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.
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 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
