OPEN LETTER TO THE AVMA
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AVMA's proposed Model Veterinary Practice Act
An open letter to the AVMA Practice Act Task Force
 
 

*NOTE: The AVMA Practice Act Task Force (PATF) is accepting comments postmarked no later than March 15, 2003. If you would like to add your name and endorsements to our Open Letter, please contact Robert Imrie by March 10, 2003, at which time we will forward supporting signatures to the AVMA Practice Act Task Force. To see our current list of supporters, see Here.
 

The AVMA is attempting to formulate a Model Veterinary Practice Act, and, unfortunately, they seem to be intent upon "pleasing ALL veterinary practitioners," even ones who have elected to employ unproven, disproved and/or irrational "alternatives" to scientific biomedicine. (For details, see http://www.avma.org/education/mvpa/default.asp and, for a PDF copy of the proposed act, http://www.avma.org/education/mvpa/mvpa_commentary.pdf). We feel this move is in the best interests of neither the public, veterinary patients, nor the veterinary profession. We have written the following "open letter" to the AVMA Practice Act Task Force, and we urge anyone who agrees with our position to contact us by e-mail so that they can add their names (along with city/state/country) to the "list of signatory parties" to the letter. The letter will ultimately be forwarded to the AVMA and other appropriate entities.

To the AVMA Practice Act Task Force,

While we, the undersigned, appreciate both the need for revising the AVMA Model Veterinary Practice Act and the difficulties inherent to updating such a document, we feel it would be a serious mistake, on several grounds, for the AVMA to attempt to define and regulate unproven, disproved, irrational and/or unscientific "complementary, alternative, and integrative therapies" as the "practice of veterinary medicine," as the proposed, revised AVMA Model Veterinary Practice Act [MVPA] attempts to do. (See excerpted passages from the proposed, revised AVMA MVPA cited below.) )

If such provisions are included in the final draft of the AVMA MVPA, and if any state should subsequently include such provisions in their state's veterinary practice act [VPA] as a result, said state VPA would almost certainly be subject to successful legal challenge. Indeed, in the state of North Carolina, a lawsuit brought by the state veterinary board against a chiropractor practicing on animals was just dismissed because the relevant statute was considered too vague (State of North Carolina v. Gilligan, New Hanover County, NC, file no. 02CR10756).

In addition, the precedents in human medicine are clear. One does not have to be a physician to practice chiropractic on humans in any state in the Union. Likewise, there are few if any statutory requirements that acupuncturists, homeopaths, herbalists, or "manipulative therapists" be physicians. How can anyone reasonably claim a substantially higher standard for veterinary medicine than the one that already exists in human medicine? If one doesn't have to be a physician to legally administer these putative therapies to people, it makes no sense that one should have to be a veterinarian to administer them to animals.

It should be noted that, while the 1996 AVMA Guidelines on Complementary and Alternative Veterinary Medicine included language to the effect that alleged CAVM therapies constitute "the practice of veterinary medicine," such language was wisely abandoned in the 2001 Guidelines. Non-veterinarian practitioners and proponents of such "CAM" therapies have argued that, by taking the position that any therapy applied to animals constitutes the practice of veterinary medicine, the veterinary profession is merely attempting to protect it's own turf. We feel these arguments have merit - even though we don't support the apparent intent of their authors. As one critic of CAVM therapies has wryly observed, "if you're going to nail a dead chicken to a horse's stall and call it therapy, why would you care whether or not the 'therapist' doing the nailing has a veterinary degree?"

Furthermore, some practitioners of CAVM modalities explicitly state that what they do is not "the practice of medicine." This is the position of the American Veterinary Chiropractic Association; it was also held by a veterinary homeopath who sued the Texas State Board of Veterinary Medicine (Ralston v. Texas State Board of Veterinary Medical Examiners, Travis County, Texas, Case no. 97-00203). If CAVM practitioners state that they are not practicing veterinary medicine, how can the AVMA rationally disagree?

In our view, attempting to include any and every alleged animal therapy under the umbrella of "the practice of veterinary medicine" is, in fact, contrary to the best interests of the veterinary profession as well as the best interests of our patients and clients. In our view, the appropriate "turf" for the veterinary profession is science- and evidence-based medicine. At least it's a "turf" the profession can reasonably hope to defend on a rational and objective basis. We think it would be unwise for the profession to embrace, and therefore eventually be forced to defend, therapies that have no objective evidential or rational basis.

History has shown that unproven and disproved "alternatives" to rational therapy are difficult, if not impossible, to regulate in any objective or meaningful way. For instance, how does one effectively regulate "Chinese herbs" in view of the fact that, according to the tenets of traditional Chinese herbalism, it is perfectly acceptable to "substitute" plant material from one species with material from an entirely different and unrelated genus - merely on the basis of shape, color, or cosmological considerations? How does one determine whether or not a veterinary acupuncturist knows the "proper" location of acupuncture points and meridians in his/her animal patients when the ancient and medieval Chinese medical and veterinary literature clearly indicates that putative acupuncture points in humans have moved several times over the last 1,500 years, that the "needling (bleeding) points" of animals are not at all the same as the acupuncture points in humans, or when neither acupuncture points nor meridians have been shown to exist as discrete entities in any species? How does one determine that a veterinary homeopath is "competently" treating his/her patients when the best available scientific evidence indicates that no bona fide homeopathic treatment has ever been shown to be effective, above placebo, in the treatment of anything?

Embracing as "the practice of veterinary medicine" therapies that have clearly and repeatedly been shown not to work can only cause irreparable harm to the veterinary profession. If the profession intends to embrace even unproven, disproved, irrational and highly implausible therapies as such, we believe it will ultimately bear responsibility for defending not only its decision, but for defending the use and "misuse," by veterinarians, of all such alleged therapies. Veterinary medicine cannot be scientific and non-scientific at the same time.

For all of these reasons, we urge the AVMA Practice Act Task Force to eliminate all references to allegedly "complementary and alternative veterinary medicine" [CAVM] from the Model Veterinary Practice Act [MVPA]. We also respectfully suggest that, in order to limit future AVMA responsibility and liability with regard to inevitable "bad clinical outcomes" resulting from the application of unproven, disproved and irrational veterinary therapies, the committee consider proactively wording the appropriate sections so that they clearly indicate that, in the eyes of the AVMA, veterinarians are only "practicing veterinary medicine" when their ministrations involve rational, science- and objective evidence-based therapies. Otherwise "they are on their own."

The Veterinarian's Oath specifically obliges us to use our "scientific knowledge and skills for the benefit of society"" It says nothing about "alternatives" to scientific knowledge or skill. We believe that it would be in the best interests of both society and the profession for the AVMA MVPA to adhere to the standard clearly mandated in our professional oath.

Robert Imrie, DVM
Coordinator, NCAHF Veterinary Task Force
Director, Task Force for Veterinary Science, http://www.vet-task-force.com

David Ramey, DVM
Equine advisor, NCAHF Veterinary Task Force
Co-founder, Task Force for Veterinary Science, index.html
Member, 1999 AVMA Task Force for CAVM
 

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From the proposed AVMA Model Veterinary Practice Act:

(From Section 2 (pages 2 and 3), regarding "definitions":)

6) "Complementary, alternative, and integrative therapies" means a heterogeneous group of preventive, diagnostic, and therapeutic philosophies and practices, which at the time they are performed may differ from current scientific knowledge, or whose theoretical basis and techniques may diverge from veterinary medicine routinely taught in accredited veterinary medical colleges, or both. These therapies include but are not limited to veterinary acupuncture, acutherapy, and acupressure; veterinary homeopathy; veterinary manual or manipulative therapy (ie, therapies based on techniques practiced in osteopathy, chiropractic medicine, or physical medicine and therapy); veterinary nutraceutical therapy; and veterinary phytotherapy.

[...]

18) "Practice of veterinary medicine" means:

a) To diagnose, treat, correct, change, alleviate, or prevent animal disease, illness, pain, deformity, defect, injury, or other physical, dental, or mental conditions by any method or mode; including: [...]

ii. the use of complementary, alternative, and integrative therapies [...]

(From page 4, commentary on section 2:)

The definition of the practice of veterinary medicine in the 2002 draft revision includes the use of complementary, alternative, and integrative therapies, which is also defined in Section 2, subsection 6. The definition used for the MVPA is based largely on that in the AVMA Guidelines for Complementary and Alternative Veterinary Medicine, which were approved by the AVMA Executive Board in 2001. The AVMA recognizes that clients may seek any of a number of treatment modalities for their animals. However, when applied to animals, these treatment modalities represent the practice of veterinary medicine, and as such, are subject to regulation as outlined in the practice act. [...] The AVMA also believes veterinarians should ensure that they have the requisite skills and knowledge for any treatment modality they may consider using. The foremost objective in veterinary medicine is patient welfare. Informed consent should be obtained prior to initiating any treatment, including complementary, alternative, and integrative therapies.
 

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Interested parties wishing to add their signatures to our Open Letter to the AVMA Practice Act Task Force may do so by emailing us directly, or by using our contact form. Please include your full name, city, state and country.

Robert Imrie, DVM
Director, Task Force for Veterinary Science

David Ramey, DVM
Co-founder, Task Force for Veterinary Science

For a list of current supporting signatures, and to find out how to add yours, please see HERE.
 

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