May 21, 2026
Webinar Recap: What the Texas Veterinary Board Told Us About Alternative Therapies
On the evening of Wednesday, May 20, the Texas Board of Veterinary Medical Examiners (TBVME) hosted a webinar on alternative therapies. AOPP was represented on the call by Lauren, and we want to share a clear summary of what was covered, what was not covered, and the concrete steps our community can take from here.
The short version: the board used the session to walk through the rules and statutes that are already in place and not much about the proposed rule changes that drew so many of us to the call. Several attendees asked the board to address the draft rule changes that were published in March. The board repeatedly declined, explaining that the proposed rules have not yet been formally proposed for public comment and that the evening was meant to clarify the current legal landscape. As the board put it, the goal was to close the gap between what many practitioners think is in the rules and what is actually on the books.
So while the proposed changes are the reason this issue is a “hot button” right now, the webinar itself was mostly an educational session on existing law.
The legal framework: two sources of authority
The single most important takeaway for Texas is how veterinary regulation is structured, because it determines who can actually change what.
The two sources of authority:
- Statute (Chapter 801, the Veterinary Licensing Act): Anything with an 801 prefix comes from the Texas Legislature. The board cannot change statute; only the legislature can, and it next convenes in January for a 140-day session.
- Administrative rules (the 570s, in the Texas Administrative Code): These are rules the board writes and can change, but only within the authority the legislature has given it.
This matters enormously because the requirement at the heart of our concern is set out in statute, not in the rules. So again, the legislature must change the statute before the board can further write, interpret, and then enforce those rules of the law.
Enforcement
A few points the board was clear about:
- The TBVME is complaint-driven.
- It does not go looking for violations except during inspections. It relies on complaints from the public and the profession.
- The board does not accept anonymous complaints
- For unlicensed practice, the board can issue a cease-and-desist order.
- A subsequent violation can carry monetary penalties
- Practicing veterinary medicine without a license is a misdemeanor
- Owners are exempt when working on their own animals.
The board noted that the recent uptick in cease-and-desist activity tracks a broader rise in complaints as the population has grown, and that alternative-therapy concerns are usually folded into those numbers.
A few words on the draft proposed changes
When asked, the board’s general counsel and chairman made an important clarification: the draft rules condense the alternative-therapy provisions from roughly seven separate rules into one, with the stated goal of making them shorter and easier to read, but they say the supervision requirements were not fundamentally changed. Because supervision flows from statute 801.151, the board explained it could not remove that requirement through rulemaking even if it wanted to.
The rule review itself was triggered by the board’s 2023 Sunset review, which attached the agency to the Texas Department of Licensing and Regulation for four years and required a full review and rewrite of its rules NOT because of an increase in complaints. Although there have been an increase in complaints about alternative therapy providers in recent years.
The real lever: the legislature
Here is the conclusion that emerged repeatedly on the call, including from veterinarians on the line: because the supervision requirement is set in statute, the board has no authority to remove it. Meaningful change has to go through the Texas Legislature, and the board, as a government agency, is not permitted to lobby for that change.
That puts the responsibility on stakeholders like us.
How the AVMA fits in
To advocate effectively in Texas, it helps to understand the national framework, and that means understanding the American Veterinary Medical Association (AVMA).
The AVMA publishes a Model Veterinary Practice Act (MVPA), a set of template principles that state legislatures and veterinary boards routinely use as a guide when they write or revise their own practice acts. Many states adopt its language closely. Critically for us, the MVPA’s definition of the practice of veterinary medicine expressly includes complementary, alternative, and integrative therapies. That is precisely the framework Texas adopted in 1999, and it is why these modalities fall under veterinary oversight in so many states. The MVPA was most recently revised in 2025 through a multi-stakeholder process and a vote of the AVMA’s House of Delegates (where each state’s veterinary association holds delegates).
The practical implication: if we want the legal definition to evolve, the AVMA and its state affiliate, the Texas Veterinary Medical Association, are not just obstacles. They are stakeholders we can work alongside.
There is a real precedent for this. On the webinar, a representative of the National Board of Certification for Animal Acupressure and Massage described how, in Washington State, advocates brought together the massage board, the physical therapy board, the veterinary board, and the state AVMA chapter to jointly write legislation that ultimately created a licensing pathway for these modalities. Similar approaches have advanced in other states. The lesson is that durable change has come from coalitions that include the veterinary establishment, not from confrontation with it.
Bottom line
The webinar confirmed that the supervision requirements many of us are worried about have been law since 1999 and cannot be undone by the board alone. The path forward runs through the legislature, through the public-comment process on the July draft, and through coalition-building with the veterinary community and the AVMA’s Texas affiliate.
TEXAS Practitioners, here’s what we’re asking you to do!
- Get on our action roster and tell us your county/zip so we can connect you with your legislators when the time comes: [sign-up form]
- Sign up for the vet board’s email list so you get the webinar recording and notice of the July meeting: [TBVME email subscribe link]
- Email us your story — two or three sentences on how these rules affect you, your animals, or your access to care. Your story is what moves legislators. ([email protected])
- Forward this to two people who should be included.
We’ll be back soon with the next steps.
-The AOPP team
May 20, 2026
Alternative Therapy Webinar hosted by the Texas Board of Veterinary Medical Examiners
April 30, 2026
Next board meeting is scheduled for July 21, 2026:
https://veterinary.texas.gov/board-meetings/july-21-2026/
No agenda or updated draft revisions for chapters 571 or 573 have been released yet.
April 21, 2026
Board Meeting Agenda with Link to meeting:
April 20, 2026
Texas Regulatory Update: Proposed Rule Revisions Removed from April 21 Board Meeting Agenda
The Texas Board of Veterinary Medical Examiners has announced that proposed revisions to Chapters 571 and 573 will not be considered at the April 21, 2026 Board meeting.
In an update posted on April 15, 2026 at 1:52 p.m., the Board stated that the draft rule revisions were removed from the agenda. According to the Board, updated draft rules will be prepared and scheduled for consideration at a future meeting.
Additional information, including revised draft language and future meeting details, will be shared once available.
The AOPP will continue to monitor this issue and provide updates as more information is released.
April 2026
Texas Proposed Rule Update: What It Could Mean for Animal PEMF Practitioners
Texas animal PEMF practitioners should pay close attention to a proposed rule update from the Texas Board of Veterinary Medical Examiners. This is not law yet, but if adopted, it would make Texas’s position on animal PEMF much more explicit. The Board is currently accepting public comment, and the deadline is March 31, 2026. Comments should be sent to [email protected].
What is changing?
In the draft revision to Chapter 573, the Board specifically lists pulsed electromagnetic field therapy (PEMF) as an example of “musculoskeletal manipulation” (MSM), alongside electrical stimulation, shockwave therapy, and dry needling. The draft states that animal chiropractic and other forms of MSM are considered alternative therapies in the practice of veterinary medicine.
That matters because the current Texas rule on musculoskeletal manipulation already treats these services as part of veterinary medicine, but it does not expressly name PEMF in the text. The new draft would remove ambiguity by naming PEMF directly.
If enacted, what would this mean for Texas PEMF practitioners?
If this draft becomes final in substantially the same form, Texas would be making it very clear that animal PEMF is not treated as a fully independent wellness activity outside veterinary oversight.
Under the draft, animal PEMF could be performed by:
a licensed veterinarian, or
a non-veterinarian employee or independent contractor working under veterinarian supervision, if the rule’s conditions are met.
Before PEMF could be provided under this rule, the veterinarian would need to have:
an established veterinarian-client-patient relationship (VCPR),
examined the animal to determine the therapy is not likely to be harmful, and
obtained a signed acknowledgment from the owner or caretaker that the therapy is considered an alternate therapy under Texas law.
The draft also adds that when a non-veterinarian employee or independent contractor performs the treatment, the supervising veterinarian must have provided specific manipulations and/or treatments for that person to provide.
Why this is a major issue for independent PEMF businesses
For practitioners who currently operate independently, this proposal would be very significant if adopted. If adopted as written, it could reinforce that a Texas animal PEMF provider generally should not be operating on their own without veterinarian involvement, unless they clearly fall within a separate statutory exemption. The rule itself points back to Texas Occupations Code §801.004 for limited exceptions, but otherwise places PEMF inside the veterinary framework.
It also matters that the draft keeps Texas’s VCPR rule in place: a veterinarian-client-patient relationship may not be established solely by telephone or electronic means. In practical terms, this means remote-only signoff is not a clean solution.
The compliance burden would likely increase
The proposal would not just affect whether PEMF can be offered. It would also affect how it must be documented and supervised. The draft expands veterinary medical record requirements and specifically requires records to include treatment options offered, what the client consented to or declined, and authorizations or acknowledgments, including the signed acknowledgments required by Rule 573.14.
The supervising veterinarian would also remain responsible for delegated acts and for the standard of care associated with the treatment.
What is the AOPP’s concern?
The AOPP supports clarity, training, and accountability. But clarity should not come at the cost of erasing the reality that many non-veterinarian animal PEMF providers operate in limited, non-diagnostic, non-invasive supportive roles.
A rule that explicitly names PEMF without also creating a narrow, practical pathway for trained non-veterinarian providers will:
make existing practitioners vulnerable,
reduce access for animal owners,
discourage collaborative care models, and
treat low-risk supportive PEMF sessions as though they are the same as diagnosis or full veterinary treatment.
Texas has an opportunity to be clear without being unnecessarily restrictive.
How to submit a comment
Email your comment to [email protected] by March 31, 2026. Keep it respectful, specific, and practical. Personal experience matters. If you are a Texas practitioner, explain how this proposal would affect your business, your collaborating veterinarians, and your clients.
Suggested Public Comments to Send:
Option 1:
To the Texas Board of Veterinary Medical Examiners:
I am writing in response to the proposed Chapter 573 draft. I am concerned that specifically listing PEMF as part of musculoskeletal manipulation within the practice of veterinary medicine could be interpreted too broadly and could eliminate limited, non-diagnostic supportive PEMF services provided by trained non-veterinarians.
I support reasonable standards and clear limits. But I ask the Board to consider a narrower framework that allows non-invasive PEMF sessions within defined boundaries, without diagnosis, prognosis, prescription, or representation as veterinary medicine.
Please adopt language that protects the public while preserving a practical pathway for responsible PEMF practitioners.
Option 2:
To the Texas Board of Veterinary Medical Examiners,
I am writing to express concern about the proposed rule language affecting animal PEMF.
I support reasonable standards and clear boundaries. However, I respectfully ask the Board not to adopt language that would automatically treat all non-veterinary PEMF activity as the practice of veterinary medicine.
Non-veterinary supportive PEMF sessions, when provided within defined limits and without diagnosis, prognosis, prescription, surgery, invasive procedure, or representation as veterinary medicine, should not be considered the practice of veterinary medicine solely because a pulsed electromagnetic field device is used.
Please consider a narrower framework that protects the public while preserving a lawful role for limited, non-invasive, supportive PEMF services provided by non-veterinarians.
Thank you for your consideration.
Option 3:
To the Texas Board of Veterinary Medical Examiners,
Thank you for the opportunity to comment on the proposed rule changes.
I respectfully ask the Board to avoid adopting language that would automatically treat all non-veterinary animal PEMF sessions as the practice of veterinary medicine.
Non-veterinary supportive PEMF sessions, when provided within defined limits and without diagnosis, prognosis, prescription, surgery, invasive procedure, or representation as veterinary medicine, should not be considered the practice of veterinary medicine solely because a pulsed electromagnetic field device is used.
I support clear boundaries, public protection, and veterinarian involvement where medical diagnosis or treatment is needed. However, the rule should also recognize the distinction between veterinary medicine and limited, supportive, non-invasive PEMF services provided within appropriate limits.
I respectfully urge the Board to consider narrower language that protects the public without unnecessarily restricting responsible non-veterinary practitioners.
Thank you for your consideration.
