Texas Proposed Rule Update: What It Could Mean for Animal PEMF Practitioners

March 30, 2026

Texas animal PEMF practitioners should pay close attention to a proposed rule update from the Texas Board of Veterinary Medical Examiners. This is not law yet, but if adopted, it would make Texas’s position on animal PEMF much more explicit. The Board is currently accepting public comment, and the deadline is March 31, 2026. Comments should be sent to comment@veterinary.texas.gov.

What is changing?

In the draft revision to Chapter 573, the Board specifically lists pulsed electromagnetic field therapy (PEMF) as an example of “musculoskeletal manipulation” (MSM), alongside electrical stimulation, shockwave therapy, and dry needling. The draft states that animal chiropractic and other forms of MSM are considered alternative therapies in the practice of veterinary medicine.

That matters because the current Texas rule on musculoskeletal manipulation already treats these services as part of veterinary medicine, but it does not expressly name PEMF in the text. The new draft would remove ambiguity by naming PEMF directly.

If enacted, what would this mean for Texas PEMF practitioners?

If this draft becomes final in substantially the same form, Texas would be making it very clear that animal PEMF is not treated as a fully independent wellness activity outside veterinary oversight. 

Under the draft, animal PEMF could be performed by:

1. a licensed veterinarian, or

2. a non-veterinarian employee or independent contractor working under veterinarian supervision, if the rule’s conditions are met.

Before PEMF could be provided under this rule, the veterinarian would need to have:

• an established veterinarian-client-patient relationship (VCPR),

• examined the animal to determine the therapy is not likely to be harmful, and

• obtained a signed acknowledgment from the owner or caretaker that the therapy is considered an alternate therapy under Texas law.

The draft also adds that when a non-veterinarian employee or independent contractor performs the treatment, the supervising veterinarian must have provided specific manipulations and/or treatments for that person to provide.

Why this is a major issue for independent PEMF businesses

For practitioners who currently operate independently, this proposal would be very significant if adopted. If adopted as written, it could reinforce that a Texas animal PEMF provider generally should not be operating on their own without veterinarian involvement, unless they clearly fall within a separate statutory exemption. The rule itself points back to Texas Occupations Code §801.004 for limited exceptions, but otherwise places PEMF inside the veterinary framework.

It also matters that the draft keeps Texas’s VCPR rule in place: a veterinarian-client-patient relationship may not be established solely by telephone or electronic means. In practical terms, this means remote-only signoff is not a clean solution.

The compliance burden would likely increase

The proposal would not just affect whether PEMF can be offered. It would also affect how it must be documented and supervised. The draft expands veterinary medical record requirements and specifically requires records to include treatment options offered, what the client consented to or declined, and authorizations or acknowledgments, including the signed acknowledgments required by Rule 573.14.

The supervising veterinarian would also remain responsible for delegated acts and for the standard of care associated with the treatment.

What is the AOPP’s concern?

The AOPP supports clarity, training, and accountability. But clarity should not come at the cost of erasing the reality that many non-veterinarian animal PEMF providers operate in limited, non-diagnostic, non-invasive supportive roles.

A rule that explicitly names PEMF without also creating a narrow, practical pathway for trained non-veterinarian providers will:

• make existing practitioners vulnerable,

• reduce access for animal owners,

• discourage collaborative care models, and

• treat low-risk supportive PEMF sessions as though they are the same as diagnosis or full veterinary treatment.

Texas has an opportunity to be clear without being unnecessarily restrictive.

How to submit a comment

Email your comment to comment@veterinary.texas.gov by March 31, 2026. Keep it respectful, specific, and practical. Personal experience matters. If you are a Texas practitioner, explain how this proposal would affect your business, your collaborating veterinarians, and your clients.

Suggested Public Comments to Send:

Option 1:

To the Texas Board of Veterinary Medical Examiners:

I am writing in response to the proposed Chapter 573 draft. I am concerned that specifically listing PEMF as part of musculoskeletal manipulation within the practice of veterinary medicine could be interpreted too broadly and could eliminate limited, non-diagnostic supportive PEMF services provided by trained non-veterinarians.

I support reasonable standards and clear limits. But I ask the Board to consider a narrower framework that allows non-invasive PEMF sessions within defined boundaries, without diagnosis, prognosis, prescription, or representation as veterinary medicine.

Please adopt language that protects the public while preserving a practical pathway for responsible PEMF practitioners.

Option 2:

To the Texas Board of Veterinary Medical Examiners,

I am writing to express concern about the proposed rule language affecting animal PEMF.

I support reasonable standards and clear boundaries. However, I respectfully ask the Board not to adopt language that would automatically treat all non-veterinary PEMF activity as the practice of veterinary medicine.

Non-veterinary supportive PEMF sessions, when provided within defined limits and without diagnosis, prognosis, prescription, surgery, invasive procedure, or representation as veterinary medicine, should not be considered the practice of veterinary medicine solely because a pulsed electromagnetic field device is used.

Please consider a narrower framework that protects the public while preserving a lawful role for limited, non-invasive, supportive PEMF services provided by non-veterinarians.

Thank you for your consideration.

Option 3:

To the Texas Board of Veterinary Medical Examiners,

Thank you for the opportunity to comment on the proposed rule changes.

I respectfully ask the Board to avoid adopting language that would automatically treat all non-veterinary animal PEMF sessions as the practice of veterinary medicine.

Non-veterinary supportive PEMF sessions, when provided within defined limits and without diagnosis, prognosis, prescription, surgery, invasive procedure, or representation as veterinary medicine, should not be considered the practice of veterinary medicine solely because a pulsed electromagnetic field device is used.

I support clear boundaries, public protection, and veterinarian involvement where medical diagnosis or treatment is needed. However, the rule should also recognize the distinction between veterinary medicine and limited, supportive, non-invasive PEMF services provided within appropriate limits.

I respectfully urge the Board to consider narrower language that protects the public without unnecessarily restricting responsible non-veterinary practitioners.

Thank you for your consideration.