Nebraska

August 2026

AOPP Seeking a Legislative Sponsor for the 2027 Session

On April 29, 2026, the Nebraska Board of Veterinary Medicine and Surgery took the position that PEMF application on animals falls within the definition of the practice of veterinary medicine and surgery under Nebraska Revised Statute section 38-3312.

That position has not changed. It remains in effect today.

The board did not create that definition. The Legislature did, and the Legislature is the body that decides what the Veterinary Medicine and Surgery Practice Act covers and what it does not. The board’s role is to enforce the statute it is given. That is why AOPP’s response is directed to the Legislature rather than to the board.

AOPP has drafted statutory language that would add non-clinical PEMF application to the list of activities the Act does not prohibit. That list already exists at Neb. Rev. Stat. section 38-3321 and already contains a range of activities involving animals that are not clinical care. Equine, cat, and dog massage practice was added to that list by the Legislature in 2018 through LB 596. AOPP is asking for the same treatment, using the same statutory architecture.

The draft is complete and formatted to Nebraska bill structure. AOPP is now seeking a state senator to introduce it in the 110th Legislature, First Session.

The new bill would:

• Define non-clinical animal wellness service as the non-invasive application of pulsed electromagnetic field energy for general wellness purposes.
• State expressly that the defined activity is not any act described in section 38-3312.
• Add the activity to the exemptions at section 38-3321 for equines, cats, and dogs.
• Make a conforming change at section 38-3314 so an exempt operator is not brought back into the Act as an unlicensed assistant.

The draft creates no new license, registration, fee, supervision requirement, or veterinary referral requirement, and imposes no new duty on the board or the Department of Health and Human Services. It leaves the board’s authority over veterinarians, veterinary technicians, and animal therapists fully intact, along with its authority to enforce the Act against unlicensed practice.

The timeline

Nebraska only allows bill introduction during the first ten days of session. There is no second window. We need a sponsor commitment in the fall to make a 2027 bill possible.

How Nebraska members and animal owners can help:

Introductions to senators.

If you have a working relationship with a Nebraska state senator, or with someone who does, that is the most valuable thing you can offer right now. Contact AOPP before reaching out on AOPP’s behalf so the approach is coordinated.

Willingness to testify.

Every bill in Nebraska receives a public hearing. Testimony from Nebraska animal owners who live in a senator’s district carries more weight than testimony from any association. AOPP is building a list of owners willing to appear in Lincoln or submit written comment.

Your district.

Knowing which legislative district you live in helps AOPP map where its Nebraska membership and owner base actually sits. You can look this up through the Nebraska Legislature’s Find Your Senator tool.

What not to do.

Please do not contact the Board of Veterinary Medicine and Surgery to complain about its April position. The board does not vote on legislation, and a complaint campaign will not help this effort. AOPP will handle all communication with the board directly.

To get involved, contact [email protected].

Please note:

Nothing described on this page has changed Nebraska law. Until a bill is introduced, passed, and signed, the board’s stated position governs. AOPP certification is a professional credential. It is not a license, and it does not authorize any activity under Nebraska law or the law of any other state.

This page is provided for general information and is not legal advice. Operators with questions about their own circumstances should consult a Nebraska attorney.

_________________________________________________________________________________________

May 6, 2026

Nebraska Board of Veterinary Medicine Reiterates Interpretation on Animal PEMF

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.

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.

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 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.

Join AOPP Today

The fight for sensible, accessible animal PEMF policy continues, state by state and meeting by meeting.

Questions? Contact Lauren at [email protected]

April 2026

April 29, 2026 Board Agenda to include PEMF  discussion item:

“When does PEMF use become the practice of Veterinary Medicine, since the apparatus itself isn’t regulated?”

View full agenda: Link

AOPP Seeking Clear Legal Recognition for Supportive Animal PEMF in Nebraska

The Association of PEMF Professionals is actively seeking support in Nebraska for a statutory update that would bring greater clarity to supportive animal PEMF practice.

Under current Nebraska law, the definition of the practice of veterinary medicine is broad. It includes diagnosing, treating, correcting, relieving, or preventing animal conditions through drugs, apparatus, applications, or other therapeutic or diagnostic techniques, as well as giving advice about those acts or representing the ability to perform them. Because of that, supportive animal PEMF can be swept into the veterinary practice definition even when a practitioner is not diagnosing, prescribing, performing invasive procedures, or otherwise acting as a veterinarian.

AOPP’s position is straightforward: 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. Nebraska law already shows that the Legislature can distinguish veterinary medicine from other animal-related services when it chooses to define those roles clearly. The state separately defines equine, cat, and dog massage practice, and it also recognizes an animal therapist framework.

At the same time, the current animal therapist pathway is not a practical fit for most non-veterinary PEMF practitioners. Nebraska’s statute requires an applicant to already hold another Nebraska health care license under the Uniform Credentialing Act, along with additional animal-specific qualifications. That may fit some rehabilitation-based professionals, but it does not create a workable pathway for a limited, non-diagnostic supportive PEMF role.

That is why AOPP is advocating for a better fit: a clear statutory pathway for a qualified non-veterinary animal PEMF professional operating within defined limits. This means preserving the veterinarian’s exclusive role in diagnosis, prognosis, prescription, surgery, and treatment of disease, while making clear that supportive PEMF can exist as a separate, limited service under Nebraska law.

AOPP supports reasonable guardrails that preserve the line between supportive services and veterinary care, including clear prohibited acts, truthful advertising standards, written disclosure that the practitioner is not a veterinarian, and referral obligations when an animal presents with red-flag issues or otherwise needs veterinary evaluation. This creates a clearer, more workable framework for animal owners, veterinarians, and qualified practitioners alike.

UPDATED 2/4/2025

The Nebraska Veterinary Board has determined the use of PEMF to be veterinary medicine and has sent animal practitioners cease and desist letters.

In an additional meeting on October 23, 2024, the board was again approached with practice questions regarding PEMF and the practice of veterinary medicine. You can read their responses below and the link to the full meeting minutes:

PRACTICE QUESTION(S) A. If a person is certified as a PEMF (Pulsed Electromagnetic Field Therapy) Practitioner, can a Veterinarian make a referral to the certified PEMF practitioner to work on an animal in the Veterinarian’s care? If so, would the referral need to be reestablished at different intervals?

The opinion of the Board is that Unlicensed Veterinary Assistants have no authority to perform this procedure. Please refer to the Nebraska Veterinary Medicine and Surgery Regulations, Title 172 Chapter 180 004.02 for full explanation of Unlicensed Veterinary Assistants authority: https://rules.nebraska.gov/rules?agencyId=37&titleId=101

B. If a PEMF machine is owned by an entity/person can they rent the machine to an individual who wants to do therapy on their own animal? The Board has no opinion, but rather suggests that you refer to your attorney.

Read the full minutes HERE

In a meeting on April 11, 2024 the board meeting minutes state the following:

PRACTICE QUESTION(S) A. What is the scope of practice regarding “Pulsed Electromagnetic Field Therapy” for animals?It is the opinion of the Board that Pulsed Electromagnetic Field Therapy would be within the scope of practice for Veterinary Medicine and Surgery in accordance with 38-3312-1 38-3312. Practice of veterinary medicine and surgery, defined. Practice of veterinary medicine and surgery means: (1) To diagnose, treat, correct, change, relieve, or prevent animal disease, deformity, defect, injury, or other physical or mental conditions, including the prescription or administration of any drug, medicine, biologic, apparatus, application, anesthetic, or other therapeutic or diagnostic substance or technique, and the use of any manual or mechanical procedure for testing for pregnancy or fertility or for correcting sterility or infertility. The acts described in this subdivision shall not be done without a valid veterinarian-client-patient relationship;

STATE OF NEBRASKA STATUTES RELATING TO THE VETERINARY MEDICINE AND SURGERY PRACTICE ACT

38-3312. Practice of veterinary medicine and surgery, defined. Practice of veterinary medicine and surgery means: (1) To diagnose, treat, correct, change, relieve, or prevent animal disease, deformity, defect, injury, or other physical or mental conditions, including the prescription or administration of any drug, medicine, biologic, apparatus, application, anesthetic, or other therapeutic or diagnostic substance or technique, and the use of any manual or mechanical procedure for testing for pregnancy or fertility or for correcting sterility or infertility. The acts described in this subdivision shall not be done without a valid veterinarian-client-patient relationship; (2) To render advice or recommendation with regard to any act described in subdivision (1) of this section; (3) To represent, directly or indirectly, publicly or privately, an ability and willingness to do any act described in subdivision (1) of this section; and (4) To use any title, words, abbreviation, or letters in a manner or under circumstances which induce the belief that the person using them is qualified to do any act described in subdivision (1) of this section.

Source: Laws 2007, LB463, § 1094.

LINK: https://dhhs.ne.gov/licensure/Documents/VeterinaryMedicineSurgery.pdf

 

Nebraska Veterinary Medicine Surgery

State of Nebraska Uniform Credentialing Act

Nebraska Licensure of Animal Therapists Chapter-182