03/26/2025
RAAHP Canada needs your support!
The College of Veterinary Professionals of Ontario (CVPO) has recently finalized its proposed regulatory concepts to support the implementation of the new Veterinary Professionals Act (VPA), 2024. The CVPO is currently seeking consultation and feedback from healthcare professionals, stakeholders, and the public.
The Registry of Animal Health Practitioners of Canada (RAAHP) welcomes several aspects of the VPA as outlined by the CVPO. However, certain provisions within the Act may inadvertently restrict patient access to services and limit interprofessional collaboration by prohibiting non-veterinarian animal health practitioners from performing specific tasks currently within their scope of practice in Ontario.
Healthcare professionals and the general public are encouraged to participate in the consultation process by completing the survey available at:
https://www.cvo.org/veterinary-practice/consultations/regulatory-concepts
The deadline for submission is April 16, 2025. The survey includes demographic questions and offers the flexibility to provide feedback on all topics or select specific areas of interest. While all sections are important, we specifically encourage you to comment on the following key areas are particularly relevant to interprofessional practice and patient care.
Key Areas of Interest for Non-Veterinarian Healthcare Professionals:
1. Non-Delegable Activities
The VPA designates the communication of a diagnosis (encompassing diseases, disorders, dysfunctions, or clinical presentations) as a non-delegable activity exclusive to veterinarians. This restriction will impede collaborative care models, limiting the ability of veterinarians to consult with allied professionals such as animal physiotherapists, chiropractors, or Traditional Chinese Medicine (TCM) acupuncturists for diagnostic input within their respective domains.
2. Forms of Energy
This authorized activity is addressed in the sections pertaining to chiropractors and animal rehabilitation professionals, highlighting its relevance to multiple disciplines.
3. Chiropractors
RAAHP Canada strongly supports the proposed educational standards and authorizations for chiropractors under the VPA, recognizing their role in animal healthcare.
4. Animal Rehabilitation
The VPA’s requirement of “recognized education in either animal or human anatomy that garners entry into a profession in animal or human medicine” as a baseline for animal rehabilitation professionals recognizes the comparative value of training in human medicine. This foundation of education in conjunction with the additional education requirements in animal rehabilitation positions animal physiotherapists to competently provide care to animals. To be most effective, we require the ability to make and communicate our own rehabilitation diagnoses, and be permitted use all tools within our scope of practice, such an acupuncture and dry needling.
o Proposed Enhancements: Consideration should be given to expanding authorizations for animal rehabilitation professionals. This could include the ability to communicate a rehabilitation diagnosis (e.g., a physical therapy or pathofunctional diagnosis) identifying neuromusculoskeletal disorders or dysfunctions as the cause of an animal’s symptoms, based on a physical assessment.
o Below-the-Dermis Procedures: Authorizing animal physiotherapists and veterinary technicians with specialized training to perform anatomical/western-based acupuncture and dry needling would enhance patient care. Such practices, supported by established training programs and historical precedent in Ontario and Canada, would improve continuity of care and access to these services.
There is a marked disparity between authorizations given to professionals not specifically named in the regulation, i.e. physiotherapists, TCM acupuncturists, or osteopaths, as compared to chiropractors despite similar standards and education. The professionals not specifically named or listed in the Act are every bit as professional and competent as chiropractors, but for lack of regulation in animal practice are either completely barred from entry to practice at all (i.e. TCM acupuncturists), or denied tools of their trade (i.e. physiotherapists in using needles in practice).
Based on the regulations, chiropractors are permitted to practice on animals. Other regulated health professionals, such as animal physiotherapists and TCM acupuncturists who have equivalent training and standards, are equally competent to practice, but have been partially or entirely excluded from practicing strictly on the basis of current regulations. This has resulted in animal physiotherapists being unable to communicate a diagnosis or perform dry needling, and it has entirely eliminated TCM acupuncturists from being able to practice on animals at all. This is a prime example of where regulation is interfering with positive outcomes for both the public and the animals.
Traditional Chinese Medicine (TCM) Acupuncturists
The VPA currently lacks a designated category for TCM acupuncturists, leaving no clear avenue for feedback specific to this profession. As such, this section serves as a logical point for commentary. RAAHP Canada advocates for TCM acupuncturists with additional training in animal anatomy and conditions to be granted authorization to provide acupuncture and TCM services to animal patients, including the communication of a TCM-specific diagnosis. This would expand consumer access to an underserved segment of veterinary care and support interprofessional diversity.
Healthcare professionals, animal owners, and the general public are all encouraged to complete the survey.
https://www.cvo.org/veterinary-practice/consultations/regulatory-concepts
