The proposed rule modifies veterinary licensing processes for clarity, consistency, and to ensure there are processes for all applicant types. Without these changes, there would continue to be unintentional gaps preventing applicants with unique circumstances from having a path to licensure. The rule draft makes the following changes:
The rule draft removes language in s. VE 1.14 (6) that limits who must apply by examination or endorsement. The language was added in 2022 and created problems by limiting the licensing processes available to applicants. Removing this language allows applicants who cannot apply by endorsement to instead apply by examination. This change also removes an inconsistency that currently says a Wisconsin licensee must apply by endorsement. The rule draft adds language to ss. VE 1.14 (1) and VE 1.28 (1) and (2) to make it clear that the Board may review an application for items listed under s. VE 1.20. This clarification addresses the concerns that led to the limitations under s. VE 1.14 (6) that were created in 2022. For example, an applicant with discipline in another jurisdiction applying by examination is still subject to review under s. VE 1.20. The rule draft adds language to s. VE 1.20 to make it clear that the section applies to both new applicants for licensure and applicants for renewal. This clarification addresses the concerns that led to the limitations under s. VE 1.14 (6) that were created in 2022. For example, an applicant who was previously licensed in Wisconsin, then licensed in another jurisdiction, and received discipline from the other jurisdiction, is still subject to review under s. VE 1.20. The rule draft adds language to s. VE 1.16 (1) to create a process for applicants by examination who have not passed the North American Veterinary Licensing Examination (NAVLE) in the past 5 years. This addition includes language consistent with s. VE 1.28 (2) regarding the Board inquiring as to whether the applicant is competent to practice and imposing reasonable conditions. The rule draft adds language to s. VE 1.18 (3) to create a process for applicants by endorsement who have neither satisfied the qualifications for licensure, in s. VE 1.16, within the last 5 years nor actively practiced for 4,000 hours during the 5 years preceding application. This addition includes language consistent with s. VE 1.28 (2) regarding the Board inquiring as to whether the applicant is competent to practice and imposing reasonable conditions. The rule draft makes minor edits throughout the licensing processes to consistently use the term “jurisdiction”.
Summary of, and Comparison with, Existing or Proposed
Federal Statutes and Regulations
Licensure requirements to practice veterinary medicine are established by each state and are not established by federal statutes or regulations.
Pursuant to 9 CFR 160 to 162, a veterinarian must be specifically authorized by the United States Department of Agriculture – Animal and Plant Health Inspection Service to perform animal disease eradication and control functions under federal animal health laws. Summary of Comments Received during Preliminary Comment Period
and at Public Hearing on Statement of Scope
The Board held a preliminary hearing on the statement of scope (SS 109-23) on February 13, 2024, with comments open until February 15, 2024. The hearing offered a combination of in-person access and remote access. There were no attendees at the hearing, in-person or remote, and no written comments were received. Comparison with Rules in Adjacent States
The proposed rule modifies veterinary licensing processes for clarity, consistency, and to ensure there are processes for all applicant types. These changes are specific to Wisconsin rules and address unintentional gaps in current licensing processes. Adjacent states also have veterinary boards that license veterinarians.
Illinois
Illinois veterinary licenses are issued by the Illinois Veterinary Licensing and Disciplinary Board, attached to the Illinois Department of Financial and Professional Regulation.
Iowa
Iowa veterinary licenses are issued by the Iowa Board of Veterinary Medicine, attached to the Iowa Department of Agriculture and Land Stewardship.
Michigan
Michigan veterinary licenses are issued by the Michigan Board of Veterinary Medicine, attached to the Michigan Department of Licensing and Regulatory Affairs.
Minnesota
Minnesota veterinary licenses are issued by the Minnesota Board of Veterinary Medicine.
Summary of Factual Data and Analytical Methodologies
There are unintentional gaps and inconsistencies in current veterinary licensing processes. The Board reviewed veterinary licensing processes, assessed what process would apply to each applicant type, and identified unintentional gaps preventing applicants with unique circumstances from being able to apply. The proposed rule modifies veterinary licensing processes for clarity, consistency, and to ensure there are processes for all applicant types.
Analysis and Supporting Documents used to Determine Effect on Small Business or in Preparation of an Economic Impact Analysis
Most veterinary practices are small businesses. The Board expects the proposed rule to have minimal to no economic impact. Under the current rules, there are unintentional gaps preventing some applicants with unique circumstances from applying. The proposed rule modifies veterinary licensing processes for clarity, consistency, and to ensure there are processes for all applicant types. The proposed rule would have a positive impact on those applicants who do not currently have an application process, and would not impact other applicants or licensees.
Fiscal Estimate and Economic Impact Analysis
The Fiscal Estimate and Economic Impact Analysis is attached.
Effect on Small Business
The Department’s Regulatory Review Coordinator, Bradford Steine, may be contacted by:
Telephone at (608) 405-0370
The Regulatory Flexibility Analysis is attached.
Department Contact Person
Angela Fisher
Division of Animal Health
Department of Agriculture, Trade and Consumer Protection
P.O. Box 8911
Madison, WI 53708-8911
(608) 224-5051
Place Where Comments are to Be Submitted and Deadline for Submission:
Comments must be received on or before March 18, 2025, to be included in the record of rule-making proceedings. Submit comments:
By mail to:
Angela Fisher
Division of Animal Health
Department of Agriculture, Trade and Consumer Protection
P.O. Box 8911
Madison, WI 53708-8911
RULE TEXT
Section 1. VE 1.14 (1) and (6) are amended to read:
