9/3/2026
Regulatory Affairs Update
Michigan’s Department of Licensing and Regulatory Affairs (LARA), acting through the Director of its Bureau of Professional Licensing, has issued a Notice and Order to Cease and Desist against a PEMF operator who was providing sessions to animals in Michigan. The order directs the operator to stop immediately and advises that violations may lead to administrative, civil, and criminal consequences.
Earlier this year AOPP had submitted a formal comment in the matter, and now that how the state has resolved this, it tells us a great deal about Michigan’s posture. This is the first enforcement action of this kind we are aware of in Michigan involving PEMF.
The Department’s reasoning follows three steps:
1. Michigan defines the practice of veterinary medicine to include “applying an apparatus or appliance” (MCL 333.18805(2)(a)).
2. Because the statute does not define “apparatus” or “appliance,” the Department applied ordinary dictionary definitions and concluded that the equipment involved, described in the order as loops, paddles, mats, boxes, and light emitters, falls within both terms.
3. The operator’s public advertising described the services as reducing pain and inflammation. The Department treated that language as “treatment” and concluded that applying an apparatus to ameliorate, correct, reduce, or modify a condition in an animal constitutes the unlicensed practice of veterinary medicine.
The evidence the order relies on is the operator’s own website and her statements to a Department investigator. The order does not describe any examination, any diagnosis, any prescription, or any observed session with a specific animal. The case was built on marketing copy.
Michigan has not declared PEMF to be veterinary medicine. A Michigan agency has taken the position that this operator’s advertised services were. That is a meaningful distinction, and we intend to keep making it. We want members to be precise about this, because the difference matters:
- It is not a decision of the Michigan Board of Veterinary Medicine. It was issued by the Bureau director under the Department’s own enforcement authority.
- It is not a rule, regulation, or statutory change. Nothing in Michigan law has changed.
- It is not a reasoned adjudication. No hearing has been held. No hearings examiner has construed the statute.
- It does not address PEMF as a category. The order does not use the terms “PEMF” or “pulsed electromagnetic field” anywhere. It addresses one operator’s advertised claims and the equipment pictured on her website.
The Takeaway for Michigan PEMF operators
Michigan’s exemption list is one of the narrowest in the country.
MCL 333.18814 exempts exactly four things from the practice of veterinary medicine: administering to livestock you personally own, scientific research, poultry testing under the national improvement plan, and USDA veterinary inspection. There is no wellness carve-out. There is no owner’s-agent exemption. There is nothing in Michigan law to argue your way into.
Review every public-facing word you have written.
The Department read this operator’s advertising and treated it as an admission. “Treat,” “treatment,” “therapy,” “rehabilitation,” “heal,” “cure,” “recovery,” “reduce pain,” “reduce inflammation,” and any named condition are the vocabulary that produced this order. That includes your website, your intake forms, your social media, your printed materials, and anything a client could screenshot.
Do not use restricted titles anywhere.
MCL 333.18811(4) reserves “veterinary,” “veterinarian,” “veterinary doctor,” “veterinary surgeon,” “doctor of veterinary medicine,” “D.V.M.,” “V.M.D.,” “animal technician,” and “animal technologist” to licensed persons. This applies to your business name, your email address, your signage, your domain, and your social profiles. It is a separate violation from practicing without a license, and it does not require anyone to prove you treated an animal.
Michigan does permit delegation, and that is the live compliance path.
Michigan Administrative Code R 338.4911 allows a veterinarian to delegate the performance of an act, task, or function within the practice of veterinary medicine to an individual who is otherwise qualified, subject to the limits of MCL 333.16215. Operators who want to continue working in Michigan should be talking with Michigan counsel about a documented delegation relationship with a supervising veterinarian — not about whether the statute might be read in their favor.
If you ever receive an order, the clock is shorter than it looks.
A cease and desist under MCL 333.16233 gives 30 days to request a hearing, and those days run from the effective date of the order, not from the date it lands in your mailbox. Mail delay comes out of your window, not the state’s. Call a Michigan professional licensing attorney the day you receive anything.
Implications beyond Michigan
Michigan is the second state this year where a regulator has placed PEMF inside the practice of veterinary medicine without the legislature ever having said so. In the other instance, a board answered an operator’s direct inquiry by stating that PEMF falls within its practice act — in a state whose statute never mentions PEMF at all.
Two states. Same year. Same mechanism. Neither one involved a bill, a hearing, or a rulemaking. The gap in the statute got filled by staff.
That is the finding, and it should change how all of us read a quiet regulatory landscape. Statutory silence is not permission. It is an unanswered question, and the answers are starting to come back the wrong way. Every entry on our national chart that reads “no restriction” because a statute says nothing is provisional until a state says something affirmative.
It also tells us where the work is. AOPP has concentrated on legislation, and legislation remains the durable fix — a supportive services clause that carves non-diagnostic, non-invasive modalities out of the definition of veterinary medicine, in every state. But bills move on a legislature’s calendar, and boards answer emails on Tuesday. Board guidance, informal opinions, and enforcement discretion need as much of our attention as bill drafting does.
A note on privacy
We are not naming the operator involved, her business, her location, or the file number, and we will not be circulating the order. She is not an AOPP member. She is a person having a hard month, and nothing about our regulatory work requires making that harder. We would ask members to extend the same courtesy if the matter comes up in forums or groups.
The Association of PEMF Professionals is not a law firm and does not provide legal advice. This update is general information about a public regulatory action and is not a substitute for advice from a licensed attorney in your state. If you are facing a regulatory inquiry, consult counsel.
