Nebraska Board of Veterinary Medicine Issues Interpretation on Animal PEMF
May 6, 2026
Link to Nebraska Regulations Page: Nebraska
On April 29, 2026, the Nebraska Board of Veterinary Medicine and Surgery took up the PEMF practice question that had been placed on its agenda. AOPP submitted written comment in advance of the meeting, and I attended virtually to deliver public comment and engage in direct discussion with the board. Here is what happened and what it means for practitioners in Nebraska.
The Board’s Interpretation
After reviewing the matter and hearing public comment, the board reached a formal interpretation: because PEMF devices are intended to prevent or treat a disease or indication, and because they are used in the context of animal care, the use of such devices falls within the statutory definition of the practice of veterinary medicine and surgery. Under Nebraska’s current statutes, that means it must be performed by a licensed veterinarian.
The board applied the same reasoning to cryotherapy and also determined it to be the practice of veterinary medicine in Nebraska.
The board was transparent about the basis for these conclusions. Members emphasized that they are bound by the statutes as they are currently written, and that their interpretations follow directly from that language. They also made clear that they do not have the authority to change the law or interpret it differently than the statutes allow. These determinations are not policy preferences; they are a reading of existing law.
This outcome is consistent with the direction the board has been trending. As noted in our previous post(below), the board’s January 2026 meeting minutes already reflected a restrictive posture toward apparatus-based animal services, and the April 29 discussion extended that same reasoning to PEMF and cryotherapy alike.
What Comes Next: The 407 Application Process
The board directed stakeholders who wish to see a different outcome toward Nebraska’s Credentialing Review (407) Program. This is the formal statutory process (named for LB 407) through which interested parties can petition for a change in the scope of practice or seek new credentialing for a health profession in Nebraska.
There are several critical things to understand about this process:
It is the appropriate starting point. If AOPP and other stakeholders want to pursue any regulatory change in Nebraska, a 407 application is where the process begins. The board pointed to it as the established pathway.
It results in a recommendation, not a change to the law. The board was explicit on this point. A 407 application, even if successful, only allows the relevant review bodies to make a formal recommendation to the Legislature. It does not, in and of itself, change the law or the regulatory landscape.
The 407 process is a three-stage review. Proposals go through an ad hoc technical review committee appointed by the Director of Public Health, then to the relevant board, and finally to the Director for a final report. The entire process is required by statute to be completed within nine months. All reports generated through the process are submitted to the Legislature’s Health and Human Services Committee to inform any legislation that may follow.
Legislative action is the only path to lasting change. The board reinforced that only an act of the Nebraska Legislature can ultimately change the law. A 407 process can build the record and generate the recommendation, but the finish line is the Legislature.
AOPP’s Position and Path Forward
AOPP’s position remains unchanged: non-diagnostic, non-invasive supportive PEMF should not be treated as the practice of veterinary medicine solely because a device is used. Nebraska already has precedent for more tailored statutory frameworks (including the existing Licensed Animal Therapist structure) that demonstrate the Legislature’s ability to carve out appropriate, narrow pathways when the need is established.
We appreciate the board’s transparency throughout this discussion and their willingness to engage directly with our comments and questions. The outcome was not what we hoped for, but we now have a clear and honest picture of the regulatory landscape and the road ahead.
AOPP will be moving forward with a 407 application in Nebraska. This is the right process, and we intend to use it. We will keep our Nebraska members and the broader PEMF community informed as that work progresses.
The Bigger Picture: Laws Need to Catch Up to Reality
Let’s be direct about what these rulings (PEMF and cryotherapy, both classified as veterinary medicine) tell us.
These supportive, non-invasive modalities are already used across the country by thousands of practitioners. Animals are already benefiting. Businesses are already operating. The real world has moved forward. What Nebraska’s board made clear on April 29 is not that these services are dangerous or inappropriate. It is simply that the statutes have not kept pace with what is already happening.
That is a regulatory gap, not a safety concern. And it is one we see playing out in state after state.
Boards are not the problem here. Most boards are doing exactly what the Nebraska board did: reading the law as written and applying it faithfully. The problem is that the laws themselves were written in a different era, without any consideration of the supportive services that now exist. Boards cannot fix that. Only legislatures can.
AOPP’s ultimate goal is a supportive services clause in every state. We are working toward statutory language that clearly and specifically carves out non-diagnostic, non-invasive supportive modalities from the definition of veterinary medicine, creating a realistic and enforceable framework that reflects what is actually happening in practice. That is the long game, and we are playing it.
In the meantime, we will continue to work with each state individually and engage each board specifically. Every meeting we attend, every comment we submit, and every relationship we build with a board or a legislator moves us closer to the regulatory clarity this profession deserves.
Nebraska Practitioners: We Need You
Here is the honest truth about how this process works: the more practitioners we document in Nebraska, the stronger our case becomes.
A 407 application is evaluated in part on the scope of the profession and its impact on the public. The number of people practicing, the animals being helped, and the economic activity being generated all matter when review bodies assess whether a change in scope of practice is warranted. A larger, well-documented Nebraska membership base means:
- A bigger voice when engaging with the review committee, the board, and ultimately the Legislature
- Greater demonstrated animal impact: more practitioners means more animals receiving supportive PEMF care across the state
- Stronger economic impact data: showing that this is a real, active profession with meaningful economic presence in Nebraska
If you are a PEMF practitioner working with animals in Nebraska, now is the time to join AOPP. Your membership directly strengthens our ability to advocate on your behalf in this process. Every practitioner we can count in Nebraska adds to the case we bring forward.
The fight for sensible, accessible animal PEMF policy continues, state by state and meeting by meeting.
Questions? Contact Lauren at [email protected]
April 23, 2026
Link to April Board Agenda: Here
AOPP’s Submitted Letter to the NVBM: AOPP Letter
The Nebraska Board of Veterinary Medicine and Surgery has placed PEMF on the agenda for its April 29, 2026, meeting. The agenda includes a specific practice question: When does the use of PEMF become the practice of veterinary medicine, since the apparatus itself is not regulated? The board is also scheduled to review proposed draft revisions to both its regulations and statutes related to the Veterinary Medicine and Surgery Practice Act. Public comments are listed on the agenda, and the meeting is open in person and by WebEx.
Nebraska’s current statutory definition of the practice of veterinary medicine is broad. It includes diagnosing, treating, correcting, changing, relieving, or preventing animal conditions through a drug, medicine, biologic, apparatus, application, or other therapeutic or diagnostic substance or technique. It also includes giving advice or recommendations on those acts and demonstrating the ability to perform them.
The board’s January 30, 2026, meeting minutes suggest that it has already adopted a restrictive view of similar apparatus-based services. In response to a practice question about Equine Aquatred, Theraplate, and Equine Acuscope/Myopulse, the board stated that the presenter would need to be licensed as a veterinarian to provide those services in Nebraska. The board also suggested that if a pathway is desired for non-veterinarians, support should be sought from a state senator to pursue statutory change.
AOPP’s position is that non-diagnostic, non-invasive supportive PEMF should not be treated as the practice of veterinary medicine solely because a pulsed electromagnetic field device is used. At the same time, this issue should not be resolved by an overly broad board position that, by default, sweeps all PEMF into veterinary medicine. Nebraska law already shows that the state can create more tailored pathways when needed. For example, Nebraska has an existing animal therapist framework.
AOPP believes the better path is a narrow statutory solution rather than a blanket restrictive rule. Veterinarians should remain responsible for diagnosis, prognosis, prescription, surgery, invasive procedures, and treatment of disease. But supportive PEMF should be addressed through clearer statutory boundaries that distinguish veterinary medicine from a limited non-veterinary supportive role. That is the conversation AOPP will continue advancing in Nebraska.
Members and practitioners who wish to write to the board should keep their message respectful, concise, and focused on the need for a narrower legislative fix rather than a sweeping interpretation. Or, use the template below.
Email comments to:
Nebraska Board of Veterinary Medicine and Surgery
c/o Janis Gadeken-Harris, Health Licensing Coordinator
Nebraska Department of Health and Human Services
Dear Members of the Nebraska Board of Veterinary Medicine and Surgery,
I am writing respectfully regarding the Board’s discussion of PEMF. I urge the Board not to adopt a blanket position that all animal PEMF is the practice of veterinary medicine solely because a device is used. A more workable approach would be to recognize that this issue may require a narrower statutory solution rather than an overly broad interpretation under current law.
Veterinarians should remain responsible for diagnosis, prognosis, prescription, surgery, invasive procedures, and treatment of disease. At the same time, supportive non-diagnostic, non-invasive PEMF should be considered more carefully and not automatically treated as veterinary medicine in every context.
Nebraska has previously addressed related animal-service issues through more tailored statutory frameworks, including the existing animal therapist structure. I respectfully ask the Board to leave room for a narrower legislative approach here rather than supporting a blanket restrictive position.
Thank you for your time and consideration.
Sincerely,
[Your Name]
[City, State]
[Business Name, if applicable]
Link to Nebraska Regulations Page: https://pemfprofessionals.com/regulation/nebraska/
