A square peg in a round hole: Six major roadblocks to the mid-level practitioner proposal

A square peg in a round hole: Six major roadblocks to the mid-level practitioner proposal

The mid-level practitioner…what is it, and how could it impact veterinary medicine in Colorado? For over a year, CVMA has been asking these questions to see whether a new veterinary professional could positively impact the delivery of veterinary medicine in Colorado. This article is the third in a series exploring the concept of the mid-level practitioner and examining what may make sense for Colorado.

Interested in being a part of the conversation? CVMA is hosting a town hall Q&A session on Thursday, January 19 — click here to register, and click here to submit comments/questions in advance.

The previous article in this series submitted by Drs. Apryl Steele and Wayne Jensen proposes the creation at CSU of a Professional Science Master’s Degree in Veterinary Clinical Care. The program would total five semesters – three semesters online and two in-person. To date, the specifics of admissions criteria, prerequisites, knowledge, skills, abilities, and curriculum have been loosely articulated. Under the proposal, graduates of the program would diagnose, initiate treatment, prescribe, and perform surgery of “uncomplicated cases” under direct supervision of a licensed veterinarian.

CVMA does not see this as a workable concept. There are at least six major roadblocks to the mid-level professional that is proposed.


  1. FDA allows only licensed veterinarians to prescribe

The U.S. Food, Drug and Cosmetic Act stipulates that only licensed veterinarians may prescribe on-label off label, and extra-label drugs to animals. This means that mid-level professionals would be unable to manage straightforward cases that require new prescriptions or revised prescriptions without demanding time and attention from a veterinarian.


  1. USDA accreditation is available only to licensed veterinarians

Food animal veterinarians have been stretched very thin in Colorado for many years. For reasons of food safety, health certificates for interstate and international trade, feed directives and issues of anti-microbial and anti-helminthic resistance, as well as economic pressures, there has not been an innovative breakthrough that increases capacity for this sector of veterinary medicine. The mid-level provider, as described would not have a focus on rural or food animal veterinary medicine. This is one of the many hurdles for the mid-level practitioner program that must be addressed before we can reasonably consider this program a good investment for CSU, its potential students, and rural veterinarians.


  1. Veterinarians perform four essential tasks

The laws of Colorado and of the U.S. clearly allow only licensed veterinarians to perform these four essential tasks: Diagnose, Initiate treatment; Prescribe, and Perform surgery. This means that the proposed mid-level practitioner would not be able to perform these tasks in Colorado and most of the U.S. without changes to individual state laws.


  1. How we determine competence to practice

Across the country, consumer and patient protection relies on competence to practice veterinary medicine. Competence and qualifications for licensure are determined by defined courses of study for DVMs and veterinary technicians, rigorous, uniform accreditation and re-accreditation processes conducted by AVMA, and national-level competence examinations such as the NAVLE, ECFG, PAVE, and the VTNE.

None of these assurances of competence – a curriculum, a competency examination, an accreditation program, or regulation by a state licensing body — exist for a mid-level practitioner. How will owners, employers, and colleagues be assured of a mid-level practitioner’s competence to practice?

Accurate diagnosis – the identification and naming of a disease, illness, or condition — is the essential and most challenging task that veterinarians are educated to perform. Diagnosis, prognosis, and development and implementation of a treatment plan are the essence of what veterinarians learn to do with four very rigorous years of study. CVMA is not convinced that veterinarians, clients, or patients will benefit from mid-level practitioners with incomplete knowledge of diagnosis. Veterinarians remain uniquely qualified to prescribe, diagnose, initiate treatment, and perform surgery due to the robust training they receive.


  1. Effective engagement of veterinary personnel talent

The benefit of having additional veterinary personnel available in a veterinary practice is only useful if they are appropriately trained and properly leveraged so that both veterinarians and veterinary personnel can work at their highest level. This is the foundation of increasing capacity for care and improving efficiency.

While it is thought that mid-level practitioners could expand the capacity in a veterinary hospital, the reality is that with limited training, they would be unable to adequately add capacity. There would be significant demand for mentoring, communication, and guidance. It is proposed that mid-level practitioners could manage “uncomplicated” cases. However, determining the degree of complication is not always apparent at first, and no list of “uncomplicated cases” has been provided. It is prudent to assume that the proposed mid-level practitioner would demand a great deal of veterinarian oversight.

The profession is currently not utilizing our veterinary technicians to their full capacity. We are not using the help we have already in our clinics to the maximum level of their education and training. The stakeholder process has made it quite clear that veterinarians and even technicians frequently do not clearly understand what tasks can and should be delegated to technicians. Veterinary technicians are, generally speaking, vastly underutilized in terms of their education, their ability to contribute to clinical practice and overall efficiency. Introducing a new mid-level practitioner to the equation would only further confuse technicians and veterinarians and make the process of appropriate utilization of veterinary personnel even more difficult.


  1. The projected salary for mid-level practitioners does not fit the current reality

In 2022, the AVMA reported that only 43% of all 2021 graduates earned $80,000 per year or more. It is not clear why it is assumed that the mid-level practitioner would earn $80,000 per year. In 2021, the mean salary for veterinary technicians in Colorado was an estimated $42,000. CVMA questions the idea that a mid-level practitioner would merit a salary double that of a veterinary technician, given the similarity in their ability to offer increased capacity of care.


We need to find a better way

In conclusion, CVMA observes — here in Colorado and across the country — the veterinary profession is stretched in shelter settings, companion animal practice, mixed animal practice, food animal practice, rural practice. Based on the discussions held since June of 2022 in the Working Group organized by Rep. Karen McCormick, the proposed mid-level practitioner does not offer significant benefit for any of these sectors.

CVMA’s assessment is that given these six major roadblocks, the effort required to launch a mid-level practitioner program in Colorado does not provide enough benefit to proceed. We owe it to veterinary professionals and Colorado’s animals and their owners to find a better, faster, more practical way to go forward.


Have questions or comments? Click here to submit them! CVMA will host a member town hall January 19 during which submitted questions will be addressed.