Proficiency in the medical and surgical care of animals is a prerequisite for any practicing veterinarian. Equally important, but less emphasized in veterinary education, is proficiency in communicating the medical and surgical aspects of patient care to clients and the related activity of medical records keeping. A perceived failure in any of these areas, or in any other facet of clinical practice, may lead an owner to pursue legal recourse, such as a professional negligence or veterinary malpractice lawsuit, potentially leading to serious repercussions for the veterinarian in question. Laws providing remedies for owners of pets that have been harmed or mistreated by veterinarians are in transition,1 and pet owners are learning to leverage more of the legal tools at their disposal. In addition, unhappy clients are increasingly often turning to social media and other forms of online commentary to voice their dissatisfaction in public forums. However, the traditional venues for owners to express dissatisfaction with the veterinary care provided to their animals involve filing either a malpractice suit or a complaint with the state VMB, potentially prompting an investigation into the veterinarian's conduct.
Under the US Constitution, state governments are given the sovereign right to protect the general welfare of their citizens. The states accomplish this, in part, by requiring a license to practice various professions, including veterinary medicine, within the state and by establishing state boards to oversee the administration of those licenses. Every state maintains a VMB that oversees the practice of veterinary medicine and determines whether and what sanctions should be imposed for violations of relevant state statutes and regulations. Depending on the scope of the board's authority, a VMB may impose sanctions on licensed veterinarians, veterinary technicians, and unlicensed individuals engaging in the practice of veterinary medicine, as defined by the state's practice act.
Although the specific procedures involved when a complaint is filed with a state VMB vary, the general outlines are the same. A VMB will initiate an investigation on receipt of a letter of complaint regarding an individual, but may also initiate an investigation absent a specific consumer complaint. Typically, the initial investigation involves a relatively informal examination of the facts surrounding the complaint, although it could include interviewing witnesses. In some states, VMB staff review all complaints and refer only those they deem appropriate to the board. If the board determines that the facts support further action, the case will then progress through various administrative processes established by the VMB. The board may request additional information, including medical records, invoices, and communication logs; undertake site visits and interviews; and require written responses from the individual. In addition, in some states, the VMB may request expert opinions from board-certified specialists.
If the VMB determines that a violation has occurred, it will then proceed to the disciplinary phase, during which it will decide whether sanctions should be imposed on the individual. These sanctions may include fines, probation, continuing education requirements, suspension of licensure, or other actions the VMB sees fit. Importantly, sanctions imposed on a veterinarian in one state may trigger a review by VMBs in other states in which the veterinarian is also licensed.2,3
Because of the potentially serious adverse consequences of VMB disciplinary actions, clinical practitioners should have an appreciation of the major types of owner complaints that result in such actions. The purposes of the study reported here, therefore, were to determine the most common offenses leading to state disciplinary actions and to identify trends in the number of disciplinary actions or changes in the types of offenses over time.
Materials and Methods
To obtain a nationally representative sample of states, the 50 states and 8 territories were grouped according to the 10 Federal Emergency Management Agency regions,a and 1 state or territory within each region was randomly selected by means of standard software.b If any of the selected states or territories was unable to provide detailed information on state disciplinary actions, another state or territory was chosen from the same region by means of the same process.
To obtain insight into trends over time, the authors sought to obtain data for the period from 2005 through 2011 (the most recent year for which complete data were available). When possible, information was obtained from state-maintained websites, but each state was contacted directly to ensure that the information provided on the website was complete and up to date. For states that did not provide disciplinary action information online, officials were contacted by means of information obtained from the state VMB website. Once the proper contact person was identified via email or telephone, a spreadsheet was emailed to that representative for completion.
For all states, information was obtained for each year from 2005 through 2011 on the number of state disciplinary actions taken by the VMB during the year. Disciplinary actions were classified into 17 categories (false or misleading advertising; illegal practices; criminal proceedings; failure to complete continuing education requirements; fraud; dishonesty, a lack of integrity, or unfair dealing; violations of narcotic or prescription regulations; negligence or malpractice; practicing without a license; improper record keeping; defects in sanitation; substance abuse; operating an unlicensed facility; performing unnecessary treatment; unprofessional conduct; violation of a board order; and other). Categories were based on those used by one of the states included in the study. Basic descriptions of the various categories were provided, but not specific definitions. Respondents were asked to provide additional comments for any disciplinary action that did not easily fit one of the predetermined categories.
Number of state disciplinary actions against licensed veterinarians in 10 states from 2005 through 2011, grouped according to type of infraction.
| year | ||||||||
|---|---|---|---|---|---|---|---|---|
| Category | 2005 | 2006 | 2007 | 2008 | 2009 | 2010 | 2011 | Total |
| Negligence or malpractice | 61 (40.4) | 35 (28.2) | 40 (38.5) | 36 (35.3) | 38 (26.4) | 48 (43.6) | 36 (45.6) | 294 (36.1) |
| Improper record keeping | 17 (11.3) | 21 (16.9) | 10 (9.6) | 13 (12.7) | 11 (7.6) | 13 (11.8) | 10 (12.7) | 95 (11.7) |
| Practicing without a license | 13 (8.6) | 8 (6.5) | 7 (6.7) | 8 (7.8) | 19 (13.2) | 5 (4.5) | 7 (8.9) | 67 (8.2) |
| Unprofessional conduct | 9 (6.0) | 13 (10.5) | 7 (6.7) | 4 (3.9) | 17 (11.8) | 5 (4.5) | 1 (1.3) | 56 (6.9) |
| Unlicensed facility | 19 (12.6) | 4 (3.2) | 1 (1.0) | 1 (1.0) | 9 (6.3) | 6 (5.5) | 2 (2.5) | 42 (5.2) |
| Violation of narcotic or prescription regulations | 7 (4.6) | 5 (4.0) | 6 (5.8) | 4 (3.9) | 8 (5.6) | 8 (7.3) | 1 (1.3) | 39 (4.8) |
| Violation of board order | 1 (0.7) | 7 (5.6) | 5 (4.8) | 5 (4.9) | 6 (4.2) | 7 (6.4) | 5 (6.3) | 36 (4.4) |
| Other | 3 (2.0) | 5 (4.0) | 2 (1.9) | 8 (7.8) | 6 (4.2) | 2 (1.8) | 7 (8.9) | 33 (4.1) |
| Substance abuse | 4 (2.6) | 3 (2.4) | 6 (5.8) | 5 (4.9) | 11 (7.6) | 2 (1.8) | 2 (2.5) | 33 (4.1) |
| Failing to complete continuing education | 7 (2.6) | 7 (5.6) | 3 (2.9) | 6 (5.9) | 1 (0.7) | 3 (2.7) | 1 (1.3) | 28 (3.4) |
| Illegal practices | 3 (2.0) | 4 (3.2) | 3 (2.9) | 1 (1.0) | 4 (2.8) | 3 (2.7) | 5 (6.3) | 23 (2.8) |
| Fraud | 0 (0.0) | 4 (3.2) | 5 (4.8) | 3 (2.9) | 3 (2.1) | 1 (0.9) | 1 (1.3) | 17 (2.1) |
| Dishonesty, lack of integrity, or unfair dealing | 3 (2.0) | 5 (4.0) | 4 (3.8) | 1 (1.0) | 2 (1.4) | 0 (0.0) | 1 (1.3) | 16 (2.0) |
| Criminal proceedings | 1 (0.7) | 0 (0.0) | 4 (3.8) | 2 (2.0) | 4 (2.8) | 4 (3.6) | 0 (0.0) | 15 (1.8) |
| Defects in sanitation | 3 (2.0) | 0 (0.0) | 0 (0.0) | 3 (2.9) | 3 (2.1) | 1 (0.9) | 0 (0.0) | 10 (1.2) |
| Unnecessary treatment | 0 (0.0) | 2 (1.6) | 1 (1.0) | 1 (1.0) | 0 (0.0) | 2 (1.8) | 0 (0.0) | 6 (0.7) |
| False or misleading advertising | 0 (0.0) | 1 (0.8) | 0 (0.0) | 1 (1.0) | 2 (1.4) | 0 (0.0) | 0 (0.0) | 4 (0.5) |
| Total | 151 | 124 | 104 | 102 | 144 | 110 | 79 | 814 |
Values in parentheses represent percentages for that year.
Results
Four states initially selected to participate, 2 in one region and 2 in another, did not have the necessary information readily available. These states were replaced by 4 other states, so that information was obtained from 10 states. Five states included in the study maintained websites that contained the necessary information, and therefore officials in these states were contacted solely to confirm the accuracy of the information; for the remaining 5 states, officials were contacted to obtain the necessary information.
The type of information maintained by participating states and made available for the study varied greatly. Some states provided case summaries, and others provided full case information. Two states completed the emailed questionnaire and returned it with no additional information, whereas others provided additional information regarding specific violations. Using all of the available information, we determined that the initial 17 disciplinary action categories were sufficient to summarize the information received, and categories were not adjusted.
The greatest numbers of disciplinary actions taken by state VMBs from 2005 through 2011 were in response to negligence or malpractice (n = 294 [36.1%]), improper record keeping (95 [11.7%]), practicing without a license (67 [8.2%]), and unprofessional conduct (56 [6.9%]; Table 1). These 4 categories represented 62.9% (512/814) of all disciplinary actions taken during the 7-year study period.
There was little change over time in the rankings of the 4 most common disciplinary action categories, with negligence or malpractice always ranked first, improper record keeping always ranked second (except for 2009), and practicing without a license and unprofessional conduct always ranked third or fourth (Figure 1). In addition, subjective evaluation of the data did not demonstrate any sustained (ie, ≥ 3 years' duration) increase or decrease in the number of disciplinary actions in any of these 4 categories over the time frame reviewed. Year-to-year increases and decreases were identified in all categories, most prominently for the negligence or malpractice category. However, the descriptive nature of the study did not allow us to test for statistically significant changes in the number of disciplinary actions over time, and it could not be determined whether perceived differences were a result of natural variations, changes in state VMB resources, changes in state VMB enforcement discretion, or some other factor.
Change over time in percentages of total state disciplinary actions in 10 states for the 4 most common categories of infractions.
Citation: Journal of the American Veterinary Medical Association 244, 12; 10.2460/javma.244.12.1397
Change over time in percentages of total state disciplinary actions in 10 states for the 4 most common categories of infractions.
Citation: Journal of the American Veterinary Medical Association 244, 12; 10.2460/javma.244.12.1397
Change over time in percentages of total state disciplinary actions in 10 states for the 4 most common categories of infractions.
Citation: Journal of the American Veterinary Medical Association 244, 12; 10.2460/javma.244.12.1397
Discussion
It was a challenge to compile information used for the present study, both because of a lack of consistent definitions for disciplinary actions taken by state VMBs and because of a lack of uniform record-keeping systems, which led to inconsistencies in how data were recorded and maintained. Some states meticulously recorded data and made the information easily accessible online, but others did not. An important limitation of the present study, therefore, was an inability to verify the accuracy of the data provided, and it was often difficult to determine the specific conduct or circumstances that resulted in the disciplinary action or even whether specific actions represented small animal or large animal practices. In addition, it would have been valuable to analyze not just the absolute number of disciplinary actions but also the rate of disciplinary actions (ie, the number of state disciplinary actions per veterinarian per year). Unfortunately, some of the states could not provide an accurate count of the number of licensed veterinarians in the state for each year of the study. Additionally, some states have the authority to take action against nonlicensees and veterinary technicians, which would have added another element of complexity to the analysis of rates. Nevertheless, our results do highlight the fact that VMBs are functioning to ensure consumer protections by scrutinizing individuals engaging in the practice of veterinary medicine within the state.
Despite the various limitations of our study, we believe our findings provide valuable insight into the types of offenses most likely to result in disciplinary actions against veterinarians. The largest number of disciplinary actions in any year were consistently related to claims of negligence or malpractice. This is a key finding in that it will allow veterinarians to target their efforts to prevent such actions or reduce their occurrences. The same holds for the next 3 categories, which held fairly consistently. The absolute number of disciplinary actions fluctuated over the 7 years of the study; in particular, the total number reported during 2011 was low. This possibly could have been a result of incomplete reporting at the time the study was undertaken in 2012. Alternatively, the decrease in the number of companion animal visits to veterinary practices may have concurrently reduced the number of complaints. The lower absolute numbers may have artificially skewed the proportions for 2011.
In order to better understand the types of actions that resulted in disciplinary action, it is important to look at how the categories are defined and case examples. In the present study, we did not provide standard definitions or criteria for the 17 disciplinary action categories because of variations among states and even over time within states. That said, some general comments can be made about the types of offenses that could result in disciplinary actions, especially for the 4 most common categories in the present study.
For example, the legal elements for a finding of veterinary malpractice have been explained:4
The gravamen (ie, the material or important part of a grievance or complaint) of (a veterinary malpractice) action is that in providing veterinary care, the veterinarian failed to use such reasonable skill, diligence, and attention as might ordinarily have been expected of careful, skillful, and trustworthy persons in the profession. The courts have generally recognized that for the owner of an animal to prevail in such an action, he or she must prove the relevant recognized standard of care exercised by other veterinarians, the defendant veterinarian's departure from that standard when treating the animal, and some injury to the owner proximately caused by that departure.4
As an example of the type of actions that could result in a finding of negligence or malpractice, a state VMB reportedly revoked the license of a veterinarian and sentenced the veterinarian to probation for 1 year after it was determined that the veterinarian failed to monitor an ill dog that was to be placed in intensive care. The animal died after 3 days of minimal observation by the veterinarian. When the case was brought to court, the judge held that the veterinarian was negligent for leaving the dog unmonitored, while receiving IV fluids, for up to 7.5 hours for 3 successive nights.
A good example of a record-keeping law can be found in the Rhode Island statutes, which state that a “veterinarian … shall keep a written record, or a computerized record able to produce a printed copy, of all animals receiving veterinary services…. The minimum amount of information to be included in written or computerized records and summaries shall be as established by rules and regulations.”5
One state VMB found that a veterinarian departed from or failed to conform to the minimum standards of acceptable and prevailing medical practice on several occasions, and also held that the veterinarian's errors were compounded by poor record keeping, including poor charting of diagnoses, test results, treatment plans, and treatment implementation. The veterinarian characterized the record keeping deficiencies as mere administrative issues, but the judge assigned to the case viewed this conduct more severely and found that the veterinarian's poor record keeping constituted a serious deviation from the standards of the profession.
The unauthorized practice of veterinary medicine includes veterinarians acting without a current license, veterinarians acting with a restricted license, and non-veterinarians performing actions that fall within the scope of veterinary medicine over which the state has authority.6 These offenses may result in a felony or, more commonly, misdemeanor charge.7 Most states have provisions allowing for injunctions, cease-and-desist orders, and fines.8
An example of disciplinary action related to practicing without a license, which also highlights the complexity that may characterize these types of violations, involved a dog that died after a veterinarian ordered an unlicensed veterinary technician to radiograph the dog. The state VMB disciplined the veterinarian for misconduct, because state statutes prohibited unlicensed technicians using radiographic equipment, and the licensed veterinarian was held to be vicariously liable for the actions of the unlicensed veterinarian technician. Additionally, the court found that the VMB properly ordered the veterinarian to pay the fees of the board's expert witness.
Few states clearly define unprofessional conduct. One that does is Maine:
“A. Advertising in any manner considered by the board to be false, misleading or otherwise deemed unprofessional; B. Knowingly making any false or fraudulent statement, written or oral, in connection with the practice of veterinary medicine; C. Refusing to divulge to the board upon demand, the means, method, device or instrumentality used in the treatment of a disease, injury, ailment or infirmity of any animal; or D. Fraud or dishonesty in the application or reporting of any test for disease in an animal or making a false report of any contagious or infectious disease.”9
In contrast, the Minnesota statutes simply state that “engaging in unprofessional conduct as defined in rules adopted by the board or engaging in conduct which violates any statute or rule promulgated by the board or any board order” will allow the board to revoke, suspend, or impose limitations upon a license.10
Illustrating difficulties that can arise with claims of unprofessional conduct is the case of a dog owner who made several appointments to have her dog euthanized. The dog was blind in 1 eye and having difficulties breathing, and the veterinarian had recommended euthanasia because of the dog's chronic dyspnea. The owner missed several appointments, but ultimately did bring the dog in to be euthanized. The procedure proved difficult owing to the animal's condition, and the dog collapsed and died prior to the actual euthanasia. The owner then claimed that the veterinarian had killed her dog and filed a complaint with the state VMB. After an investigation was initiated, the veterinarian phoned the dog's owner, telling her that “he prayed every night that she would rot in hell.” The board found that the veterinarian had demonstrated professional incompetence by his verbal harassment but that the euthanasia procedure had been done in a non-negligent manner. The veterinarian filed suit opposing the ruling that he had demonstrated professional incompetence and suggesting that the VMB had overstepped its authority by regulating conduct that was not covered by the state practice act. The court ruled that rude and discourteous behavior does not fall within the ambit of professional incompetence, that poor manners do not equate with incompetence, and that the veterinarian's conduct was not subject to license discipline.
Trends in state regulations help highlight those areas in which regulatory bodies are focusing their attention—and where disciplinary actions may be more likely to occur—in their efforts to protect the public. Importantly, states regularly advocate for strengthening consumer protections through legislation, and from 2007 through 2012, numerous changes have been made in state practice acts that impact veterinarians, including matters of record keeping, animal cruelty reporting, licensure, professional conduct, and sanctions related to license discipline penalties.
For instance, traditionally a successful claim of malpractice has required that 4 elements be present: duty, breach, proximate cause, and damages. The duty element is established by the existence of a veterinary-client-patient relationship, and it is generally accepted that veterinarians have control over when this relationship is established and what actions are undertaken within the relationship. Recently, however, regulations have been adopted that further define the scope of the veterinary-client-patient relationship and that place additional requirements on veterinarians. For example, Pennsylvania has adopted regulations that create exceptions to veterinary discretion, requiring veterinarians to provide euthanasia, notify the client before terminating care of a client's animal, provide details about the veterinarian's duty to protect the personal privacy of clients, explain the benefits and important potential risks of treatment options, and obtain written consent to euthanize an animal or administer treatments that carry substantial risks.11 Veterinarians who fail to meet these additional requirements may be at an increased risk for claims of malpractice.
Some states, such as Pennsylvania, allow the board to sanction a veterinarian who has allowed the risk of malpractice to increase unacceptably but has not yet committed malpractice. A veterinarian who fails, for instance, to recognize the limits of his or her own expertise and neglects to refer a patient to another veterinarian could be subject to censure under this provision.11,12
The most common state legislative changes nationwide, however, relate to record-keeping requirements. Changes have been made relative to required record content, requirements for the release of records to clients on request or following a change in practice status, sanctions for record-keeping violations, and required records retention duration, which several states have recently increased. For example, Illinois now requires maintenance of records for a minimum of 5 years (rather than 3) from the date of last known contact, and copies must be released to the client on written request.13 Pennsylvania changed its requirement to provide greater details for the content of veterinary records, increased the duration that records must be retained, and required veterinarians to provide records to clients within 3 days of a request.11
Pennsylvania added an explicit requirement that veterinarians document communications with clients, including consent to or rejection of recommended diagnostic tests and treatments.11 Washington also adopted regulations that clarify what must be included and maintained in veterinary patient records.14 This regulation also clarified who may request copies of patient records and fees that may be charged. It also shortened the time to respond to a request for records from 15 to 10 days.
Also, several states now have more specific requirements on the release of medical records. For example, if the veterinarian-client relationship is ended or the practice closes, Texas requires that veterinarians ensure that clients receive reasonable notice and have an opportunity to obtain copies of records or arrange for these records to be transferred to another veterinarian.15 New Jersey adopted rules on how a veterinary licensee or executor must handle records when a veterinary practice permanently closes.16
Arizona specified in 2010 that its VMB may designate minor records violations as administrative violations, rather than as unprofessional conduct, if the items in question are routine entries in the medical records and do not affect the diagnosis or care of the animal.17 Idaho allows a veterinarian who has violated record-keeping requirements to pay a fine in lieu of disciplinary proceedings.18
In Mississippi, legislation passed in 2010 requires the VMB to respond to public records requests on written request within 7 working days from the receipt of request.19
In the realm of unlicensed veterinary practice, veterinary dentistry has recently been the subject of substantial regulatory activity. In 2013, the Texas Board of Veterinary Medical Examiners issued a new definition of dentistry while addressing the duties and practice limitations of registered veterinary technicians. In 2013, legislation in New York was proposed that would include the treatment of dental conditions in the definition of veterinary medicine but exempt persons who float horse teeth.20
Finally, in regard to unprofessional conduct, the Hawaii Board of Veterinary Medicine can, as of 2009, revoke or suspend a veterinary license or fine a licensee for conduct or practice contrary to the recognized principles of veterinary medical ethics of the veterinary professional as adopted by the Hawaii Veterinary Medical Association and the AVMA.21 In 2011, Arizona amended its description of unprofessional conduct to include representing that the veterinarian is a specialist if the veterinarian lacks the credential to be a specialist.22
Conclusions can be drawn from the numbers and types of disciplinary actions, case examples, and changes to state regulations that govern the profession. These conclusions help inform the development of the following recommendations to better protect and guide veterinary professionals to avoid potential disciplinary actions.
According to the AVMA PLIT, the leading cause of malpractice claims in both human and veterinary medicine is miscommunication.23 Given that, in our study, negligence or malpractice was the most common cause of state disciplinary actions, veterinarians would do well to evaluate how well they are communicating with their clients. Also, in taking the Veterinarian's Oath, veterinarians accept the responsibility of continually advancing their professional knowledge and competence, but for many of the disciplinary actions identified in the present study, practitioners likely would have benefited from continuing education in record keeping and communication skills. Veterinarians also need to evaluate the limitations of their own skills and their ability to handle specific cases, and should offer referral to specialists when cases exceed their capabilities.
Relating information to clients but failing to document it in the record is clearly a source of problems, particularly when records come under examination by VMBs. Conversely, a piece of information deemed worthy as a written medical note in a patient's chart may also be relevant to the client, particularly remarks that relate to zoonoses or other conditions of human health concern. In general, veterinarians should consider providing written consent forms and discharge instructions for clarity in communications. Finally, records management could be enhanced through the use of electronic, rather than handwritten, records.
Veterinarians are legally bound by the laws and regulations of the states in which they are licensed and as such should familiarize themselves with the directives that guide the practice of veterinary medicine in those states. Such information is typically available online through the state licensing board website. Veterinarians should review this information when applying for licensure, but should also plan on re-reviewing it on a regular basis, as regulations may change. Increasingly, VMBs are using guidelines embodied in the Principles of Veterinary Medical Ethics of the AVMA as the basis for their determination of appropriate conduct, so veterinarians should familiarize themselves with these guidelines. As an example, in 2013, Connecticut adopted a statute providing that in determining whether a veterinarian has acted with negligence, the Connecticut Board of Veterinary Medicine may consider standards of care and guidelines published by the AVMA, including guidelines for the use, distribution, and prescribing of prescription drugs.24
Keeping abreast of legislative changes will help inform veterinarians of trends in state statutes and regulations. Through its website, the AVMA provides information on various state laws, links to state information, a monthly summary of state legislative activity, and a year-end wrap of important bills and regulatory changes, organized by topic.25 This is an excellent resource for information on potential changes to various state practice acts.
ABBREVIATION
| VMB | Veterinary medical board |
Region I includes Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont; region II includes New Jersey, New York, Puerto Rico, and the Virgin Islands; region III includes Delaware, the District of Columbia, Maryland, Pennsylvania, Virginia, and West Virginia; region IV includes Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, and Tennessee; region V includes Illinois, Indiana, Michigan, Minnesota, Ohio, and Wisconsin; region VI includes Arkansas, Louisiana, New Mexico, Oklahoma, and Texas; region VII includes Idaho, Missouri, Nebraska, and Kansas; region VIII includes Colorado, Montana, North Dakota, South Dakota, Utah, and Wyoming; region IX includes Arizona, California, Hawaii, Nevada, American Samoa, Guam, the Mariana Islands, the Marshall Islands, and Micronesia; and region X includes Alaska, Idaho, Oregon, and Washington.
RANDBETWEEN, Excel 2007, Microsoft Corp, Redmond, Wash.
References
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3. Mueller, DVM, 2006 WL 949920 (Mo. Admin. Hrg. Comm. 05–1112-VM, Mar. 6, 2006).
4. Cheryl M. Bailey, Veterinarian's liability for malpractice, 71 A.L.R. 4th 811, 816, § 2(a) (1989).
5. R.I. Gen. Laws § 5–25–7.1(a) (2012).
6. Commonwealth v. Heller, 121 A. 558 (Pa. 1923).
7. Elisea v. State, 777 N.E.2d 46 (Ind. Ct. App. 2002).
8. Gilman v. Nev. State Bd. of Veterinary Med. Examiners, 89 P.3d 1000 (Nev. 2004).
9. Me. Rev. Stat. tit. 32, § 4864(11) (2013).
10. Minn. Stat. § 156.081 (2013).
11. 49 Pa. Code § 31.21 (2013).
12. Nelson v State Bd. of Veterinary Med., 863 A.2d 129 (Pa. 2004).
13. 225 Ill. Comp. Stat. 115/25.17 (2013).
14. Wash. Admin. Code § 246–933–320 (2013).
15. 22 Tex. Admin. Code § 573.55 (2013).
16. N.J. Admin. Code § 13:44–4.9 (2013).
17. Ariz. Rev. Stat. § 32–2233 (2013).
18. Idaho Code Ann. § 54–2118 (2013).
19. Miss. Code Ann. § 25–61–5 (2010).
20. S.B. 2742, 2013 Leg., Reg. Sess. (N.Y. 2013).
21. Haw. Rev. Stat. § 471–10 (2013).
22. Ariz. Rev. Stat. § 32–2232 (2013).
23. AVMA PLIT. Owner consent: a wise investment. Prof Liabil 2010; 29: 2. Available at: avmaplit.com/uploadedFiles/AVMAPLIT/Publications/Professional_Liability/Professional%20Liability%20Summer%202010.pdf. Accessed Sep 24, 2013.
24. S.B. 918, 2013 Reg. Sess. (Ct. 2013).
25. State and local issues. AVMA. Available at: https://www.avma.org/Advocacy/StateAndLocal/Pages/default.aspx. Accessed Nov 8, 2013.
