I am writing in response to the: Notice of Intended Regulatory Action Notice is hereby given in accordance with § 2.2-4007.01 of the Code of Virginia that the Board of Veterinary Medicine intends to consider amending 18VAC150-20, Regulations Governing the Practice of Veterinary Medicine.

The purpose of the proposed action is to establish rules for haul-in veterinary facilities. The rulemaking action is result of the 2025 Report of the Large Animal Veterinarian Shortage Study Workgroup. A haul-in veterinary facility allows owners to bring animals to veterinarians at an inspected facility for treatment. Proposed provisions may include developing a model for regulating haul-in facilities, including facility registration, inspection, and treatment standards.

2025 Report of the Large Animal Veterinarian Shortage Study Workgroup

Executive Summary:

Pursuant to the Joint Resolutions, the Board of Veterinary Medicine (“Board") and the State Veterinarian convened a workgroup which met multiple times over the course of 2024. The workgroup considered the required topics of the Joint Resolutions, which were as follows:

The financial resources subgroup recommended exploring development of: (1) a loan repayment program that ties awards to practice in underserved communities; (2) matching awardees of grants with mentors to assist with grant-writing and other facets of mentorship; (3) developing a pathway for haul-in(*1) or shared use large animal veterinary facilities to address shortages in a variety of ways:

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Financial Resources

Haul-in facilities would allow owners to bring animals to veterinarians to be treated at an inspected facility. Currently, there is no provision that allows practice to occur away from the location of the animal. Under current regulations, veterinary medicine may only be practiced out of a registered establishment categorized as stationary (“bricks and mortar") or ambulatory (generally house calls or farm visits). Large animal veterinarians often travel extensively to provide healthcare at animals’ locations, impacting patient safety and contributing to burnout and attrition. Haul-in facilities would enable veterinarians to treat more patients, would address environmental factors (inclement weather, poor barn lighting), and travel times without requiring the veterinarian to incur the financial burden of opening and maintaining a stationary establishment.

I would like to make the following points:

COMMENT 1:  Having owned and operated a large animal ambulatory practice in Virginia for over seventeen years, I treated animals under the jurisdiction and rules of the Commonwealth in a multitude of locations other than on the producer’s farm, including on the producer’s neighbor’s farm, at livestock markets, at fairgrounds, at the Virginia Horse Center, the Salem Civic Center, and other similar venues, at the Beef Expo, the State Fair, “Sissy’s scales on route 42 writing health certificates, the wayside pull-off in Staffordsville, VA where we did Coggins, vaccines, and dental clinics, and on a trailer in my office parking lot, none of which were “a registered establishment” and all of which were “ambulatory” where animals were congregated at a single premises other than the farm of origin.

COMMENT 2:  The Purpose of the proposed action: “A haul-in veterinary facility allows owners to bring animals to veterinarians at an inspected facility for treatment.  is taken out of the context underlined in the committee’s Executive Summary (above).

Note the underlined phrases: “recommended exploring” / “developing a pathway” / “shared use large animal veterinary facilities” / “Haul-in facilities would allow owners to bring animals to veterinarians to be treated at an inspected facility” / “without requiring the veterinarian to incur the financial burden of opening and maintaining a stationary establishment”

It is vague, at best, what exactly the definition of a haul-in facility is, and having only mentioned "inspected" once, it IS only suggestive that they might require inspection.

The KEY POINT here that a the definition of a “Haul-in Facility” has not been established.

I find it premature to establish rules for haul-in facilities before they have been properly defined.

COMMENT 3: If the Board of Veterinary Medicine still sees a need to amend 18VAC150-20, Regulations Governing the Practice of Veterinary Medicine. I suggest it simply adds language such as the following:

Definition of Haul-in Facility: An uninspected premises, other than the farm of origin or a veterinary hospital, that animals are aggregated, transported, or collected at to facilitate the provision of veterinary care by a licensed ambulatory veterinarian.