September 11, 2026
On July 21, 2026, the Texas Board of Veterinary Medical Examiners voted to move proposed amendments to Rule §573.14 into formal rulemaking. The draft that reached that vote no longer names PEMF the way an earlier version did, and we expect some members will read that as a sign the pressure has eased. We want to explain carefully why we do not read it that way.
The Board starts the clock
The Board took up two rule items that morning, one covering Chapter 571 on licensing and one covering Chapter 573 on rules of professional conduct, both framed as proposed changes to be published in the Texas Register. The Board voted to move the §573.14 amendments forward, which begins the formal rulemaking process.
None of this is final yet, because the proposal has to be published in the Texas Register before it can take effect, and publication opens a 30-day window in which anyone may submit written comments or request a public hearing. That publication had not happened as of this writing, and we are checking for it each week. We will post the day it appears.
A quieter draft, and a wider one
In March, the Board circulated a draft that named pulsed electromagnetic field application directly, listing it as an example of musculoskeletal manipulation alongside electrical stimulation, shockwave, and dry needling. We wrote about that version at the time.
The later draft, dated June 24, 2026, dropped the list, and PEMF no longer appears anywhere in the text of §573.14.
What replaced it deserves more attention, however. The definition of musculoskeletal manipulation now reaches the therapeutic application of “any and all mechanical forces applied manually through the hands or any mechanical device,” where the rule in effect today reaches “mechanical forces” applied the same ways. Those added words widen the definition rather than narrowing it.
The draft also adds a phrase the current rule does not contain, stating that musculoskeletal manipulation is an alternate therapy in the practice of veterinary medicine “pursuant to Texas Occupations Code 801.151(c)(2).”
Where the word went
Section 801.151(c)(2) is the provision of the Veterinary Licensing Act that directs the Board to write rules governing alternate therapies, and the list of alternate therapies in that provision names magnetic field therapy along with ultrasound, holistic medicine, homeopathy, chiropractic, acupuncture, and laser therapy.
The draft therefore removes PEMF from the rule while pointing the rule at the statute that already names magnetic field therapy. Rather than disappearing, the connection moved up a level, out of a Board rule and into state law, where changing it takes an act of the Legislature instead of a rulemaking docket.
One further distinction matters for anyone trying to read the legal landscape accurately. Section 801.151(c)(2) instructs the Board to adopt rules, and it does not by itself prohibit anyone from doing anything. Enforcement in Texas runs through the definition of veterinary medicine at §801.002(5) and the licensing requirement at §801.251. A change to the wording of a Board rule, standing on its own, was never going to resolve the underlying question.
Four other changes worth noting
The independent contractor route becomes narrower. The rule in effect today allows a non-veterinarian employee or an independent contractor to perform musculoskeletal manipulation under a veterinarian’s direct or general supervision. The draft keeps that arrangement and adds a condition, requiring the supervising veterinarian to have provided the diagnosis and identified the specific regions of the body to be treated.
The statutory exemptions appear in the rule itself. New language lists, among those authorized to perform musculoskeletal manipulation, a person to whom the exceptions in Texas Occupations Code §801.004 apply. Section 801.004 is the exemptions section of the Veterinary Licensing Act, and the draft rule now points at it directly.
Recordkeeping expands. Under the draft, veterinary medical records must capture the treatment options offered, what the client consented to or declined, and the signed acknowledgments required under §573.14 and §573.16.
Laser therapy gets a delegation route that manipulation does not. The draft repurposes §573.17 to cover laser therapy and allows a licensed veterinary technician or a non-veterinarian employee to perform it under general supervision. No equivalent route exists for musculoskeletal manipulation.
Enforcement in Texas
The Board’s own enforcement report from July is worth reading alongside the draft. Across the quarter covering March through May of 2026, practicing without a license was the second largest category of complaints, with 38 cases. The cease and desist orders issued during that period include one for treating equine patients with non-invasive electrotherapy devices without veterinary supervision, and another for performing animal chiropractic without a licensed veterinarian present.
Texas is enforcing against non-veterinarian, device-based bodywork under the rules that exist right now. Whatever becomes of §573.14, that is the environment operators are working in today.
Our position
AOPP’s position in Texas concerns PEMF and nothing else. We are not asking the Board to loosen how it treats manipulation or shockwave, and we are not asking it to permit anything that penetrates the skin.
The question we are raising is a definitional one. When a session involves no skin penetration, no drug or biologic, no diagnosis, and no alteration of a veterinarian’s treatment plan, we do not believe it belongs inside a rule about musculoskeletal manipulation. Manipulation describes the application of force to move or mobilize tissue and joints, and placing a coil or mat on an animal does not do that. This is the case we intend to make once the comment period opens.
What to do now, and what to avoid
Watch for our next post, which goes up the day the Texas Register notice publishes. It will carry the official submission instructions, the deadline, and a framework you can use to write your own comment. Comments from Texas operators who can describe their actual practice and their actual clients carry far more weight than form letters, so the most useful thing you can do between now and then is start gathering the specifics of your own situation.
Please do not contact the Board individually to ask whether your practice is legal or to request an opinion about your circumstances. We have watched that approach go badly for operators in other states this year, where a single inquiry produced a written position that then applied to everyone. If you have questions about your own exposure, bring them to us or to your own attorney.
Questions: [email protected]
Primary sources
- Chapter 573, Rules of Professional Conduct, proposed draft updated June 24, 2026 (TBVME)
- Chapter 571, Licensing, proposed draft updated June 23, 2026 (TBVME)
- Board announcement of the July 21, 2026 vote on publication (TBVME)
- July 21, 2026 board meeting page, with agenda, board book, and meeting video (TBVME)
- Texas Occupations Code §801.151(c)(2), §801.004, §801.002(5), and §801.251
Drafts posted by the Board are working documents and can be replaced at any time. The version published in the Texas Register is the one that governs, and AOPP will note any differences when it appears.
