

Super. So, I do have a little bit of a presentation for you here today. And this is something that some elements we did also present to the California Board of Veterinary Medicine. So, just to jump right in, I'm going to—if I can get the right screen. There we go. A little bit of an overview.

Wanted to give you some background and context for this conversation and build on that foundation to talk about some legislative initiatives that we've had in Kentucky and where those carve outs from veterinary medicine have happened and those asks that continue to come in.

To give you a good understanding of our board, the Kentucky Board of Veterinary Examiners was a 10-member board that has an added 11th seat now. The Board is primarily veterinarians and by mandate, they must represent all species. So, we have our food animal, equine, small animal veterinarians from all regions of the state and we also have a public member and licensed veterinary technician.

But that added seat is what I wanted to bring to your attention, the allied animal health provider license. And we're still waiting to license our first of those, so that seat is yet to be filled. Also, we talk about animals and humans trained in human care, wanting to transition over to veterinary care.

And I want to establish for you that baseline when we look at veterinary medicine, it's been around for thousands of years. In fact, it was in the late 1700s that the first veterinary medicine school was founded. So, the science of veterinary medicine has been happening for a very long time.

Modern veterinary education in the United States is a four-year undergraduate degree typically. Some do only go for the first three years and make it into the school, but there's a four-year doctoral degree and it must be from an accredited school. A lot of hands-on learning. There's a national board exam that covers all species.

And then, after graduation, most veterinarians tend to limit their practice to focus on special services, either for small or large animals. In some cases, mixed practices, given the economic environment. But veterinary education doesn't even stop there because of course, as a professional—profession—it is continuing education, is required in various modalities.

And then further, we have those boarded specialists or diplomats that attain an additional three to four years of education in various topics. I think there are some 44 AVMA recognized specialties, and they also must maintain continuing education in those specialized areas.

So, learning about animals is not something that you can do medically in a semester or a couple of weeks or an online course. It's something that takes a depth of understanding to properly treat animal patients.

So, right out of the gate, I want to bring you the recommendation from the Kentucky Board about how governance of these allied professions might happen. We hear a lot of talk these days about veterinarian shortages, particularly in equine and food animal medicine.

It is especially acute in rural areas because of the economic situation of those veterinarians being able to make a living and maintain their practice in those regions. That topic is very broad and I'm not going to get into all those details today.

But proponents of carveouts argue that a division of labor will be the solution to shortages, and that does not account for some 12 new colleges of veterinary medicine, added cohorts, increased cohort sizes, where we're going to see additionally hundreds of new veterinarians graduating each year.

And so, shortages I don't think are going to be an issue long term and may not be the best foundational argument as far as adding carveouts. Because everybody seems to want a slice of veterinary medicine, I think the best question is who doesn't want to be a part of this?

It's the chiropractors, physical therapists, rehabilitators, therapists, nurses, all of those you see on that list. We've been contacted in Kentucky, and I know my counterparts in other states have received similar outreach, interest in a license, just because people want to participate in or help with animals.

And so, when we talk about governance and I talk about the veterinary medicine education for your DVMs or your VMDs, these are subject matter experts on animals.

And Kentucky believes through our own experience, and I'm going to share a little bit of that in a few minutes, that the work on animals should be governed and oversight by veterinarians. Keeping all practice under the single board's umbrella is also less confusing for constituents.

It provides one source for the laws for animal service providers and consumer complaints. It's a whole lot less confusing for the public and it helps with the enforcement side or aspect of that. So, I want to talk to you a little bit about Kentucky. In 2020, we began a practice act. Modernization was ended successfully in '23. The whole practice act for the profession here was updated and included some new definitions.

We do get allied animal healthcare providers that read our definition section, hit number 24, and they see this complementary and alternative veterinary medicine therapies not considered part of conventional vet med, and they think, great, I don't need a license, and off they go.

But if they keep reading, in definition number 52, the practice of veterinary medicine, it is inclusive of complementary and alternative veterinary medicine therapies. And so, veterinary medicine is just generally the work on animals—is how we see it in Kentucky.

And in order to accommodate practitioners who are not veterinarians, we also created, at the same time during the update, these allied animal health professional providers, or AAHP providers, who, with approval from the General Assembly on the type of provider and in compliance with the rules established by the Board as far as education, training, and requirements, that they can become licensed to work.

So, I want to look then at those AHP licenses. In general, the Board has been granted the scope of authority to govern them. They do have title protections against the recommendation of all boards involved so far and many of the professionals in the human fields who are trying to cross over into veterinary medicine. Legacy pathway, window or grandfathering, is allowed in Kentucky, but like I said, against all recommendations.

There's limited, very strict limitations on the scope of practice, education, testing, medical record keeping, similar to some of the requirements you just heard from Ms. Pedigo. As an overview, we have two license types currently, and I'll talk to you about a couple other ones in the work.

But our animal chiropractic providers, because they are also licensed by a human professional board with a substantial amount of training in their field and hold a dual license with our board, no supervision is required and no referral is needed.

Our equine dental providers, or EDPs, are required to have indirect supervision because their education is limited, although no referral is needed. Communication with veterinarians, however, is required to try to understand if there's any contraindicators and just provide general oversight for the patient. And there's very, like I said, strict limited scope of practice.

No medical imaging, no surgery, no prescription authority, no drug administration authority, and limitations on those other modalities. One of the areas that we have spent a lot of time in as a board with stakeholders are the responsibilities and limitations on practice.

And so, we see that keeping people in their lane, staying within the limitations, is certainly going to be a governance challenge because while we've come to compromise, we didn't always agree on the correct direction.

Communication with the VCPR, veterinarian dispensation and administration of drugs would be another challenge, particularly pending the federal scheduling of the alpha 2s, related to equine sedation. A big conversation with all stakeholders involved is always about liability for services where that lies.

We've tried to clarify that liability in Kentucky lies with the service provider, regardless of the supervision, although the veteran does have some role in that.

And we also had a large conversation about training of new allied animal health professionals, particularly in those professions that don't require the rigorous human training on the other side, such as our equine dental provider students. I'm happy to get into that more detail. Another big thing we took from the Texas Model was the AHP Advisory Committee.

Although this Committee is appointed by the Veterinary Board Chair, they do get to weigh in on all AAHP issues, including grievances. And I'm just going to briefly run through quickly the carveouts that we have. In Kentucky, in the late 80s and 90s there was a specific carveout and statute for reproductive specialists.

We've had several conversations with these folks as they are nearing retirement and their clients are looking for who's taking their place. You can refer to those Kentucky minutes.

However, I will say that the feeling of the veterinarians in Kentucky is specifically related to reproductive specialists, that they are trained and only certain reproductive windows and not looking at the animal holistically, which is something we come back to with all of these AAHP providers.

Animal massage therapists, we've been working with them for years on filing a bill. This is actually where Kentucky learned that through conversations in 2019, the massage therapists didn't think really that much additional training was needed to be able to practice on animals.

And because we didn't agree on the training requirements to protect the animals and the public, that Bill died, and now, it is trying to come forward again under the framework we have in statute for the AAHPs. Animal chiropractic providers were just passed in '23 and we do have a couple applications on hand.

We do have requirement for them to complete training with either the AVCA, as mentioned by Nevada, or the IVCA. And our equine dental providers just came on this year in '25.

I will say that we are trying to incorporate cooperation as well from our horse racing and gaming corporation here in Kentucky to ensure that licensure is consistent across the state. So, again, there's still other agencies we're working with here.

And just a couple of last slides, the animal massage therapists, as I said, we continue to work with physical therapists, have seen our framework and are interested in becoming licensed as well, and some other providers, reproductive specialists. I mentioned rehabilitation and others.

So, I feel like as soon as we get one on board, we're talking to the next group to say who wants to come on board. But I think where I'd like to end this is just to say that, you know, veterinarians, being the subject matter experts in this, should be involved at every stage of governance.

I'm happy to answer questions. Also, Legal Counsel for Kentucky's Board is here with me today, Carmine Iaccarino. So, he is also here and available.

Great. Thank you so much. Okay, that concludes the first panel. So we're going to do our first round of questions. We will start here with my colleagues at the dais, and then we will go to public comment. We're going to do public comments totally at the end? Okay. All right, well hang in there then.

Senator Archuleta.

Madam Chair, we heard from Kentucky and obviously from Nevada, and all we're trying to establish is the fact that unlicensed individuals can be part of the team, I call it, that the veterinarian needs to provide good medical care. The other, obviously, is the fact that the rehabilitation of the animal, the dog, whatever, and the patient, the client, if we will, you know, if I took my dog in, I want to have a relationship with that Doctor and feel confident.

And if there was a bone operation or whatever it is, that I, in turn, would be part of the process and know what's going on.

Because I would imagine that, you know, the rehab does entail participation from the owner, and so, giving the owner knowledge of what the process will be and how long it will take. So, it's a combination of things.

And so, I just see it as a team effort that it sounds like that we should adopt, that I think a lot of veterinarians are doing that, and we need to, I guess, open that door to make them feel that they're on the right side of the law. That's my comment.

All right, very good. No questions at this point? Okay. I do have a few clarifying questions here, and let's start with one for Jennifer from Nevada. Is the supervision relationship between veterinarians direct or indirect?

So this in the schematic we have, it would be considered, I guess, indirect in that there is not on site supervision. So it would be a relationship of communication, documentation, but it would not be on the same site.

Okay. Also a question for you, Jennifer. In Nevada, are the practice provisions authorizing allied human health care practitioners to provide services to animals in your state in statute or regulations?

I'm sorry, I muted myself. So the statutes allow for the regulation of allied health professionals. The specific licensure requirements are in regulation.

Okay, one. One more for you. How are the allied health care practitioners licensed in your state, and do they each have a separate board or are they combined into one board?

So the license is granted with a combination of requirements, education and application and training. And that was sort of outlined briefly for the licensure. They are dual licensed in their related animal health care board. I mean, human. I'm sorry, human health care board. So the chiropractors are licensed by the chiropractic board.

They're also licensed by the veterinary board in their respective fields.

So if they're dual licensed, do they report to both boards or is there some combination of the boards that oversee the dual licensures?

No, each licensee reports or applies, maintains their license with each separate board.

So in order to be dual licensed, you'd have to report to at least the two boards. Correct. All right, that's interesting. Great. Okay, let's move to Kentucky here. A couple questions for you, Michelle. You mentioned that against recommendations, and that's in quotes, as an element of some statutes taking effect. Can.

Can you tell us a little bit more what you mean by that? Is that from your board, is that stemming from concerns about animal safety or you mentioned that it might. Might not be recommended.

Thank you for the opportunity to address this. So the statement was related to the grandfathering, or what we call the legacy pathway, that individuals who have just been doing this on their own without formal training could acquire a license within a limited window to practice based on their experience.

And this was against the recommendation of the veterinarians as well as, for example, the chiropractors or the equine dental providers who we have created licenses for, felt that training was essential to ensure patient safety and public protection, and that if you didn't have that, there shouldn't be a grandfather pathway.

Okay, that makes sense. All right, one more question for you, Michelle. How does a consumer know where to relay complaints? Probably have a few more complaint Department questions in California than either of your states. But important for us to make sure that the community knows where to issue those complaints and who's responsible for enforcement.

So when you're receiving calls from community Members who hear something that concerns them, what does the enforcement component look like? And has your board received any complaints, substantiated or not? How do you address it? What does that enforcement process look like? Can you walk us through that a little bit?

Yeah, absolutely. I think I will say that the strongest argument, I think for ensuring that the veterinary board is provided the governance and oversight of these allied professions is for those consumer complaints. One, you're going to have a central source. Anything related to animal license professions will come through the veterinary board.

And two, the experts in animals are going to best understand how that patient has been impacted or affected. We're going to handle complaints much like our current process. It is outlined in regulation. Complaints are going to come in and be evaluated, run through our grievance Committee and go through the formal process of investigation and hearing if necessary.

I think where it changes a little bit for the allied professions is we're going to have our Advisory Committee where anything touching on animal worked on by the AAHP provider would be reviewed by the Advisory Committee as well. And if necessary, looping in, for example, the chiropractor board to work with them on the case jointly.

Did you say the complaints come in online? Can people come to like a hearing? Is there a phone number? How do they. How does the General public reach?

Yeah, so our complaint process requires filling out a form. It's called a grievance form. We'll accept those electronically or by paper. That triggers the complaint to be assigned to a bifurcated grievance Committee which reviews the cases in an Executive setting, Executive session setting, to ensure that those who are not guilty are protected through the process.

Nothing of our details are released until a final order is reached.

Okay.

Did that answer your question?

Yeah, yeah, no, that's great. That's great. We, we also have to automate stuff too, a little easier. Okay, just looking at my colleagues one more time and we can move on to the second panel.

And we thank you both so much for bringing the expertise of Nevada and Kentucky to California's dialogue as we look for a pathway forward here to provide top notch care to animals and pass legislation that is thoughtful and informed by best practices happening across the country, not just here.

So to Jennifer and Michelle, thank you both so much for joining us in California in the State Senate this morning. We appreciate you. Okay, we're going to move on to the second panel now. Katie, these folks are all here. I am told These are the licensing boards and practices acts.

Members of our board today we're going to talk about how do non veterinarians serve animal clients in California today? This is kind of wrap our minds around the issue and then sort of think about how we, how we move forward from here Today.

I'm going to just let you each introduce yourself so that I don't mess up your names and get your titles exactly the way you like them be. Okay? All right, I'm going to start with you, Jessica.

Hi, good morning. I'm Jessica Seiferman, the Executive officer of the Veterinary Medical Board.

Jason Kaiser, the Executive officer with the Physical Therapy Board.

And Kristen Walker, Executive officer with the Board of Chiropractic Examiners.

All right, great. So just make sure we're clear on that. So we're talking about how we're going to. How we're currently dealing with the issue of non veterinarians working with animal clients. And in front of us we have the Veterinary Board, the Physical Therapy Board and the Board of Chiropractic Examiners. All right, very good.

Jessica, will you kick us off then and we'll go down the line?

Sure. Good morning again, Chair, Members of the Committee. My name is Jessica Seiferman. I'm the Executive officer of the California Veterinary Medical Board. The board's mission is to protect all consumers and animals by regulating licensees, promoting professional standards and enforcing the California Veterinary Medicine Practice Act.

The board, with over 17,000 veterinarians, regulates the largest population of veterinarians in the nation. Unlike any other healing arts professional who mostly provides specific component of medical treatment to one species, humans, Veterinarians provide treatment to over 700 species of mammals, birds, reptiles and amphibians that call California homes. Even within a species, there's vast differences.

Take canines for example. According to the American Kennel Club, There are roughly 200 recognized breeds from a 6 pound Chihuahua to an English Mastiff weighing over 200 pounds. Please keep in mind that many, if not most of canine species are intentionally genetically mutated and bred for looks rather than survival.

When listening to testimony today, please think about the spine of a Chihuahua to that of a horse. Then think about the spine of a human. The board also regulates over 4600 registered veterinary premises throughout California. Each veterinary premises must meet set minimum standards to ensure the health and safety of the public animal patients and veterinary staff.

For nearly 30 years, California licensed chiropractors have been providing musculoskeletal manipulation or MSM on animal patients under the direct supervision of veterinarians.

Chiropractors may perform MSM on animal patients only after a supervising veterinarian has examined the animal patient and has sufficient knowledge to make a diagnosis of the medical condition of the animal has assumed responsibility for making clinical judgment regarding the health of the animal and the need for medical treatment, including a determination that MSM will not be harmful to the animal patient the veterinarian has discussed with the owner of the animal or the owner's authorized representative a course of treatment and is readily available or has made arrangements for follow up evaluation in the event of adverse reactions or failure of the treatment regimen, the veterinarian shall obtain as part of the patient's permanent record a signed acknowledgement from the owner of the patient or his or her authorized representative.

The MSM is considered to be an alternative to non standard veterinary therapy. Once a supervising veterinarian meets this requirement, they can authorize a chiropractor to complete an initial examination of and or perform treatment upon an animal patient.

After the chiropractor has completed an initial examination of and or treatment upon the animal patient, the chiropractor shall consult with the supervising veterinarian to confirm that MSM care is appropriate and to coordinate complementary treatment to assure proper patient care.

Where the supervising veterinarian has ceased relationship with a chiropractor who is performing MSN treatment upon an animal patient, the chiropractor shall immediately terminate such treatment. Animal physical rehabilitation or APR is defined as the treatment of injury or illness to address pain and improve function by means of physical corrective treatment.

It does not include relaxation, recreational or wellness modalities including but not limited to massage, athletic TR or exercise. Veterinary assistants, including physical therapists may perform APR under the direct supervision of a veterinarian who has established a veterinary client patient relationship.

In both MSM and APR practices, direct supervision is necessary to allow veterinarians to step in and provide life saving measures when something goes wrong. There are no requirements for chiropractors or physical therapists providing their respective services under the direct supervision of a licensed veterinarian to register with the Board.

While most state veterinary boards have similar laws to California, the Board recognizes there are some states who certify other health other allied health professionals to practice on animal patients.

This is why in January the Board invited the Kentucky Board of Veterinary Examiners and the Nevada Veterinary Board to provide an overview of their oversight of other allied health professionals. The Board also heard from the American Veterinary Chiropractic Association on their animal Chiropractic certification program.

The Board continues to participate in discussions with California stakeholders and other states regarding this evolving topic regarding the Board's enforcement in these areas. The Board investigates complaints received from the public, the Board of Chiropractic Examiners, the Physical Therapy Board, and other licensees.

If chiropractors or physical therapists provide their service to animals without direct supervision, the Board can issue an unlicensed practice citation. If a veterinarian authorizes a chiropractor or physical therapist to provide services without a VCPR or proper supervision, it is considered unprofessional conduct and the Board can take disciplinary action against that veterinarian.

In closing, I'd like to acknowledge that there are many different interests sought to be promoted today, so I encourage Members to use Business and professions code Section 4800.1 as your guidepost your North Star, as we do every day.

My colleagues with their similar statute which states that protection of the public shall be the highest priority for the Board in exercising its licensing, regulatory and disciplinary functions. Whenever the protection of the public is inconsistent with other interests sought to be promoted, the protection of the public shall be paramount.

Thank you for your time today and I'm happy to answer any questions.

Great. Thank you so much. We'll just keep moving right through the panel. Jason, you want to keep Good morning.

Thank you for the opportunity to present on behalf of the Physical Therapy Board of California and because I love acronyms so much, I'll refer to that as ptbc.

There are quite a few acronyms throughout this presentation, so the PTBC is housed under the umbrella of the Department of Consumer affairs, or DCA, along with 37 other boards, bureaus and commissions. The PTBC is responsible for licensing and regulating physical therapists and physical therapist assistance in California.

The regulatory framework is established primarily through the Physical Therapy Practice act within the California Business and Professions Code, starting with Section 2600. Further specificity is provided by regulations promulgated and adopted by the Board. Following a detailed public rulemaking process. The board regulates approximately 30,000 pts and 10,000 ptas.

The board is comprised of seven Members and currently has two vacancies. The board's authority encompasses licensing, education, verification and enforcement to ensure public safety and competent practice, as well as providing outreach and education to the public regarding the practice of physical therapy.

Physical therapist applicants must complete a Doctorate of Physical Therapy from a program accredited by the Commission on Accreditation and Physical Therapy Education or commonly referred to as Capti. Most DPT programs are 3 years in duration and require applicants to hold at least a bachelor's degree for admission.

Physical Therapist Assistant applicants must earn an Associate degree also issued from capti Clinical experience is a component of that education. All applicants must pass the National Physical Therapy Examination, known as the MPTE and the California Law Examination to obtain licensure. In California, physical therapy aides, while not licensed, are still regulated by the Board.

They require no formal education. They receive training from and are under the supervision of a physical therapist. All care provided to the consumer, either by a PT, a PTA or a PT aide is the responsibility of the physical therapist.

The PTBC itself issues specialty practice certifications in, and this is a little bit of a mouthful, Kinesiological Electromyography, also known as kemg, and Electroneuromyography, also known as enmg. These certifications require additional coursework, supervised clinical hours, and the passing of a state exam. These certifications are linked to the PT's license and are renewed alongside that parent license.

Consumers in California may access physical therapy services in several ways, most commonly by means of a diagnosis in which physical therapists may treat consumers where a diagnosis is established by a physician and documented in the patient's medical record, and then by temporary direct access in which consumers may see a PT directly without a physician's diagnosis or referral for 12 visits or 45 days, whichever comes first.

To continue care after this time, an approval of the physical therapist's plan of care must be obtained from a physician. The approval of the physical therapist's plan of care may be obtained by physician examination either in person or via telemenes.

A little bit about the Board's enforcement responsibility The PTBC investigates complaints involving physical therapists, physical therapist assistants, physical therapist aides and non licensed practitioners practicing physical therapy or what is commonly referred to as unlicensed practice. All complaints received are investigated.

Complaints may be received by consumers, licensees, employers, third party payers or other state agencies, including boards or bureaus within the Department of Consumer Affairs. Complaints from other boards, agencies or official sources are assessed for PTBC jurisdiction. If a violation involves another practitioner, the PTBC collaborates with the relevant board as needed.

The PTBC is responsible for investigating complaints to determine if a license has violated the Physical Therapy Practice act and if so, pursuing action which may result in citation, fines, probation, suspension or revocation of license and when warranted, serious cases may be referred to the Attorney General's Office for prosecution or to the local District Attorney Attorney for criminal action.

The topic of pts treating animals has been the subject of significant discussion between ptbc, the Veterinary Medical Board and stakeholders for over a decade.

I myself have worked with three different Executive officers from the Veterinary Medical Board AB 1458 as well as similar legislative bills from the past, such as AB3013 and AB814, have been part of the PTBC's legislation reports and have been discussed at its public Board Meetings.

The PTBC also attended the Animal Rehabilitation Task Force established by the VMB from 2016 to 2017 to serve as a resource for information pertaining to the regulation of the profession of physical therapy.

The PTBC's authority covers PTS treating persons with the inference of human While animal rehabilitation is regulated under the vmb, pts that treat animals are considered veterinary assistants and are subject to veterinary medical laws.

Should the VMB sanction a PT license for a violation of the VMB Practice act, the PTBC would consider if that violation is substantially related to the practice of physical therapy and may sanction the PT license as deemed necessary.

This is in alignment with other duly licensed scenarios where a PT may be violating another practice act, such as the Medical Practice act, chiropractic or occupational therapy, acupuncture, or nursing, just to name a few.

In summary, the PTPC remains committed to upholding exacting standards for physical therapy practice, enforcing those standards with a fair and robust process, and engaging in ongoing discussions to address evolving practice issues. Thank you for your attention. I'm happy to answer any questions that you might have.

All right, thank you very much.

We'll keep keep going down the line here. All right, thank you. Good morning. Chair Ashby, Members of the Committee, thank you for inviting the Board of Chiropractic Examiners to this hearing. The Board was created in 1922 to regulate the practice of chiropractic in California as a result of a voter approved initiative measure.

The Board's mission is to protect the health, welfare and safety of the public through licensure, education, engagement and enforcement in chiropractic care with a vision of ensuring California consumers receive high quality, patient centered and collaborative care.

The board oversees approximately 12,000 licensed doctors of chiropractic, commonly referred to as chiropractors, 20 chiropractic programs located throughout the United States and Canada and 106 providers of chiropractic continuing education. Public protection is the Board's highest priority when exercising its licensing, regulatory and enforcement functions.

To that end, the Board has established rigorous standards for approval of chiropractic educational programs and for licensure.

To be eligible for licensure in California, applicants must earn a Doctor of Chiropractic degree from a Board approved program with at least 4400 hours of didactic education and clinical training complete a five part national board examination covering basic and clinical sciences, clinical competency, practical skills, and physiotherapy, and pass a state examination on California laws and professional practice standards.

Chiropractors are licensed as primary contact portal of entry providers in all 50 states, meaning patients can directly access their services without a referral from a medical Doctor or a limit on the number of treatments or visits.

The scope of chiropractic in California can be succinctly summarized as non surgical and non pharmaceutical health care that's considered consistent with chiropractic methods. Chiropractors are thoroughly trained to obtain a comprehensive health history from their patients and perform a thorough physical examination, including neurological and orthopedic testing and, when clinically indicated, diagnostic imaging and laboratory testing.

Following the examination, chiropractors develop a diagnosis or clinical impression, rule out any red flags or contraindications to chiropractic treatment, create a treatment plan, and obtain the patient's verbal and written informed consent before proceeding with treatment.

While chiropractors primarily work in private practice, they are increasingly being integrated into medical practices, public and private hospital systems, and federally qualified health centers and rural health clinics to collaborate with and complement existing care teams and increase patient access to primary care, particularly in underserved and rural areas of the state.

Similar to physician and surgeon and veterinarian licenses, a Doctor of chiropractic license permits a chiropractor to perform any chiropractic technique within the scope of practice. Many chiropractors choose to specialize in a specific area of practice or technique and to obtain certifications in neurology, radiology, rehabilitation, sports medicine, or pediatrics.

The gold standard of specialty certification within the chiropractic profession is the attainment of diplomate status in a recognized specialty after completion of at least 300 hours of postgraduate education and training and examination and additional continuing education requirements to maintain that certification.

Recently, the Board established a new Subcommitee on Chiropractic Specialties to protect the public by setting standards for the advertising and formal recognition of specialties within the chiropractic profession. In addition to setting standards for licensure, the Board has a comprehensive enforcement program to regulate the practice of of chiropractic, enforce the provisions of the act and Board regulations.

The Board has an in house team of special investigators and analysts to investigate complaints regarding chiropractic care and when necessary, the Board refers cases to the Department of Consumer Affairs Division of Investigation. The Board has broad regulatory and enforcement authority over the conduct of licensed chiropractors and when appropriate, the Board disciplines its licensees.

The Board also has jurisdiction over unlicensed individuals who illegally engage illegally engage in the practice of chiropractic without a license, and the Board addresses those complaints through administrative citations and referrals for criminal prosecution.

The Board works collaboratively with the other Department of Consumer affairs licensing boards to share information regarding complaints that may overlap the Board's jurisdictions and to route consumer complaints to the appropriate licensing program. The practice of animal chiropractic remains somewhat of a regulatory gray area because the Chiropractic act is silent on the issue.

And while the Veterinary Medical Board's regulation allows chiropractors to perform musculoskeletal manipulation on an animal under the direct supervision of a veterinarian in accordance with a specified protocol, it does not specifically address the advertising of animal chiropractic services by chiropractors.

The Board has not received any complaints about animal chiropractic resulting in an injury to a patient, but the Board occasionally receives complaints about the advertising of that service and investigates those complaints to determine if our licensees are practicing within the confines of the Veterinary Medical Board's regulation.

The Board then shares the information and findings with the Veterinary Medical Board so they can take appropriate action as well for unlicensed practice. The Board has observed the recent expansion of direct access to animal chiropractic in other states over the past decade.

For the past two years, Board leadership has engaged with stakeholders on the issue, reviewed the various direct access and referral regulatory models that currently exist in other states, evaluated the animal chiropractic education and certification programs, and discussed perspectives on the issue with the Veterinary Medical Board.

The Board has no official position yet on the issue of direct access to animal chiropractic, but the board is open and willing to regulate it and collaborate with the Veterinary Medical Board to establish standards of practice in this area. Thank you for allowing me to present today and I would also be happy to answer any questions.

Great. Thank you so much, Kristin. Okay, we are going to then come back to the dais for questions and comments from my colleagues. Would you like to start? Senator Trobo, who's, by the way, participating in this hearing with us today at my invitation. Thank you for joining us. She's got some bills and legislation in this space.

We won't speak specifically about that legislation today, but in General on this topic, she's one of the folks in the Legislature who is seeking solutions and informed legislation.

And so a big part of this hearing today is trying to provide her with some assistance and tools so that she can continue forward on the path that she's really interested in and have as much material and access to expertise as possible. Go right ahead, Senator.

And for that I do want to thank the Chair, Ms. Ashby, for the opportunity to be here today and be able to have an opportunity to ask questions within the scope of practice. So thank you very much, Chair, for the opportunity.

I do have some questions with regards to and this will go to either the vet board or the chiropord. Each one be open to answering the questions. In the past thus far, what type of complaints have been filed regarding animal chiropractors? Have we had much?

Obviously there's intensive and extensive training in various boards in all your respective fields, whether it's physical therapy or the chiropractor or the veterinarian. All of you deserve the utmost respect for the coursework and the training that your folks receive.

But in this case, I'm curious to know if we've had a significant amount of complaints regarding animal chiropractors working either independently or under the direction of our veterinarians.

So for the Veterinary Medical Board, the complaints are typically regarding chiropractors who are practicing on animals and they're not licensed and they don't have the supervision that they need for veterinarians. So it's typically unlicensed practice, not so much standard of care type violations. And we do get that when.

Often when the chiropractic board, through their investigation, finds that the chiropractors are also extending their services to animal patients.

And do you have any data as to the number of complaints of unlicensed chiropractors working in this capacity?

I don't have that with me today, but I can get that for you and provide it after the hearing.

I'm just kind of curious in how prominent it is to have unlicensed chiropractors, which I'm assuming in other states they would be considered those that have been grandfathered in. Would that be. Would that be the type of chiropractors that you're dealing with that are unlicensed?

When you say unlicensed. So they're unlicensed. Not in the Veterinary Medical Board, but they are licensed chiropractors who are practicing on it.

Is that what you mean when you're filing complaints against the chiropractors who are unlicensed?

Yes, we deem them unlicensed because they're not veterinarians. Where they might be actual licensed chiropractors under the chiropractic board.

Okay, so there is a distinction. Yes. Okay, got it. So I would be kind of curious to know the number of those. So we don't have the number of complaints on there. Have there been any verified complaints of animals being injured or harmed by certified animal chiropractors?

Not to my knowledge. Not to mine as well.

Okay, so neither board has had confirmed complaints with animals being injured or harmed by certified animal chiropractors. Madam Chair, question. Do we still have the. The boards, The. The folks from Kentucky and. And they are Nevada online? I doubt that. We do you want. To pull them back up? Is that what you're asking?

I'm just kind of curious to know whether or not a question that I just realized is we don't have any complaints in our state. Can you curious if there's a history of complaints of verified complaints of animals being injured or harmed by certified animal chiropractors in those states?

Maybe we can have the folks talking to them rather than bringing them back up on Zoom. Why don't you repeat that question one more time? We'll have our tech team ask them those questions. We'll bring them back to the dais and answer them for you. You want to repeat it one more time?

Certainly. Have there been any verified complaints of animals being injured or harmed by certified animal chiropractors in those states?

Okay. And just to be clear, I do think you should ask the clarifying question because there may be complaints that aren't lodged with these particular groups. I think that's part of the issue is we're not clear on where people would be submitting their complaints. So.

But it is a good clarification that none of you have received them, is that correct? All right.

Neither. Neither. Neither of the boards have. Okay. And this is for the Veterinarian Board. This is the following question. What is your understanding of the American Veterinary Chiropractor Association's education and certification process for chiropractors and veterinarians?

So I don't oversee that certification program. So I don't know the specifics of the certification program. Okay.

I think it was helpful with the explanation that. Let me see if I get this correctly. Kristen Walker gave earlier with regards to the education. That is. Would you mind really quickly just reiterating what that is?

That training for a chiropractor or for the diplomat status to practice in California. You need to practice as a chiropractor in California. You have to obtain a Doctor of Chiropractic degree with a minimum of 4400 hours of education and clinical training. And it has to be obtained from a board approved chiropractic program.

We have a rather robust system for approving each of the chiropractic programs within the country. So they have to meet in addition to national accreditation standards, they have to meet board specific regulations to be approved.

And then on top of that, there's a diplomate status that many practitioners optionally will pursue with an additional 300 hours of training and examination and additional continuing.

Education requirements, as is for chiropractic practice on.

On animals. Currently, to practice on animals. There is. The board has no authority to allow that. So the only existing model in California is for chiropractors to practice what's known as musculoskeletal manipulation under the direct supervision of a veterinarian.

There's a bit of a gray area in regards with the use of the actual term animal chiropractic because our act is silent on the issue, whereas veterinary medical boards regulations refer to it as musculoskeletal manipulation. So we occasionally get complaints about the advertising of animal chiropractic because it technically.

Doesn'T exist within The California. Yeah. But it does exist in. In other states, such as.

In a, there's, there's a handful of other states that have different models. There's Colorado, for one. Tennessee, I believe, is the most recent state that had it passed. I believe there's about eight states in total that have some model for animal chiropractic with direct access.

Okay. And would either of the states that testify today, do they have those models there?

Kentucky's is different than the models where we've. There's. There's different. There's different models. There's. There's states that allow referral from a veterinarian to a chiropractor. There are states that allow. That basically create exemptions from the Veterinary Medical Practice act to allow for animal chiropractic by certified animal chiropractors.

And then there's a handful of states that also directly regulate the practice. So there's three different models. Some are regulated through basically, some are unregulated, but just exempted. And then there's some that are directly regulated by chiropractic boards in other states.

Okay. And the two states under. In your. In your expertise, did either of the states that testify today have any of those models? No, not. Not the states today. Okay, here is. All right. And then this is for the vet board. Another question. Actually, I have a couple. And then I'll just. I'll give you some opportunity to.

To answer them. Has a direct supervision of animal chiropractors placed additional stress on veterinarians who want to provide this service to their clients?

Not that. Not to my knowledge, has been reported. What's been reported from the veterinary profession is that the current setup works well for animal patients and for the clients of California.

Okay. And could having direct access to animal chiropractic care improve outcomes on animals in General?

We believe that it does improve outcomes to animals in General. Just if something were to go wrong during the treatment, the veterinarians on site ready to step in should they need to.

But as of right now, you don't have any data that stipulates that there has been anything if something were to go wrong while they're manipulating the animal under the supervision of a chiropractor or under a veterinarian, hows would they be.

Would they be required to file a complaint with your board just to let them know that something happened or.

No. And so that could be. When you talk about not having complaints, that could also be because of the current structure, because a veterinarian can step in and provide any kind of life saving measures that happen. And if something were to go wrong, then that veterinarian would be held responsible.

And if they didn't provide the proper supervision, for example, then they would be held accountable for that, not the chiropractor.

So as of right now, we literally do not have any data either way because they wouldn't report it unless perhaps a consumer filed a complaint if something were to have gone wrong, potentially.

But because there's direct supervision and the veterinarian is there on site, the consumer themselves might not actually know what happened in the, the exam room or because the client isn't necessarily in the room when the treatment's being provided. And so the veterinarians are able to step in and help monitor the patient because they're on site.

So there's no way to assess whether or not there really has been any negative impacts on.

Not from our perspective.

Not from your perspective on there. So kind of makes it kind of a difficult judgment too because it's hard to assess whether or not there is a need or not a need for direct supervision.

I mean philosophically I can understand the importance of having the direct supervision of a veterinarian to kind of step in if there is an issue. But then again, we have no data stating that there has been a need in the past to actually have a requirement to have a veterinarian under that supervision. Do you understand where.

Yeah, I understand it's a little difficult on the gray area. So it would be helpful to know if we have other states that are practicing a similar model that may have data that would be helpful.

And I don't know if we have or anything, but if there's anything in your specific spaces there that might be helpful as well because either way we don't have the data to make it that accurate. Educated assessment.

I can say that in September there's going to be an annual conference with, sorry, the annual. The American State Veterinary Board Association where we're all meeting with the Executive directors.

I'm leading a discussion with all of those states who do regulate allied health professionals to work together in all the states to find the different models so we hopefully will have more information. I can ask that question of those states as well and bring it back to you.

Yeah, I think even moving forward, if we don't have that data, it might be helpful to acquire that data or to start accumulating that data just so that we can. Especially since there's so much discussion on whether or not supervision is necessary or not. Is it necessary? Is very, very helpful.

Would be Helpful in any of the spaces, I think. What is the understanding of animal chiropractors malpractice coverage?

I would not be able to answer that question. Okay.

It's my understanding that there's additional coverage available for it. I don't know the specifics, but I do know it exists. There's chiropractic malpractice coverage, and I believe it's a rider or something to that effect for animal chiropractors.

And is that required when you are under the supervision of a veterinarian or is that not necessary if they're under the supervision of a veterinarian in California?

So the veterinary state board does not require malpractice insurance for our licensees or for chiropractors? I don't think either of them do either.

No. We also don't have that requirement. Malpractice insurance.

Okay, this here's an acronym and you folks can. You guys are the experts on this. So the CVMA website states that veterinarians alone cannot solve the problems in that stand as barriers to veterinarian care for so many pet owners.

Because the health of the pet is linked to the health of their family, the problem of access to veterinary care should be considered a public health and social service issue.

Collaborative steps must be taken to help underserved families access veterinarian care for their pets to ensure communal health and welfare collaboration of government agencies, private nonprofit groups, pet owners and the veterinary sorry professions are key to addressing this issue. Why can't animal chiropractors be a contributing solution to this access to veterinary veterinarian care public issue?

So we actually believe that they are part of it and they are currently providing the services under the direct supervision of the veterinarian. So. So we do think that they are an important piece of it. And we also acknowledge that they can't. The veterinarians can't do it alone.

But we are looking to capitalize on the existing structure with the RVTs looking at their practice and growing the RVT's knowledge and potential scope to look at addressing that. And then also with a lot of collaboration with other states to see what they're doing to address the veterinary shortage.

Folks are working in those spaces and I know for sure that you folks are definitely working with the physical therapy space as well on that end.

Okay, Senator, we do have one more panel. Is that answer your question? Okay, great. So, Senator Archuleta. Yes.

Well, I wanted to compliment the boards because I think if we would turn the clock back years upon years, I can imagine that veterinarian faced with a problem, you know, operating on the hip of the dog, the family dog, which, like a lot of families, they're not dogs, they're not pets, they're family.

And so they had to reach out. And here comes physical therapists, here comes someone that, you know, maybe is a little more astute when it comes to a certain part of the medical world and you don't have to branch over, I guess.

And as veterinarians evolved into these specialists that we find that the professionalism, I think, is it's really grown. The board is doing a good job of watching them all, but we're talking licensed and unlicensed.

I think when a chiropractor is licensed and then of course he's called in, he's not licensed as a veterinarian, but he is a licensed professional. And I think we have to give some support, I guess, to the veterinarian who's smart enough, wise enough to bring in these experts.

And as we know that, as it's evolving, I think it's harder to get into the veterinarian's office than it is in our local Doctor's office. I think we've all experienced that. I certainly have.

And so, no, I'd just like to compliment the board for watching over the entire industry, because every time I take my pet in, there's consultations, there's, you know, one person after the other and x rays and etc. Etc.

And so I think that those that are there helping as the unlicensed person that one day will be licensed, especially in the office, to grow into that professional, that's what it's all about. It's the care of the animal that is so precious to all of us.

And the better you supervise and watch, I think the better the veterinarian will do. So I'd just like to compliment you.

Thank you. Thanks. Senator Archuleta, all three boards are doing an exceptional job for the State of California, for your licensees and for your. The people who are served by the licensees. I have two quick questions for you. First question really directed more towards physical Therapy board and the chiropractic examiners.

Does your board currently track licensees who practice on animals at all? No, we don't track that, nor does the PTBC. Great. Second question this directed to all three boards. What relationship do you believe should exist for licensees and veterinarians?

How would you handle enforcement if a licensed physical therapist or chiropractor provided services to animals and harm was alleged currently. And then last sort of question to add in there is. You heard the individual from Kentucky talk a little bit about dual licenses. Would like to hear your thoughts.

So as I mentioned earlier, currently under the structure, if either one of them receive complaints about their licensees performing services on animals, that they refer that that to us and then we can review that relationship that currently exists to see if the requirements were met under direct supervision or the protocols that are under regulation.

And if they, if they weren't, then we can take unlicensed practice, citation against the individual, the unlicensed individual, and disciplinary action against the supervising veterinarian.

Just like with any other overlapping when there's a dual license, if we were to take disciplinary action against a license, whether it's a veterinarian or we start issuing certifications like Kentucky or Nevada is, if we take action against our licensee and they also have a dual license with one of their programs, there's already a statutory structure that allows our boards to take disciplinary action if it was a violation of substantially related to their act as well.

Okay, great. Speaking as the administrator for the PTBC and just looking at the regulatory structure, I think the recommendation I would make is that ideally it would be governed by vmb.

And one of the things that I don't think that's been kind of mentioned in this conversation is I think it's less about the actual existence of a license and it's more about those that knowledge, skills and abilities that those practitioners might have from their education.

So even looking at a physical therapist who has a license with my board who would now be practicing on animals under the supervision of a licensed veterinarian, is it really about the existence of a license with my board or is it about the education and skills that they achieved in education towards that license?

And then I'm also looking at the potentiality of what they might be able to utilize with both licenses. Would they both be practicing on humans continually as well as animals? And in that case, I think think it's ideal to obtain a license with both boards.

But if they're going to essentially dedicate their professional life towards treating animals, I think it would be ideal for them to not have to contribute to the regulation of a profession treating humans, but they would be able to contribute to the regulation of a profession treating animals.

That makes sense, I'd say from the chiropractic board's perspective. First, addressing the issue of the unlicensed practice or the bleeding into other professions. The board already does investigate complaints to that effect. And it's actually there's the overlap. So when we talk about the collaboration between the boards, it already exists within the enforcement program.

When we have a complaint involving a chiropractor who's practicing without or exceeding the scope of what they're allowed to do under the Veterinary Medical Board, the chiropractic board looks at it as a disciplinary case for exceeding your scope of practice. The Veterinary Medical Board will issue a citation for unlicensed practice or in egregious cases, pursue criminal action.

If we're talking about a regulatory structure where this chiropractor is licensed, if it's a licensed chiropractor practicing within the bounds of the Veterinary Medical Board's regulation, but causes harm to an animal, we would be investigating the underlying circumstances of that as well.

Not only for the effect on the animal patient that was provided under the direct supervision of the veterinarian, but also for the safety of human patients as well as spinal manipulation is generally considered to be safe. So if we were to have an injury, we take those matters very seriously on our human patients.

And similar to if it involved an animal patient, similar to the other boards, if it was a dual license situation, we have authority to take action basically to piggyback off one board's action and discipline based on a substantially related act. So that would carry over.

Our board doesn't have an official position on whether it's regulated within chiropractic or if it's regulated within Veterinary Medical Board. I think they're very open to collaborating with the Legislature to find a solution that makes sense and it's for the best protection of patients.

I will just comment though that when it comes to chiropractic, a lot of this overlap is something that we already see and deal with every day within the health professions. Chiropractic and medicine are distinct, but complement each other. Chiropractic and physical therapy are again distinct, but complement each other. There's overlap.

We on a day to day basis get complaints that are, should have gone to the naturopathic board or should have gone to the physical therapy board, or maybe it's one of our licensees and they send them over. So we already have that collaboration in effect.

I would say if I, you know, without an official position, I say my, my board would likely lean a little bit more towards having the chiropractic board regulate it. Just because chiropractic is rather unique and generally misunderstood within the human healthcare system.

And I think my board may have concerns that that would carry over into veterinary medical, the veterinary medicine profession as well. But like I said, my board's very open and willing to collaborate with our partners at dca.

All right, just one more point. And this is just kind of a cautioned expectation of statistics. And I think this probably goes for the three of us at this table. Physical therapy is an example, 40,000 licensees. But we receive only about 5 to 600 complaints a year. Right.

So the numbers that you're looking for in those kind of cases is infinitesimal. Even in the human world. All the professions are fairly well behaved. Right. When it comes to practice.

So the number of cases, and out of those 500 and 600 cases, the number that actually go through the investigative process and result in discipline of any kind is even less minuscule. Minuscule.

So when we're looking for those existence of those kind of cases, in my experience over 15 years, I can recall forwarding cases to either of these boards. I could probably count them on all the digits that I have on my body.

So not very often, to Senator Archuleta's point licensure program, the oversight, the boards are doing what they're supposed to do and will always have those folks who step outside of the bounds. But that's why we're here to try to address it.

And unfortunately, when it does happen, it does tend to be fairly egregious and find its way into the papers and into the media and cause problems for an entire service industry.

But we appreciate you and everything that you're doing, appreciate Senator Chuletta really bringing it, bringing it back to the main point, which is Californians have spent a lot of time doing the best they can to provide oversight and care, to make sure that we have a licensing program that gives us the best and brightest in these spaces, that they're well trained, that they keep their education up to date, that they coordinate with each other.

And the three of you sitting here, and even though you're speaking for totally independent and different entities really have a lot of similarities and commonalities in the sense that you are trying your best to make sure that people who enter into the space of doing this work are providing top notch care in California to whomever they are serving, whether it's our pets or our kids or our parents or whoever it is, they're all loved.

Otherwise, you know, we wouldn't be doing all of this right where we care about these people and we care about these animals. We want to do right by them in California. So appreciate that. Appreciate that you spend your days doing that and helping us. Thank you for being with us today and participating in this panel.

We're going to move to our next panel. We have two more. This next one is hybrid panel. I think we have one person who's here with us. I. I think that Dr. Filist is here, but I also think that Dr. Johnson and Ziegler and I'm not sure about Dr. Amsted. Are they all on Zoom? Great.

So we have three folks with us on Zoom. Again, I'll have you each introduce yourselves. And one person present here with us. Let's just. Dr. Filiquist, before we start, let's make sure we have the other doctors on Zoom ready to go.

All right, looks like we do. Okay, we'll start with our Dr. Filliquist here in person. If you want to just introduce yourself. And then maybe we can go to the. Well, you know what? We'll just have you introduce yourself and go ahead and give your presentation.

And then we'll move to the Zoom, since it's a little clunky when folks are hybrid here.

Thank you so much. I'd like to thank the Chair and the Members for allowing me to speak here this morning. There should be some slides to go with my presentation as well. But in the meantime, I'm one of the orthopedic veterinary surgeons at UC Davis here, right next door to Sacramento.

And I'm greatly involved with the education of our veterinary students as well as veterinarians that are training to become specialists in veterinary surgery.

We should have your slides. We're trying to make sure we can get them pulled up here right now. Obviously, UC Davis Veterinary Medicine is a point of pride for the entire State of California. Thank you so much for everything that you all do. We're really fortunate to have you right here in the Capital region.

While we're waiting for that, can we get her to identify herself?

She just did introduce herself as the. She's the Professor.

I think you said Go, Dodgers.

Absolutely not. She's in Northern California. We allowed you to be here with that LA tie on and everything. But she's the associate Professor at the University of California, Davis School of Veterinary Medicine, overseeing orthopedic surgery and radiology science. Okay, we're going to have you hold on for just a second.

Dr. Filliquist, they're working on your slides. Can we bring up Dr. Johnson and Ziegler to say hello and introduce themselves while we're working on the slides? Go right ahead.

Yes, good afternoon. This is Dr. Johnson. And I'd like to thank the panel and also the Chair for having us come in and try to answer any questions and provide some information regarding this subject that's near and dear to us.

Dr. Johnson, tell them where you practice or where you teach.

Okay. Currently, I am practicing in Spring Hill, Florida. I'm a University of Florida graduate, 1982. And my main focus right now is American Veterinary Chiropractic. As a Board of Director, secretary, treasurer, President-elect in the past. And I am now the President-elect for the AVCA.

Very good. Thank you so much for being here with us. Do we also have Dr. Ziegler on the line?

Yes. Can you see me? I see our presentation just came up. Let's see.

We're working on it. We got a lot of buttons in the back today.

I'll go ahead and introduce myself. I'm Dr. John Ziegler. I'm from Louisiana. I'm the prior AVCA President along with, on the board with Dr. Gerald. I also am a prior President of the Louisiana Veterinary. I mean, Louisiana Board of Chiropractic Examiners.

Also have been part of the National Board of Chiropractic Examiners to both develop the National Board test for the chiropractic profession, as well as a test proctor and currently serve on one of the animal chiropractic certification commissions in a role as a f ormer board Member. And I practice in Natchitoches, Louisiana.

All right, thank you, Dr. Ziegler. Thank you so much for being here. And then do we also have Dr. Amstutz on the call?

Yes. Hello. Thank you so much for inviting me to join you today. It's been very educational just listening to the commentary already. My name is Dr. Kara Amstutz. I'm a veterinarian. I've been a veterinarian for 25 years. I have owned two veterinary practices throughout my tenure.

And recently within the last three years, I took over Canine Rehabilitation Institute, which is a postgraduate certification program for veterinarians, veterinary technicians, physical therapists, to learn how to do canine rehabilitation and utilize their skills in practice. I'm also a board certified specialist through the American College of Veterinary Sports Medicine, I've reached diplomat status there.

And I'm also the immediate past President of the American Association of Rehabilitation veterinarians.

Dr. Amstutz, where are you?

I'm in Springfield, Missouri.

We're really trying to cross all 50 states here today, you guys. We've done the best we can do to bring them in from everywhere. Okay. I am told that from a presentation standpoint, I think it's going to be easiest if we start with Dr. Johnson and Ziegler. Right? Is that right?

And yes, we'll do the three on Zoom first and then come back to you. I think that's the order they put them in. So, Dr. Johnson, you want to start us off? Go right ahead whenever you are ready.

And we will just say move on to the next slide. But you know, our representation is for the certification process, that there were questions about the process. And as Dr. Ziegler said, we do serve on the Commission as an examiner for the candidates, both veterinarians as well as certified human chiropractors.

So we, we actually provide as a slide will show you, as we move forward, how this works together in kind of making sure that we have the standard of care that everybody's concerned with. Next slide, please.

This is my CV for what we kind of spoke about. Again, the great thing about the American Veterinary Chiropractic Association is it's a meshing of two professions where we come together and set industry standards together. As you already know, chiropractic is not taught in any veterinary school.

So the AVCA kind of fills that space where there's a lack of education from the veterinary side, but also from the chiropractic side. We don't receive near the microbiology and pathology for different species other than humans.

And so the veterinary input into this is also from a standard set by the veterinary profession to allow us to know when to treat someone with chiropractic and when to refer them back into the veterinarian.

And so that's what our presentation will be about, is how the AVCA kind of fits the role of helping to educate both veterinarians and chiropractors and allow us to protect the public while also putting out a physician that is highly educated in the field of animal chiropractic. Next slide, please.

So we will, we will be kind of going through the different things about what the Veterinary Chiropractic Association is, the Animal Chiropractic Certification Committee, the AVCA Education Committee. And what is certification difference between that and the certification and the curriculum that they must take.

The basic program requirements, Professional Practice Analysis is the certification examination and the standards that we must hold to have a certification exam that is professional and meets the highest standards of testing. And then of course, the ACCC and the AVCA certified doctors and how that goes through, an overview of everything. So next slide please.

This slide is probably, I consider it to be probably our more important slide of the whole presentation because you get to see how the AVCA is set up and the differences between the AVCA and the Animal Chiropractic Certification Commission.

The American Veterinary Chiropractic Association has AVCA Members, but we, which are dues-paying Members, but we also have an education committee that is set forth through the board of the AVCA and also different doctors who are not, quote unquote, officers of the board, but are also on a committee. The committee provides the basic program approval.

So there are currently five to six different programs that we review. All programs must meet certain standards which we'll talk about and then in order to be approved for even the doctors of veterinary medicine or the doctors of chiropractic to even take those programs.

And then of course, we require continuing education to maintain your certification status, which we approved seminars for recertification. The Animal Chiropractic Certification Commission, again, that's a separate entity, although Members serve on each of those at certain times.

In that aspect, the Certification Commission does a practice, professional practice analysis and we have a third party person which we'll talk about that helps with that. And then we also give the certification examination.

And in order to be AVCA certified Doctor, not only have should you have taken and passed the basic program that is approved and passed their test, but you must pass that program in order to even sit for the certification exam and pass that certification examination to be considered AVCA certified.

So you can take the basic program, but you cannot be considered certified unless you have passed the basic program and you have passed the AVCA certification test.

And by the way, that's a written test as well as a practical.

Yes. Next slide, please. So the Association, of course, we're a professional, non-for-profit membership organization, again established in 1989, like I said, a great thing about this Association is it's comprised of licensed doctors of veterinary medicine and licensed doctors of chiropractic. And as the prior executive directors of the boards can tell you, sometimes there's conflict between professions.

In this instance, the professions get along great.

We go for a common goal of providing a certified professional doctor, whether it be veterinary medicine or chiropractic, who can uphold the standards set by our Association and by the testing requirements and also be held to a higher standard for the public so that we don't have to worry about unscrupulous practices being done.

And so we act as a certified agency for doctors and there's a membership and a certification which are separate entities. You have some people who are in a membership but they're not certified and therefore they cannot call themselves as certified animal chiropractors. Next slide, please.

The Animal Chiropractic Certification Commission is an administratively independent certification body of the AVCA. It implements and maintains a certification program that promotes quality in animal chiropractic. It promotes the high standards in animal chiropractic care for the protection and benefit of the patient as well as the public.

So that's a very important statement because we want you to know that as AVCA Members and certified doctors, it is also our highest concern that the public be protected as well as the patient.

We do not want doctors out there who have not taken the program that are trying to perform chiropractic and have no idea what they're doing.

So we want, we support both the California Senate's Commission on this and also each of the boards in the fact that we must have high quality doctors out there practicing at the highest standards. And we also want to protect the public as much as possible. And we're the primary national credential for this field in North America.

There is another organization, but our standards are the gold standards for the industry. Next slide please. The Education Committee.

Like I stated earlier, the Education Committee, not only do they approve the different independent institutions who are our schools that are educating the doctors of chiropractic and doctors of veterinary medicine, but they also review and approve all continuing education. And so we have, and we'll go through it as we go along.

But each school must provide 210 hours of classroom work. Both from classroom work and from practical test and also hands on applications.

And then also once you do receive your certification, we're required 30 hours every three years for you to maintain the certification which that in itself those two things will help support both the Board of Veterinary Medicine and the Board of Chiropractic to know that if someone has come through our program, not only have they received a proper education, but they also have, are continuing their education and continuing to maintain their certification.

So it helps give a little bit of a regulatory support to the state boards and what they're trying to do also. Next slide please. So what is a certification? The certification is a voluntary process by which a non government entity grants a time-limited recognition.

So again they must recertify every three years, and use of a credential to an individual after verifying that he or she has met predetermined and standardized criteria. The certification is distinct from licensure.

We do not, we cannot, we have no authority over a person's licensure. That is strictly a state by state basis with that individual, with their state board of regular regulatory examiners. We have no influence on that whatsoever. The certification in animal chiropractic developed based upon the input and oversight of both professions.

So when we're looking at what it takes to get your certification both in education and in the testing, both professions contributed into what has become the gold standard. It's not just a chiropractic profession, nor just a veterinary profession. The certification established and promotes professional accountability and visibility. And professional certification is different from a curriculum certificate program.

So you can go through a curriculum and receive a certificate that you completed that and have passed the test that they have, but until you take the AVCA certification program, you're not considered certified in animal chiropractic. So they are two distinct things.

And also every year when, Dr. Gerald and I both are on the Test Committee, and Dr. Gerald and I will both tell you that every year we have people who have gone through this, the curriculum and have their certificate from the curriculum.

But when they come and take the certification examination, every year we have a certain number of individuals who do not pass that and have to retest. So just because you've passed a curriculum does not mean you're going to pass a certification exam.

Just like if you graduate from a school of veterinary medicine or chiropractic college does not mean that you're going to pass the National Board test automatically. So it's held to that, that standard.

And to be clear, you can go ahead and if someone is takes their exam from their program and passes it, but does not do the certification process, they are still able to go out and practice.

But they cannot put the fact that they are certified through the AVCA to show that level of standard of care that we promulgate here. So it's very important and it's becoming much more recognized that the AVCA is the way to go. Although you don't have to be certified through us to practice.

Correct. Next slide please. So this is the difference between a professional certification and a curriculum certificate. Again, our certification is non-governmental program. It delivers an assess based on industry knowledge independent from training courses or course providers. It grants a time limited credential, again three years and you must take at least 30 hours to recertify.

Examination is not used as a mirror but as a screen to separate those who meet the assessment standards or the standard of care from those who do not.

And again every year we have a certain percentage of test applicants who do not pass but are told where they had their efficiencies and are able to retest at a later date.

And a primary focus on assessment, the curriculum that these different schools provide is a non degree granting program is to educate the participants instructions with intended learning outcomes and evaluates participants learning outcomes via an examination. So for instance, when I've went through, I went through Parker University for my education on that for six months.

You, you came there on a Thursday, you took a written exam from the prior month's education. Then we were in class from Thursday afternoon all the way till Sunday afternoon where we took a practical on what we had learned. And then you had a comprehensive written and a comprehensive practical when you completed the curriculum.

But that just allows you to say that you have completed a curriculum. After I passed all that, then I registered for the AVCA examination, both written and practical, which is also comprehensive and set for that certification exam. And so the curriculum certificate is primarily focused on education and training.

And I feel like the approved programs that we have do a great job of meshing these two professions together. And from a chiropractic standpoint, lets you know what is chiropractic and what is not chiropractic and needs to be referred back to the veterinarian. And as a practicing animal chiropractor, oftentimes I even did it last week.

I will refer patients back to their veterinarian because it's non-chiropractic. It's something that needs a higher level of assessment. Next slide please. So each institution must comply with all applicable state, local and provincial license requirements. Again, each basic program is required to provide a minimum of 210 certified hours.

They are to admit both doctors of chiropractic and doctors of veterinary medicine. On average, I think you're probably looking at it almost at 50% of each class.

The basic animal curriculum certificate program graduates must be prepared to obtain, consent, evaluate and provide a report of findings, arrive at and communicate a clinical assessment, and that is tested when we do our practical, and to treat neuromusculoskeletal and biomechanical conditions of animal patients.

All graduates must be confident in the common activities described by the professional practice analysis of AVCA and must be able to demonstrate diversified chiropractic. Diversified is a one of the many techniques in the chiropractic profession. But in animals it's the primary technique used to adjust animals.

However, there are some lower force or light force techniques that are also used, but that's advanced education beyond the basic programs.

Both the doctors of chiropractic and the doctors of veterinary medicine learn how to learn the neuroanatomy, the neurophysiology and also how to assess subluxations and to adjust those subluxations and when to refer back to the Veterinary Doctor if it's something beyond that.

And again, the basic program provider is granted for a two year period.

Dr. Ziegler, I know you have about four more slides. I'm just going to ask you if you could move us through them pretty quickly. Thank you.

Yes, ma'am, sorry. Next slide. So the professional practice analysis. This is an independent group that develops our test, the written and the practical. And then after every time, every year that we give this test it is then we take the results.

And Dr. David Starmers, who's currently working with us on every time we give the test, we refine it to update it to if there's any unfair testing like questions that were not fair, we rewrite those questions. It's no different than what the both the veterinary profession does and also the chiropractic profession does on their national board test.

We do the same exact thing. And as someone who's helped be a proctor for the national boards and helped write the national board for the chiropractic profession, I can tell you that it is our test is definitely on par with what is given by the chiropractic profession both from a written standpoint and from a practical standpoint.

Next slide. So the certification examination. Again its purpose is to assure the public and the profession that candidates who pass are safe for practice in the field of animal chiropractic. We try to meet the standards and do meet the standards of the American Psychological Association.

Our current and valid standards provide reliable indicators of competence and safety for the protection and benefit of the public, which is what's most important. And it consists of a written and practical components and the examination is under continuous review and refinement. Every year that we give it we do that.

As soon as we've given the test we review immediately. Next slide. So this licensed doctors of Veterinary Medicine. Licensed Doctor of Chiropractic.

We do not certify anyone if they are not licensed in their state and they must be fully licensed in their state and not have any kind history of losing their license or actions taken against them by their respective boards.

They have to successfully complete the postgraduate animal chiropractic program, pass the examination and our certificants are required to practice animal chiropractic within the laws and regulations of the individual states and provinces. And then recertification is required to maintain the credential, which is very important and it helps to ensure that the public that we are highly skilled.

Next slide. So overview. We're pleased to be contributing educational helpful information to state boards. AVCA has seen numerous approaches to appropriately regulating the practice of animal chiropractic. And again we feel that it starts with educated, safe, ethical and professional practitioners which is our number one concern. And they're required to practice within the laws of each individual state.

And we share the common purpose of the veterinary and chiropractic boards to promote and promulgate the practice of our individual professions, but also to protect the public from those who do not have the necessary knowledge and training to practice. Next slide. And that's it. And we'll be happy to answer any questions that you may have.

I know I ran through that quickly.

We appreciate that very much. We are going to keep moving here. So that's the full presentation for both doctors there, right? Ziegler and Johnson?

Yes.

All right, great. We're going to move to Dr. Amstutz then and have her walk us through her presentation on Zoom as well.

Okay. Can you see my slides? Yep, we sure can. Okay. Thanks again so much for inviting me. As I mentioned earlier, I am the owner of Canine Rehabilitation Institute, which is a postgraduate certification program for veterinarians, physical therapists, veterinary technicians to do physical rehabilitation with pets. So CRI is what we lovingly call it.

We have our headquarters in Springfield, Missouri, so we have a specific facility for our classes. Our classes are taught by a combination of veterinarians and physical therapists. So one of the things that we really pride ourselves on is the collaboration between the two professions.

So when we have PT's instructing veterinarians on topics that, you know, most of us weren't taught in school, it's really nice for them to be able to teach us those things that are new to us. And on the flip side, we have veterinarians teaching conditions and things that we see in our patients.

For PTs, they've got the manual therapy skills, they've got the knowledge of functional anatomy in humans, but they're trying to apply it to veterinary patients. We really just work together to bridge the gap. The other thing that really makes our program stand out is that we have a lot of hands-on, which I think is really important.

And you'll see in our curriculum why that is so important, especially for a physical therapist who's trying to transition into this field. But we have.

Our classes are set up with lecture time and then we always split up into small groups, small breakout groups with three to five students per instructor and a dog professor is what we call them. We always have a live dog in lab so that we can practice our palpation skills, our assessment skills and treatment skills.

Who's eligible to come through our program? Well, specifically, I believe the focus that we'd be talking about today would be our certified canine rehabilitation therapist. So eligible professionals are licensed veterinarians, licensed physical therapists, as well as licensed occupational therapists. We do have another program for assistants and for veterinary technicians.

And so our licensed vet techs and non credentialed veterinary assistants, as well as licensed PT assistants and licensed occupational therapy assistants. Our curriculum was originally developed in 2002. That's when our founder of CRI started the program.

It is updated on an annual basis based on newly published research and all of our curriculum has been approved through RACE, through the American Association of Veterinary State Boards.

And just of note, in 2005-2007, when the Colorado State Veterinary Medical Board was looking at how to integrate physical therapists into their board, they looked at minimum educational requirements and they reviewed CRI's curriculum and found that we were compliant. So what's the overview of our program? Well, there's two in-person modules on site here at CRI headquarters.

One is the Introduction to Canine Rehabilitation. It's what we call a hybrid.

So our students are, they spend up to 15 to 16 hours watching a variety of videos and then when they arrive to our facility then it's, it's, it allows us to hit the ground running to allow for much more hands-on experience while they're with us. And then the second module is a combination of skills and application.

So, so I'll get into a little bit more in-depth about what's included in these modules. And then the third module is actually an internship where they go and spend time with someone who is in practice so that they can see practically how to utilize these new skills. So the first module, the Introduction to Canine Rehabilitation.

I know one of the things that the Committee had asked is specifically what's in our program that allows for safe animal handling and you know, how to bridge the gap for physical therapists because they don't have a veterinary degree.

So some of the things that we teach in our program is how to recognize infectious disease and what zoonotic diseases should they be concerned about. How to, you know, what normal canine physiological parameters there are and what are common medications using vet med. A biggie is canine body language.

You know, veterinarians, veterinary technicians, we learned this really quickly throughout our career and that's something that we want to make sure that PTs understand and we want them to know that they can, how to handle patients very gently. And then you know, we get into the nuts and bolts of rehabilitation. Functional anatomy, biomechanics, musculoskeletal physiology.

Knowing that PTs have a lot of this information, but it doesn't necessarily directly correlate to a four-legged animal compared to a two-legged human. We go through a variety of conditions and then we really focus on evaluating treatment and clinical reasoning and case management. That's the intro course.

And then the second course builds on the first course and we dive deeper into pain physiology and pain management. Start to thinking about also like geriatric care because so many of our patients that we see in the rehabilitation practice is our geriatric patients. We also talk about neurological patients, we talk about assistive devices, a variety of things.

But one thing that I want to point out is the very last bullet point on this slide is we always go through a variety of what we call red flags. So that means if you're a physical therapist and you have a patient in front of you and things just aren't right, there's a problem here.

What do you do and what are indications and contraindications for what you should do and when is it appropriate to refer back to the primary veterinarian.

So we try to equip our PTs with knowing what is, what is appropriate and what is a red flag so they can stop and get that patient the care that it needs. And finally, the internship is 40 hours where the student would spend time with somebody who's already in practice.

We let them choose which practice model they might do. There are rehabilitation therapists who are in house call practices, who are in standalone practices, who are in specialty practices. So it just depends on what their interest level is.

All of our internship sites have to be approved by us and what we're looking for is adequate patient load, adequate equipment and obviously the training of the people who are there mentoring. And they're expected to have hands on practice of assessments, treatment plans, and providing the treatment as well as educating our clients.

And then they also have to write up three cases. So and those their case reports and everything are reviewed by our team. So to become certified through our program, they students must complete all online coursework, including quizzes throughout the the online portion. They have to attend all of the in person hands-on labs.

They must pass written examinations after each module with grade of 85% or above. And they must successfully complete their internship. And you all asked us also kind of what the statistics were. So CRI has had over 2,000 graduates since the beginning of our program. We have over 30 countries represented.

I have somebody in class right now in the other room from Hong Kong. So that's really exciting that they choose to come to Springfield, Missouri, and specific to California. We have had 180 total graduates. And then I broke it down by profession. 103 DBMs, 46 PTs, 31 technicians and assistants.

And that's all I have for you guys today. Thank you so much for allowing me to present to you.

Great, thank you so much. We're going to move right on to our next panelist in person. Dr. Filliquist. Go ahead. Hopefully we can pull your slides up now too. Give us just a second.

Should be coming up now. Look familiar? Not yet? I can't tell because if I look this way, it's the screen on the back of the TV and then.

No, that's not it.

Well, that's somebody's presentation, but not the one we need.

That's the ABCAs.

That looks more like it.

That's more familiar?

Yes, absolutely.

Perfect. That's the one we need.

All right, well, again, thank you so much for inviting me. My name is Barbara Fillequist, as I said, and I'm practicing over at UC Davis School of Veterinary Medicine.

And so, I just want to kind of take a step back and talk a little bit about the veterinary education and training that we provide and as that relates to animal physical rehabilitation. Next slide, please. And so, in California currently, we have two veterinary schools.

One's here, again, at UC Davis and then in Pomona, the Western University School of Veterinary Medicine. They're structured fairly similar. So, both are four-year curriculum programs with the first three years being spent in classroom as well as laboratory on a semester system. The last year at UC Davis is spent at the veterinary teaching hospital.

And so, the students will then rotate through the various clinical rotations that exist, and they can also choose to do externships at either private practices or other academic institutions. And so, the big difference between UC Davis and the Western School is that they don't have a veterinary teaching hospital on site, so all of their students go into this state distributive model where they visit and spend their clinical rotations at private hospitals.

Next slide. But I think regardless the way we think of animal physical rehabilitation or physical therapy, we're going to focus throughout the four years on subject matters that are, you know, relevant to this.

And so, as part of the education, you know, we're going to focus on, focus on physiologic biochemistry, start kind of sort of peripherally and lay these foundations on inflammation and pharmacology and pain. And then, that narrows down then into, well, how does pain, for example, affect our patients?

Right? Neurologically, animals with musculoskeletal disease, the behavioral responses, for example, to pain. And so, most certainly, it's a very in-depth education over these four years and that will then make veterinarians well rounded in terms of making these recommendations. The next slide, please.

And so, as part of the first-year course curriculum, as I said, it's kind of the basic foundations, learning about the functions of the musculoskeletal system. Again, anatomy, physiology, neuroscience. Again, anatomy and physiology, localizing where abnormalities are affecting the patient and how we get to the correct diagnosis.

We're going to focus a lot on the basic foundations of cell biology, receptor biology, the hematology, and how inflammation affects the body. Pharmacology, obviously—how do we use therapeutics and therapeutic diets to help patients that have mobility issues and then of course, gastrointestinal metabolism.

So again, laying the foundation of understanding the anatomy and how we get to the correct diagnosis is important. So, next slide. And the second year is kind of now focusing more on very specific organ systems, so the renal and urinary tract, cardiovascular, and the respiratory systems, endocrine reproduction, of course, oncology, infectious disease, and immunology.

And then, these big clinical foundation courses where they really start to put it together as a patient, interpreting data and thinking about approaches to diagnosis, again including musculoskeletal trauma. Next slide, please.

And sort of laying again this foundation each year so that in third year, we're really gonna start to put it together with having a patient in front of us so we have these big medicine and surgical stream courses in both small and large animal. So, they'll have patients that are presented to them.

They have to go through the diagnostic testing for think about critical problem solving and the therapeutics that are needed to address all major system diseases. And so, we're actually—I'm going to go straight from this hearing and go teach a musculoskeletal orthopedic examination of dog to the third-year students.

They also start to step up and actually have anesthesia and surgery on live animals as well as comparative medicine, and so, again, applying principles of diagnosis and therapeutics and to multiple species groups.

And it's important to recognize that even though in maybe fourth year they're going to target a very specific animal population, small animals or equine, throughout the first years, they do have to be well rounded in all species. Next slide, please.

So, as they come into our clinical rotations, then there's a required core that, again, allows us to ensure that veterinarians that are graduated have a very varied as well as meaningful understanding of the whole body, so, anatomic pathology, clinical pathology, primary care medicine, as well as these specialty services, including orthopedic surgery then, where I work.

There are also optional electives and so, our sports medicine or integrative medicine is part of that, as well as the equine sports medicine. So, all of these are elective. They're most certainly a large student body that rotate through these specific rotations as well.

And then, as I mentioned, they can have individual externships in other practices. Next slide, please. And so, we're most certainly fortunate for having a dedicated service for sports medicine and rehabilitation service, and they work, you know, closely with so many of the other clinical services.

You know, we may not think that a patient with an oncologic disease or cancer would benefit, but most certainly we know some, a lot of these processes, are painful and they most certainly benefit from it. I most certainly, as an orthopedic surgeon, interact, you know, a lot with them as well as the specialists in this area.

And so, we can provide a tremendous amount of treatments for these patients, to, again, with the goal to improve function and quality of life. And so, I can take next slide.

And then in addition, so this is all within this veterinary school of medicine, we also have the American College of Veterinary Sports Medicine and Rehabilitation, which really was developed to meet the unique needs of the athletic and working animals, as well as, again, animal in need of rehabilitation or pain relief.

And so, we use the term rehabilitation instead of physical therapy, but again, it doesn't just focus on recovery following surgical procedures, but again, improving quality of life in animals suffering from debilitating diseases, such as arthritis, as well as neurologic impairments.

And really, the objective here is to provide state of the art veterinary care in the field of sports medicine and rehabilitation, to collaborate with educational institutions, with regards to development and credentialing for residency programs, provide research, advancing the scientific knowledge, right?

And so, we need to obviously know are our treatments that we recommend actually benefiting our patients and not harming them, for example. And we also want to make sure, obviously, that we can provide continuing education for veterinarians, students, owners, and handlers of pets, as well as animal athletics and working animals.

And together with all this too, it's important to raise the public awareness of the benefits of working with certified specialists in veterinary sports medicine and rehabilitation. Next slide, please. And so, currently, the American College of Veterinary Sports Medicine and Rehabilitation is only available to veterinarians.

And it's one of 22 nationally recognized veterinary specialty organizations that's accredited by the American Veterinary Medical Association's Medical Board of Veterinary Specialists. After vet school, a veterinarian who wish to seek diplomat status in this group first has to complete a one-year rotating internship, followed by three years of a residency training program at an approved institution.

They do have to complete public research, as well as pass credentialing examination. So again, not an easy process, but again, developed to ensure that we have a high quality of care for our patients in this situation. Next slide, please. And so, the goal really with that is to ensure that we have a level of accountability.

And I really enjoyed hearing the vigor that goes into the, the certification for the American Veterinary Chiropractic Association. And so, I think it's important to always recognize that some certification, and again, I was impressed there. But some certification have no accreditation, continuity, or minimum standards set between programs. Some certifications have neither aptitude testing nor CE requirement.

And I think that continuing education requirement is vital to ensure that standards are met and that we always practice at the highest level of understanding of the evidence.

And so, I want to make sure that to understand the why and the how in our patients, it really takes, you know, an extensive education compared to maybe what just a weekend course, for example, to achieve a certification can provide.

And we've alluded to this before, and I think we all know that humans are physiologically not equivalent to other animals. And even within species, right, there's vast differences in terms of comparative physiology and anatomy, as well as behavior. Next slide, please.

And so, you know, a couple of things that I want to highlight just to get us to recognize that how important these differences can be. If we think of a dog, for example, they will transition from, you know, infant or recently born to an adult in one to two years compared to us as humans, right.

We know, for example, that that rapid growth can lead to skeletal deformity, for example, or muscle contractures that don't really exist in human medicine.

But that we are faced in if there's potentially, for example, an undiagnosed injury or even really a mild change that again, wouldn't affect a human, for example. Vital, I think, in this conversation is the recognition of pain. Obviously, you know, we don't have the benefit of asking our patients if something is painful or not.

And among species, they're going to exhibit pain very differently. And so, recognizing that is something that takes quite a bit of time to learn. A horse is going to respond very differently compared to a dog, compared to a cat, for example.

And most certainly, there is a significant difference in the position of the spine and a lot of problems that we encounter in human physical therapy. But, you know, most certainly, I can really only speak to veterinary medicine, right, is related to the position of the spine.

So, the injuries that humans sustain are due to forces that we don't necessarily see affect our patients. But most certainly, there's plenty of abnormalities that exist there. That, again, takes a thorough education to be aware of all of those differences. And again, even among animal species, we can't really always draw direct parallels.

We always joke that a cat is really not a small dog, but it's very true, they are going to act very differently in terms of disease processes and treatments as well. And most certainly, again, horses, goats, we deal with a very wide variety of species.

So, again, it takes several years to really gain a full understanding of these species' differences. Next slide, please. I think we learned and we have talked already about this, but there are definitely specific breeds that we have, you know, specifically altered to look the way they are.

And there are many inherent malalignments and malformations, for example, in the spine, that we just, again, need to have a thorough understanding of species and breed differences in order to correctly diagnose.

And I think that's key to have a diagnosis before we institute a treatment, whether it's surgical or physical therapy, to ensure that these treatments are performed safely. Next slide, please. And so, again, we've already heard a lot about continuing education for veterinarians. There's several opportunities offered out there.

There are conferences. Again, online learning platforms, as well as these educational programs. Right? And so, gaining a specialty certificate exists out there, no matter what interest a veterinarian might have. There are again, specific—University of Tennessee Physical Rehabilitation Program, the K9 Rehabilitation Institute, as well as then the American Veterinary Chiropractic Association.

So, there are many, many opportunities for continuing education as it relates to physical rehabilitation for veterinarians out there. And I think that's all that I have.

Thank you very much. Very informative, especially as the education component overlays with many questions that have been presented by the previous panelists. So, I'm going to come back to the dais here, to my colleagues, and see if they have questions, comments. You want to start us off, Senator Archuleta?

Yeah, thank you, Doctor. And you know, all of us who are pet lovers and had different breeds over our lifetime, I've had the big dogs, you know, and now the smaller one. You're right, they're all different. Are there certain doctors that we should go to that specialize in one animal versus the other?

Saint Bernard, I had one, and different breed, you know, with kids and things. Is there specialties that you would promote? What do you think of that one?

Yeah, no, that's a great question.

I think the education that veterinarians receive are—is—very thorough such that, you know, your veterinarian is going to recognize kind of the uniqueness in the smaller breed dogs and what, what to focus on there in relationship to, you know, the challenges and disorders that we see in large breed dogs and how they're affected maybe differently.

So, I think you're good with any, any veterinarian there.

And you mentioned sports dogs. I would imagine—I don't know what that would be, but you know, I guess hunting dogs and that sort of thing. But what about the canine that the police use? Especially those. I mean that. Is that a specialty for our veterinarians?

You know, there are definitely veterinarians that have more experience working with working dogs, so they would fall into the working dog category, and I think we recognize the importance there really to ensure that they are being able to perform at the high level of athleticism that they need.

There's a significant money investment in educating these dogs to work as well, and so, a lot of them benefit from physical rehabilitation and kind of that sports medicine aspect of it, making sure that they're kind of like an Olympian athlete, really, always at the top of their peak performance, really.

And our subject matter, expanding services, which entails so much.

Now, obviously, you feel that that is obviously the way to go because the more, and I called it a team earlier, team of doctors and of course the team leader being the veterinarian that brings in these specialists that we find certified versus licensed and so on, because it is gotten to a level that it's pretty expensive, to be honest with you.

I've had two dogs that we took over for my father-in-law and my mother-in-law and over time, and you know, between the two, we spent about $10,000 as they finished up their lifetime and now, you know, we can't get away from having another dog, so here we go again.

But—and this is a side note, I guess—there's a point in time, do you recommend that a second pet should come into the family to augment declining years or?

I think it depends on how much money you have.

I guess, but is that something, you know, you tell the kids, well, when they're eight years old and they're going to be 18 one day and it's still the pet, but then it's no longer in the family, do you recommend bringing in a second pet along that way?

There are a lot of—I think a lot of people that do that, and I think there are a lot of animals that, that respond actually favorable to that.

But it depends a little bit, I guess on how used that your one animal is to being the single, probably like a single child versus the second one arriving too. A little bit of rivalry there.

And my last question, going back to the expansion of services, do you see more of the professions coming in from the human side into the veterinarian world? Do you see that more in the future?

You know, I think we have we have an amazing educational process within veterinary medicine itself. Most certainly, we learn so much from human medicine. You know, we are advancing such that we're doing pet CTs now on animals, trying to localize where very specific abnormalities are present, and so, having that collaboration with human medicine is tremendous.

And with that said, we also are so fortunate that we have such a well-established industry with a high standard of care and education and so forth that we can really actually put human medicine to check. We are able to actually kind of do it on our own.

But again, there's lots of collaboration in this and again, it's a team effort, and we all benefit from that strong collaboration for sure.

Thank you.

Senator Ochoa Bogh.

Just a quick comment with Senator Archuleta's question. You know, I can tell you that my dog, she's a 15-year-old cocker spaniel, she doesn't like company. She would rather be on her own and rule the roost on her own. And she's getting up in age where she just, you know, it's an occasional pat.

And she was a very loving and social dog and she still is, but she likes her space right now. And I've been actually googling signs of pain because you were talking about being able to read all of that. But I think it depends on your dog. I know our dog would prefer if we have company come over with dogs, she goes and hides.

So, it's interesting how you think maybe to a certain degree, they might like companionship, but at certain degrees it's like, give me my space. I like my space and my quietness, so.

Not unlike us.

Yes.

Are you talking about replacing partners?

I'm just saying I may or may not associate myself with the comments of your dog.

But so, question on this one.

So, going back to, in California, as we have the veterinarian supervising chiropractors, I'm curious, when a veterinarian without any chiropractic experience, because not all of them have chiropractic experience or training, agrees to supervise an animal chiropractor, how does the vet know what the chiropractor is assessing and how does the vet know if the adjustment was performed appropriately?

That's a great question. You know, I don't necessarily think honestly that a veterinarian can know that. and I think that's actually why it's very important that veterinarians are still involved to make sure that the accurate diagnosis is established first, such that we know that, you know what are safe treatment options, and I think that's key.

If the treatment option is safe, including a chiropractic treatment, we're also are going to rely obviously on their expertise as well. You know, I can't be an expert in everything. I get lots of questions about ears and eyes and I just say, I'm sorry, you're going to have to go somewhere else. And I think it's likewise there.

We have to have trust in the people that we then collaborate with and making sure that, that we are confident about their decision making and treatments.

Perfect. Thank you. So, I believe I agree with you. It's collaboration, and truly, especially as with any field, we see that in medicine, you become more and more specialized, and to a certain degree, it's a good thing because you become an expert in that area.

But then sometimes you might—it might—hurt the whole because you don't have the full perspective on how everything is interrelated. We see that in medical practice for humans and I'm sure it's the same degree in Veterinarian medicine. Thank you for your.

Thank you so much. So, a couple of comments and I don't think I have any questions, but I would just—really want to thank this panel. I know I jokingly told you all that we are really crossing the country, but, but we kind of are.

And I'm proud of the business, professions, and economic development team for really going out and finding extraordinary experts. We're spoiled here, so, we could be lazy and just bring in UC Davis and say whatever. That's the only voice we're going to hear in the room, they're the best.

But I think it's important that we're hearing how things are going in Missouri and Louisiana and Florida and Kentucky and Nevada and appreciate all the panelists, and to the four doctors who took time to be with us today, for this panel, we appreciate you so much. And then one last comment here.

If I haven't touted my Aggie flag enough, you know, in my time on the City Council, one of my favorite projects that I got to work on, which is actually, for those of you from Sacramento, still a work in progress, is the Sacramento Zoological Society's relationship with UC Davis, and quite frankly, the entire country's zoological society's relationship with UC Davis.

I learned so much about what you do for the San Diego Zoo, for the primate program there, which is one of a kind in the world. And the veterinarians from UC Davis are also one of a kind in the world who go down and study those animals and provide care.

And then here in Sacramento, we have this incredible little creature called an axolotl. And the premier expert on axolotls in the world is also at UC Davis. And that may seem not too important to you, but there is this thing called One Health that UC Davis has really led on.

And it is the idea that is what's killing the plants is killing the animals is killing the people. Or if you're a glass half full, what's making the grass grow and what's making the animals healthy is also making the people healthy.

These conversations may seem like massages for dogs at one point, but they're so much bigger than that. It's really about the health and wellbeing of all of us and what we can study and how we can collaborate.

And it's why it's important that Missouri and Florida and Kentucky and California are talking to each other about not just animal health care, but about human health care and about how those things overlap and importantly, where they do not.

And so, I thank UC Davis for being such an extraordinary leader that we get to brag about you all the time, and I thank the other panelists for coming in from other states to help participate in this dialogue and tell us what you are doing, too. I know you have a class to teach.

We don't want to hold you any longer. Thank you so much. We have one last panel that will probably be pretty brief because it is narrowed to just the perspectives of practitioners. And I believe they're all in person. Yes? Okay. All right, so we should have Karen Atlas, Marissa Palmer, and Dr. Keith Rode here with us.

If you three would come forward. And Karen, we'll start with you. Introduce yourselves and give us a little bit of an idea—obviously, we're all over the place on the map here today—give people watching just a thumbnail of who you are, what you do, and then we'll do introductions first, then we'll go back through and launch with your presentations.

Okay, thank you.

Thank you for being here.

My name is Karen Atlas. I am a physical therapist and certified in canine rehabilitation and I am the President of the Animal Physical Therapy Coalition.

Hi there. My name is Dr. Marissa Palmer. I am a licensed chiropractor in California. I'm also an IVCA and hopefully soon to be AVCA-certified animal chiropractor.

And I'm Dr. Keith Rode. I am one of the co-owners of Woodland Veterinary Hospital, just up the road in Woodland, a small animal general practice, and I'm a past President of the California Veterinary Medical Association.

Great. Welcome to all three of you. Karen, you want to get us started?

Would love to. Thank you. Good morning, Chair Ashby and Members of the Committee. Thank you for this opportunity to provide you with the practitioner's perspective. I'm reading from my computer today because you see I am fostering puppies and well, they literally ate my homework.

Like I said, I'm a physical therapist certified in canine rehab and the President of the Animal Physical Therapy Coalition. We are a diverse coalition who brings together over 60 animal health businesses and organizations including veterinarians, veterinary technicians, PTs, veterinary specialists, animal welfare and rescue groups, law enforcement and search and rescue handlers, and pet owners alike.

We are united by a single goal and that is to expand safe access to animal rehabilitation and physical therapy. Importantly, we represent many California veterinarians and RBTs as well. So, the CVMA is no longer the sole vet voice in this debate. Let's first talk about education availability.

California PTs already complete doctoral level training in musculoskeletal, neurologic, and rehabilitative sciences. Those who choose to work with animals pursue additional animal specific education through one of the six certification programs like the K9 Rehabilitation Institute or through the K9 IQ Credentialing Program which is designed specifically for physical therapists. All are available to California residents.

These programs are not weekend courses. They combine coursework, hands-on lab, and supervised clinical internships with veterinarians and PTs working collaboratively. They require written exams and practice skills testing and for clarity, no, not everyone passes. The exams and skills testing by the certification programs would make it unnecessary for the boards to provide these exams themselves.

All certification programs are race approved which is the industry standard for veterinary continuing education. The certification programs are species-specific, primarily dogs and horses, which represent the majority of rehab cases, but the training could carry across species like cats. But the safeguard is clear here.

The veterinarian should remain the gatekeepers. They should decide when a referral or medical clearance to a PT is appropriate and maintain that the diagnostic referral and supervisory authority. But here's the problem. Under current statute, veterinarians cannot legally refer to anyone besides another veterinarian.

Ironically, veterinarian RBTs who receive very little rehab training, if at all, in their core curriculum, may legally provide these services without any additional training or certification. So, if consumer protection is truly the goal here, then minimum standards really should apply to everyone. The second issue is supervision.

Before the VMB enacted their harmful regulations, PTs classified only as unlicensed vet assistants could practice under the direct or indirect supervision of a veterinarian. This gave veterinarians discretion to decide what was appropriate.

In 2017, the Veterinary Medical Board rejected the consensus of its own Stakeholders Task Force and used misinformation to rewrite the rules as they pertained to PTs specifically. The result?

They proposed that unlicensed assistants with no training were allowed to work under direct supervision, while doctoral trained PTs would be mandated to take additional animal specific coursework just to do the same work as the unlicensed assistants. That doesn't enhance safety; that exposes the Board's bias against physical therapists. A sensible, safe approach is simple.

Let the veterinarian decide—direct supervision in acute care cases, indirect for stable outpatients—that preserves that oversight while expanding access. The third barrier is premise permitting. Currently, PTs can only practice in a facility with a VMB Premises Permit, and only veterinarians can hold those permits.

That locks PTs out of providing care anywhere except inside a vet hospital or as a ride along with a veterinarian on house or barn calls. To increase access, this practice must extend to alternative facilities, including the range setting for equine patients and mobile practices to serve the more rural areas in need.

Animal rehab is inherently low risk, despite the new narrative that has been created by the VMB. It does not involve surgery or anesthesia or any controlled substances, the very activities that would justify a special veterinary premises oversight.

Animal PT is the practice of PT and PTs are already licensed and regulated by the PT Board which inspects facilities for safety and compliance. The solution is really straightforward: use the existing state and local ordinances for animal facilities, just as we do for groomers and trainers, and let the PT Board regulate the PT practice.

If unique animal PT issues arise, subject matter experts can provide the guidance, just as they do for any specialty. If animal harm ever occurs, the PT Board and the BMB can address it together. Other states have used this collaborative referral model for decades with zero substantiated cases of PT-caused harm.

Liability would remain with the provider of the services. To address where clients complain, consumers can be educated at intake on how and where to file a complaint, consistent with the standard practice of posting complaint procedures in any licensed business. This is a safe, effective, and proven model. Members of the Committee, this is not radical reform.

Other states have shown the way, and California is simply playing catch up. Modernization of both practice acts is necessary to undo the harmful consequences of the VMB's 2022 Regulations, which entrenched a veterinary monopoly and further blocked access to safe care—blocked safe access to care.

The essentials are clear, training and rigorous is available to—training is rigorous and available to California licensed PTs. The expertise exists, but the recognition and statute does not. Supervision should be flexible. Let the veterinarian decide indirect or direct. Allow the veterinarian to refer to an animal PT or whoever else they want. Special premise permits are not necessary.

They just block access without improving safety. No other state necessitates it. Allowing for alternative facilities in remote and range settings and mobile practices are key to increasing access. Allow PTs to supervise aids. This is standard and customary for any PT and is the only way for a business to remain viable. Right now, we're facing an access crisis.

California has nearly 9.4 million dogs and over 200,000 horses, yet the number of qualified practitioners who are actually offering services here in California are more like around 37 for companion animals statewide and just a handful for the equine rehab folks. Most are not accepting new patients, or they have one to three month wait lists.

My own clinic is already booking into November. So, I urge you, please say no to veterinary monopolies and regulatory capture, and please say yes to interprofessional collaboration and safe, timely, affordable access to rehab care. Animals need it, the people want it, and many vets and PTs are eager to provide animals the best care they can together.

Thank you and I welcome your questions.

All right, thank you so much. Marissa, you want to keep us moving here?

Yes, ma'am. Thank you, Madam Chair and Members. My name is Dr. Marissa Palmer. I'm a licensed chiropractor and an IVCA and hopefully soon to be AVCA certified animal chiropractor, practicing since 2016. I have known that I've wanted to be an animal chiropractor as early as 8 years old and I've worked tirelessly to get here.

Over my years of practicing, I've seen a variety of patients, including family pets, award winning show animals, top athletes in our police canine units. Today, I'll be sharing my personal experience of being an animal chiropractor in California and highlight the struggles my fellow animal chiros and I are having.

The current version of animal chiropractic care simply doesn't work. California has too few vets. The existing system drives up costs for pet owners, and professionals live under constant threat of harassment from the Veterinary Medical Board. Becoming a certified animal chiropractor is not quick, easy, or cheap. I first had to go to human chiropractic school for four years.

Then I had to fly out to Kansas for five different months and stay out there for weeks at a time for animal chiropractic training. I had to learn animal anatomy, biomechanics, neurology, chiropractic sciences, veterinary sciences, chiropractic diagnosis and adjusting, safety and handling, and recognizing red flags and contraindications.

I then completed two written and practical examinations for my school and the international certifying organization and for me to remain certified, I complete 30 hours of continuing education every three years. After I had graduated from animal chiro school and received my California license, it took several months to find a vet that was willing to work with me.

The vets would say they were uncomfortable with the liability or they did not have the time or space. Fortunately, though, I was recommended to a vet who was open minded and welcomed me into their office, but many of my colleagues aren't as fortunate and they struggle to find a vet willing to collaborate with them.

I appreciate that my vet took me in and our relationship lasted for years, but it was difficult for my patients to get care. My practice was shaped less by my own choices and more by the setup of this office.

Despite my training in equines and livestock, my practice was restricted to just dogs and cats because this was exclusively a small animal clinic and there's an extreme shortage of large animal vets. Because my vet was already using all his exam rooms, he had to clean out his storage room just so I could have a spot to practice.

I was restricted in the hours I could offer care based on the hours the office was open. The vet has his own schedule and patients and it was difficult for us to coordinate. Because I had only one vet willing to work with me and there aren't many of us certified animal chiros, my patients would drive up to three hours to get their dogs adjusted and sometimes they had to do this multiple times a month for several months.