Florida 2023 2023 Regular Session

Florida Senate Bill S0722 Analysis / Analysis

Filed 04/11/2023

                    The Florida Senate 
BILL ANALYSIS AND FISCAL IMPACT STATEMENT 
(This document is based on the provisions contained in the legislation as of the latest date listed below.) 
Prepared By: The Professional Staff of the Committee on Rules 
 
BILL: SB 722 
INTRODUCER:  Senator Burton 
SUBJECT:  Practice of Veterinary Medicine 
DATE: April 10, 2023 
 
 ANALYST STAFF DIRECTOR  REFERENCE  	ACTION 
1. Kraemer Imhof RI Favorable 
2. Becker Becker AG Favorable 
3. Kraemer Twogood  RC Favorable 
 
I. Summary: 
SB 722 exempts a veterinarian who has an active license in good standing in another United States 
jurisdiction to perform, as an unpaid volunteer (exempted unpaid volunteer), dog and cat 
sterilization services, and routine preventative health services at the time of such sterilization 
services. 
 
The exempted unpaid volunteer must be under the responsible supervision of a Florida-licensed 
veterinarian, which requires control, direction, and regulation by a licensed veterinarian of the 
veterinary services delegated to unlicensed personnel. The supervising licensed veterinarian is 
responsible for all acts performed by an exempted unpaid volunteer acting under such supervision. 
 
An exempted unpaid volunteer, if not otherwise licensed as a veterinarian in Florida, is not eligible 
to apply for a premises permit for a permanent or mobile establishment in which veterinary 
services may be provided. 
 
The bill has no fiscal impact on state government. See Section V, Fiscal Impact Statement. 
 
The bill is effective July 1, 2023. 
II. Present Situation: 
Veterinary Medicine, the Practice of Veterinary Medicine, and Exempted Persons 
In 1979, the Legislature determined the practice of veterinary medicine to be potentially dangerous 
to public health and safety if conducted by incompetent and unlicensed practitioners and that 
minimum requirements for the safe practice of veterinary medicine are necessary.
1
 The Board of 
                                                
1
 See s. 474.201, F.S. 
REVISED:   BILL: SB 722   	Page 2 
 
Veterinary Medicine (board) in the Department of Business and Professional Regulation (DBPR) 
implements the provisions of ch. 474, F.S., on Veterinary Medical Practice.
2
 A veterinarian is a 
health care practitioner licensed to engage in the practice of veterinary medicine in Florida under 
ch. 474, F.S.
3
 
 
Veterinary medicine includes, with respect to animals:
4
 
 Surgery; 
 Acupuncture; 
 Obstetrics; 
 Dentistry; 
 Physical therapy; 
 Radiology; 
 Theriogenology (reproductive medicine);
5
 and 
 Other branches or specialties of veterinary medicine. 
 
The practice of veterinary medicine is the diagnosis of medical conditions of animals, and the 
prescribing or administering of medicine and treatment to animals for the prevention, cure, or relief 
of a wound, fracture, bodily injury, or disease, or holding oneself out as performing any of these 
functions.
6
 Veterinarians who are incompetent or present a danger to the public are subject to 
discipline and may be prohibited from practicing in the state.
7
 
 
Ten categories of persons are exempt from complying with ch. 474, F.S.:
8
 
 Faculty veterinarians with assigned teaching duties at accredited
9
 institutions; 
 Intern/resident veterinarians at accredited institutions who are graduates of an accredited 
institution, but only until they complete or terminate their training; 
                                                
2
 See ss. 474.204 through 474.2125, and s. 474.217, F.S., concerning the powers and duties of the board. 
3
 See s. 474.202(11), F.S. 
4
 See s. 474.202(13), F.S. Section 474.202(1), F.S., defines “animal” as “any mammal other than a human being or any bird, 
amphibian, fish, or reptile, wild or domestic, living or dead.” 
5
 The Society for Theriogenology, established in 1954, is composed of veterinarians dedicated to standards of excellence in 
animal reproduction. See https://www.therio.org/(last visited Mar. 24, 2023). 
6
 See s. 474.202(9), F.S. Also included is the determination of the health, fitness, or soundness of an animal, and the 
performance of any manual procedure for the diagnosis or treatment of pregnancy, fertility, or infertility of animals. 
7
 See s. 474.213, F.S., on prohibited acts, and s. 474.214, F.S., on disciplinary proceedings. See also s. 474.201, F.S. 
8
 See s. 474.203, F.S. 
9
 Sections 474.203(1) and (2), F.S., provide that accreditation of a school or college must be granted by the American 
Veterinary Medical Association (AVMA) Council on Education, or the AVMA Commission for Foreign Veterinary 
Graduates. The AVMA Council on Education is recognized by the Council for Higher Education Accreditation (CHEA) as 
the accrediting body for schools and programs that offer the professional Doctor of Veterinary Medicine degree (or its 
equivalent) in the United States and Canada, and may also approve foreign veterinary colleges. See 
https://www.avma.org/professionaldevelopment/education/accreditation/colleges/pages/coe-pp-overview-of-the-coe.aspx  
(last visited Mar. 24, 2023). The AVMA Commission for Foreign Veterinary Graduates assists graduates of foreign, non-
accredited schools to meet the requirement of most states that such foreign graduates successfully complete an educational 
equivalency assessment certification program. See 
https://www.avma.org/professionaldevelopment/education/foreign/pages/ecfvg-about-us.aspx (last visited Mar. 24, 2023). In 
turn, the Council for Higher Education Accreditation, a national advocate for regulation of academic quality through 
accreditation, is an association of degree-granting colleges and universities. See http://chea.org/about (last visited 
Mar. 24, 2023).  BILL: SB 722   	Page 3 
 
 Students in a school or college of veterinary medicine who perform assigned duties by an 
instructor (no accreditation of the institution is required), or work as preceptors
10
 (if the 
preceptorship is required for graduation from an accredited institution); 
 Doctors of veterinary medicine employed by a state agency or the United States Government 
while actually engaged in the performance of official duties at the installations for which the 
services were engaged; 
 Persons or their employees caring for the persons’ own animals, as well as part-time or 
temporary employees, or independent contractors, who are hired by an owner to help with herd 
management and animal husbandry tasks (excluding immunization or treatment of diseases 
that are communicable to humans and significant to public health) for herd/flock animals, with 
certain limitations; however, the exemption is not available to a person licensed as a 
veterinarian in another state and temporarily practicing in Florida, or convicted of violating 
ch. 828, F.S., on animal cruelty, or of any similar offense in another jurisdiction, and 
employment may not be provided for the purpose of circumventing ch. 474, F.S.; 
 Certain entities or persons
11
 that conduct experiments and scientific research on animals as part 
of the development of pharmaceuticals, biologicals, serums, or treatment methods or 
techniques to diagnose or treat of human ailments, or in the study and development of methods 
and techniques applicable to the practice of veterinary medicine; 
 Veterinary aides, nurses, laboratory technicians, preceptors, or other employees of a licensed 
veterinarian, who administer medication or provide help or support under the responsible 
supervision
12
 of a licensed veterinarian; 
 Certain non-Florida veterinarians who are licensed and actively practicing veterinary medicine 
in another state, are board certified in a specialty recognized by the Florida Board of Veterinary 
Medicine, and are assisting upon request of a Florida-licensed veterinarian to consult on the 
treatment of a specific animal or on the treatment on a specific case of the animals of a single 
owner; 
 Employees, agents, or contractors of public or private animal shelters, humane organizations, 
or animal control agencies operated by a humane organization, county, municipality, or 
incorporated political subdivision, whose work is confined solely to implanting radio 
frequency identification device microchips in dogs and cats in accordance with s. 823.15, F.S.;
 
13
 and 
 Paramedics or emergency medical technicians providing emergency medical care to a police 
canine14 injured in the line of duty while at the scene of the emergency or while the police 
canine is being transported to a veterinary clinic or similar facility. 
                                                
10
 A preceptor is a skilled practitioner or faculty member, who directs, teaches, supervises, and evaluates students in a clinical 
setting to allow practical experience with patients. See 
https://www.merriam-Webster.com/dictionary/preceptor#medicalDictionary (last visited Mar. 24, 2023). 
11
 See s. 474.203(6), F.S., which states that the exemption applies to “[s]tate agencies, accredited schools, institutions, 
foundations, business corporations or associations, physicians licensed to practice medicine and surgery in all its branches, 
graduate doctors of veterinary medicine, or persons under the direct supervision thereof . . . .” 
12
 The term “responsible supervision” is defined in s. 474.202(10), F.S., as the “control, direction, and regulation by a 
licensed doctor of veterinary medicine of the duties involving veterinary services” delegated to unlicensed personnel. 
13
 See s. 823.15(5), F.S., which authorizes such persons to perform microchipping of dogs and cats. 
14
 Section 401.254, F.S., defines the term “police canine” as “any canine that is owned, or the service of which is employed, 
by a state or local law enforcement agency, a correctional agency, a fire department, a special fire district, or the State Fire 
Marshal for the principal purpose of aiding in the detection of criminal activity, flammable materials, or missing persons; the 
enforcement of laws; the investigation of fires; or the apprehension of offenders.” A paramedic or an emergency medical  BILL: SB 722   	Page 4 
 
Persons who are eligible faculty veterinarians, intern veterinarians, resident veterinarians, or state 
or federal veterinarians exempt from complying with ch. 474, F.S., are deemed to be duly licensed 
practitioners authorized to prescribe drugs or medicinal supplies.
15
 
 
Veterinarian/Client/Patient Relationship 
Section 474.202(12), F.S., defines a “veterinarian/client/patient relationship” as one in which a 
veterinarian has assumed responsibility for making medical judgments about the health of an 
animal and its need for medical treatment. The term “patient” means any animal “for which a 
veterinarian practices veterinary medicine.”
16
 
 
The term “valid veterinarian-client-patient relationship” (VCPR) used in federal regulations issued 
by the federal Food and Drug Administration (FDA), an agency within the United States 
Department of Health and Human Services, is similar to the definition in s. 474.202(12), F.S.
17
 
 
The federal VCPR definition requires that veterinarians physically examine animal patients and 
make medically appropriate and timely visits to the location where the animals are kept.
18
 The 
FDA has amended its animal drug regulations to implement veterinary feed directive drugs.
19
 
(VFD).
20
 The FDA requires veterinarians to consider state VCPR requirements.
21
 
 
Veterinarian Licensing 
Chapter 474, F.S., relating to Veterinary Medical Practice (act) provides several pathways to 
licensure as a veterinarian in Florida. Licensure may be by examination or endorsement, and 
issuance of a temporary license is available in certain circumstances. 
 
Licensure by Examination 
An applicant for licensure as a veterinarian by examination must apply to the DBPR for such 
licensure. The board has established by administrative rule the required passing scores for a 
national examination and an examination relating to the practice of veterinary medicine in 
Florida.
22
 
The DBPR must license an applicant if the board finds the applicant has met these requirements: 
                                                
technician who acts in good faith to provide emergency medical care to an injured police canine is immune from criminal or 
civil liability. 
15
 See s. 474.203, F.S. (flush left language). 
16
 See s. 474.202(8), F.S. 
17
 See 21 C.F.R. s. 530.3. 
18
 Id. 
19
 See https://www.fda.gov/animal-veterinary/development-approval-process/veterinary-feed-directive-vfd (last visited 
Mar. 24, 2023). 
20
 Id. See 21 C.F.R. s. 530 and 21 C.F.R. part 558. A VFD drug is intended for use in animal feeds, and use is permitted only 
under the professional supervision of a licensed veterinarian. See U.S. Food and Drug Administration, Veterinary Feed 
Directive (VFD) ttps://www.fda.gov/animal-veterinary/development-approval-process/veterinary-feed-directive-vfd (last 
visited Mar. 24, 2023). 
21
 See https://www.fda.gov/animal-veterinary/development-approval-process/fact-sheet-veterinary-feed-directive-final-rule-
and-next-steps (last visited Mar. 24, 2023). 
22
 See s. 474.207(1), F.S. and Fla. Admin. Code R. 61G18-11.002. The rules promulgated by the board are available at 
https://www.flrules.org/gateway/Division.asp?DivID=270 (last visited Mar. 24, 2023).  BILL: SB 722   	Page 5 
 
 Submission of a complete application form with the required examination fee; 
 With some exceptions,
23
 graduation from a college of veterinary medicine that is either: 
o Accredited by the American Veterinary Medical Association Council on Education; or 
o Listed in the American Veterinary Medical Association Roster of Veterinary Colleges of 
the World and obtained a certificate from the Education Commission for Foreign 
Veterinary Graduates or the Program for the Assessment of Veterinary Education 
Equivalence. 
 The successful completion of the required licensure examinations, demonstrating the 
applicant’s knowledge of the laws and rules governing the practice of veterinary medicine.
24
 
 
Pursuant to s. 474.207(5), F.S., an unlicensed doctor of veterinary medicine who has graduated 
from an approved college or school of veterinary medicine and completed all parts of the licensure 
examination is permitted, while awaiting the results of the examination or license issuance, to 
practice under the immediate supervision of a licensed veterinarian. A person who fails any part 
of the examination may not continue to practice, except in the same capacity as other nonlicensed 
veterinary employees, until she or he passes the examination and is eligible for licensure. 
 
Licensure by Endorsement 
Under s. 474.217, F.S., an applicant for licensure as a veterinarian by endorsement must apply to 
the DBPR for such licensure, remit the required fee, and demonstrate to the board that the applicant 
is knowledgeable of the laws and rules governing the practice of veterinary medicine in Florida; 
and 
 Holds and has held for the three years immediately preceding the application, a valid, active 
license to practice veterinary medicine in another state or a territory of the United States or the 
District of Columbia, and has successfully completed a state, regional, national, or other 
examination that is equivalent to or more stringent than the examination required by the board; 
or 
 Meets the educational and other requirements set forth in s. 474.207(2)(b), F.S., and has 
successfully completed a state, regional, national, or other examination equivalent to or more 
stringent than the examination given by the DBPR and has passed the board’s clinical 
competency examination or another clinical competency examination specified by the board.
25
 
 
The DBPR may not issue a license to any applicant by examination or by endorsement, if the 
applicant is under investigation in any state or territory in the United States or the District of 
Columbia for an act which would constitute a violation of Florida’s veterinary medical practice 
act, until the investigation is complete and disciplinary proceedings have been terminated. 
                                                
23
 Section 474.207(3), F.S., provides a pathway to licensure for applicants who were certified for examination by the board 
prior to October 1, 1989, or who immigrated to the United States after leaving her or his home country in the Western 
Hemisphere because of political reasons and the country lacks diplomatic relations with the United States, subject to other 
requirements set forth in this section. 
24
 Id. Fla. Admin. Code R. 61G18-11.002 requires completion of two examinations: the North American Veterinary 
Licensing Examination (popularly known as NAVLE) developed by the International Council for Veterinary Assessment, 
and an examination covering Ch. 474, F.S., relating to Veterinary Medical Practice, the administrative rules promulgated by 
the board, specified Florida law, and the 2006 Edition of the “Practitioner’s Manual,” an informational outline of the 
Controlled Substances Act of 1970, published by the Drug Enforcement Administration of the United States Department of 
Justice. 
25
 See Fla. Admin. Code R. 61-9.003.  BILL: SB 722   	Page 6 
 
Thereafter, the applicant is subject to the disciplinary proceedings set forth in s. 474.214, F.S., if 
the act constitutes grounds for disciplinary action, e.g., for having a veterinarian medicine license 
suspended or for violating state or federal drug laws.
26
 
 
Temporary Licensure 
Pursuant to s. 474.2125, F.S., the board is authorized to issue a temporary license to a veterinarian 
licensed in another state to enable the veterinarian to provide veterinary medical services in Florida 
to animals of a specific owner or, in an emergency,
27
 for the animals of multiple owners, provided 
the applicant would qualify for licensure by endorsement under s. 474.217, F.S. Temporary 
licenses are not valid for more than 30 days after issuance, and may not cover more than the 
treatment of the animals of one owner except in an emergency; after the expiration of 30 days, 
another temporary license is required.
28
 
 
An application for a temporary license must state the names, addresses, and titles of all persons 
who are to enter the state with the applicant to perform the treatment accompanied by the 
application fee established by the board.
29
 Upon certification of the applicant by the board, the 
DBPR must issue the temporary license. 
 
Under s. 474.2125(4), F.S., the temporary license application constitutes the appointment of the 
Florida Department of State as the applicant’s agent for service of process in any action against 
the applicant arising out of any transaction or operation connected with, or incidental to, the 
practice of veterinary medicine authorized by the temporary license. 
 
License Renewal 
Upon receipt of a license renewal application, biennial renewal fee, and an affidavit of compliance 
with board-approved continuing education course requirements,
30
 the DBPR must renew a 
license.
31
 
 
License and Related Fees 
The board is required to establish fees for application and examination, reexamination, license 
renewal, inactive status, renewal of inactive status, license reactivation, periodic inspection of 
veterinary establishments, and duplicate copies of licenses, certificates, and permits. There are 
maximum limits on fee amounts and all fees are adopted by the board, and fees must be based on 
the DBPR’s estimates of the revenue required to administer the act and all provisions relating to 
the regulation of veterinarians.
32
 
 
                                                
26
 See ss. 474.207(2) and 474.217(2), F.S. 
27
 Under s. 252.34(4), F.S., the term “emergency” means “any occurrence, or threat thereof, whether natural, technological, or 
manmade, in war or in peace, which results or may result in substantial injury or harm to the population or substantial 
damage to or loss of property.” 
28
 See s. 474.2125, F.S., and Fla. Admin. Code R. 61G18-25.001. 
29
 Id.; see also Fla. Admin. Code R. 61G18-12.010. 
30
 See Fla. Admin. Code R. 61G-18-16.002 relating to the requirement for completion of a minimum of 30 hours of boar-
approved continuing education in veterinary medicine. 
31
 See s. 474.211, F.S.; the biennial renewal fee is $260. See Fla. Admin. Code R. 61G18-12.0005. 
32
 See s. 474.2065, F.S., and the fee schedule set forth in Fla. Admin. Code R. 61G18-12.  BILL: SB 722   	Page 7 
 
Responsible Supervision by Licensed Veterinarians 
The term “responsible supervision” means the control, direction, and regulation by a licensed 
veterinarian of the duties involving veterinary services delegated to unlicensed personnel.”
33
 The 
delegation of professional responsibilities when the delegating veterinarian knows or has reason 
to know that the non-licensed person is not qualified by training, experience, or licensure to 
perform them, constitutes grounds for the imposition of discipline.
34
 
 
Premises Permits for Veterinary Practices 
Section 474.215, F.S., relating to mandatory premises permits for all veterinary practices, requires 
a permanent or mobile establishment where a licensed veterinarian practices (establishment) to 
have a DBPR-issued premises permit. Such establishments must be inspected as part of the 
application procedure and meet minimum standards set by the board, including sanitary conditions, 
recordkeeping, equipment, radiation monitoring, required services, and physical plant 
requirements.
35
 Practitioners who make house-calls and who do not maintain an establishment are 
not required to obtain a premises permit, but must provide for minimum equipment and facilities.
36
 
An establishment owner who is not licensed as a veterinarian must apply for a premises permit, 
and if the board certifies that the applicant complies with applicable law and board rules, the DBPR 
must issue a premises permit.
37
 
 
The DBPR or the board may deny, revoke, or suspend the permit of any establishment, and may 
fine, place on probation, or otherwise discipline any such permittee who has: 
 Obtained a permit by misrepresentation or fraud or through DBPR or board error; 
 Attempted to procure, or has procured, a permit for any other person through any false 
representation; 
 Violated any of the requirements of ch. 474, F.S., or any board rule; or 
 Been convicted or found guilty of, or entered a plea of nolo contendere to, regardless of 
adjudication, a felony in any court of Florida, another state, or the United States.
38
 
 
If a premises permit is revoked or suspended, the owner, manager, or proprietor must: 
 Discontinue operating the premises as a veterinary medical practice as of the effective date of 
the revocation or suspension; and 
 Remove from the premises all signs and symbols identifying the premises as a veterinary 
medical practice.
39
 
A suspension of a premises permit may not exceed one year; if the permit is revoked, the person 
owning or operating the establishment must advise the board of the disposition of all medicinal 
drugs and must provide for ensuring the security, confidentiality, and availability to clients of all 
                                                
33
 See s. 474.202(10), F.S. 
34
 See s. 474.214(1)(hh), F.S. See also s. 474.214(2), F.S., relating to the penalties the board may impose. 
35
 See Fla. Admin. Code R.61G18-15.002. 
36
 See Fla. Admin. Code R. 61G18-15.006. Practitioners who serve solely agricultural animals are not required to obtain a 
premises permit, but must provide appropriate equipment and facilities. See Fla. Admin. Code R. 61G18-15.0022. 
37
 See s. 474.215(8), F.S. 
38
 See s. 474.215(9), F.S. 
39
 Id.  BILL: SB 722   	Page 8 
 
patient medical records, and may not apply for a permit to operate a premises for a period of one 
year after the revocation’s effective date.
40
 
 
Sterilization of Dogs and Cats 
The American Society for the Prevention of Cruelty to Animals (ASPCA) is one of the largest 
humane societies in the world.
41
 According to the ASPCA, the spaying or neutering of dogs and 
cats (sterilization services) helps control pet homelessness, a crisis that results in millions of 
healthy dogs and cats in the United States being euthanized.
42
 
 
The ASPCA indicates there are also medical and behavioral benefits to sterilization of dogs and 
cats, as follows: 
 Spaying prevents uterine infections and decreases the incidence of breast tumors, which are 
malignant or cancerous in about 90 percent of cats; 
 Neutering prevents testicular cancer and some prostate problems; 
 Improving behavioral issues, as a female animal will not be able to breed (i.e., go into heat), 
avoiding situations in which female felines possibly going into heat four to five days every 
three weeks during breeding season (yowling and urinating frequently); and 
 Male dogs will be better behaved, perhaps less aggressive, and less likely to roam away from 
home, risking injury in traffic and fights with other animals.
43
 
 
Low-cost, high-quality, high-volume spay-neuter clinics (sterilization clinics) have been 
established across the United States to increase the availability of such services, thereby reducing 
pet overpopulation and euthanasia of pets in animal shelters.
44
 Some veterinary medicine 
practitioners contend that sterilization clinics compete with private practitioners or have concerns 
about the quality of care, while other practitioners promote programs benefiting both the private 
practitioners and the sterilization clinics.
45
 
 
In 2008, the Association of Shelter Veterinarians (ASV) established comprehensive guidelines 
dealing with anesthetic procedures, surgical care, and pre- and post-operative care for spay-neuter 
programs in an effort to ensure that sterilization clinics provide high-quality care along with high 
volume.
46
  
 
As to the issue of competition with private practitioners, a study published in 2016 reported that 
the majority of cats sterilized through a reduced-cost spay–neuter program in Massachusetts had 
                                                
40
 Id. 
41
 See the ASPCA website https://www.aspca.org/about-us (last visited Mar. 24, 2023). 
42
 See https://www.aspca.org/pet-care/general-pet-care/spayneuter-your-pet (last visited Mar. 24, 2023). 
43
 Id. 
44
 See Philip A. Bushby, Journal of Feline Medicine and Surgery (2020) 22, at 208, (an open access, international, peer-
reviewed journal) (Bushby), at https://journals.sagepub.com/doi/full/10.1177/1098612X20903600 (last visited 
Mar. 24, 2023). 
45
 See Bushby at 209 and accompanying footnotes. 
46
 Id. The guidelines were updated in 2016. The author noted that a study of the “results at one [sterilization] clinic that 
performed spay–neuter on 71,557 cats and 42,349 dogs over a 7-year period documented mortality rates approximately 
1/10th of those reported at low-volume private veterinary practices.” Id. (footnote omitted). Further, key principles for 
efficiency include “designating a block of time devoted to spay–neuter, performing the surgeries at an earlier age and 
adopting very efficient surgical techniques.” Id. at 210.  BILL: SB 722   	Page 9 
 
never been seen by a veterinarian before, primarily due to the cost of services.
47
 According to the 
chief economist of the American Veterinary Medical Association, nearly a third of the nation’s 
pets do not see a veterinarian at least once a year.
48
 
 
According to the DBPR, in Fiscal Year 2021-2022, there were 12,360 veterinarians with active 
licenses in Florida, an increase of fewer than 1,000 licensees since Fiscal Year 2019-2020.
49
 
III. Effect of Proposed Changes: 
The bill exempts a veterinarian who has an active license in good standing in another United States 
jurisdiction to perform, as an unpaid volunteer (exempted unpaid volunteer), dog and cat 
sterilization services and routine preventative health services at the time of such sterilization 
services. The exempted unpaid volunteer must be under the responsible supervision of a Florida-
licensed veterinarian, as defined in s. 474.202, F.S. Such supervision requires control, direction, 
and regulation by a licensed veterinarian of the duties involving veterinary services that are 
delegated to unlicensed personnel. 
 
The bill further provides the supervising licensed veterinarian is responsible for all acts performed 
by an exempted unpaid volunteer who is acting under such supervision. 
 
An exempted unpaid volunteer, if not otherwise licensed under the act, is not eligible to apply for 
a premises permit under s. 474.215, F.S. (see Section II, Premises Permits for Veterinary Practices, 
above relating to such permits). 
 
The bill is effective July 1, 2023. 
IV. Constitutional Issues: 
A. Municipality/County Mandates Restrictions: 
None. 
B. Public Records/Open Meetings Issues: 
None. 
                                                
47
 Id. 
48
 See Malinda Larkin, New, Old challenges beg for radical change in veterinary profession, Dec. 3, 2020) summarizing the 
keynote address at the annual American Veterinary Medical Association (AVMA) Economic Summit by Matthew J. Salois, 
PhD, AVMA Chief Economist, at https://www.avma.org/javma-news/2020-12-15/new-old-challenges-beg-radical-change-
veterinary-profession (last visited Mar. 24, 2023). According to the AVMA, it represents more than 100,000 members of the 
veterinary profession “to protect, promote and advance the needs of all veterinarians and those they serve.” See 
https://www.avma.org/about (last visited Mar. 24, 2023). 
49
 See Department of Business and Professional Regulation, 2021-2022 Annual Report, Divisions of Certified Public 
Accounting, Professions, Real Estate, and Regulation at 18, at 
http://www.myfloridalicense.com/DBPR/os/documents/DivisionAnnualReport_FY2021.pdf (last visited Mar. 24, 2023) and 
2019-2020 Annual Report, Divisions of Certified Public Accounting, Professions, Real Estate, and Regulation at 20, at 
http://www.myfloridalicense.com/DBPR/os/documents/DivisionAnnualReport_FY1920.pdf (last visited Mar. 24, 2023).  BILL: SB 722   	Page 10 
 
C. Trust Funds Restrictions: 
None. 
D. State Tax or Fee Increases: 
None. 
E. Other Constitutional Issues: 
None. 
V. Fiscal Impact Statement: 
A. Tax/Fee Issues: 
None. 
B. Private Sector Impact: 
Owners of dogs or cats who cannot afford the fees of full-service veterinary practices may 
have another avenue to have their pets spayed or neutered at a sterilization clinic at a lower 
cost. 
 
A large volume of exempted unpaid volunteers performing dog or cat sterilization services, 
whether with or without accompanying routine preventive health services, may impact 
similar services typically performed by Florida-licensed veterinarians. However, 
sterilization of dogs and cats by exempt unpaid volunteers could reduce the number of 
puppies and kittens borne by animals that would otherwise not be sterilized due to cost 
considerations. Increased sterilization of pets may assist in reducing pet overpopulation 
and euthanasia of pets in animal shelters. 
 
The Department of Business and Professional Regulation (DBPR) notes that the bill “may 
reduce expenditures in the private sector by expanding the ability for sterilization services 
to be performed on a voluntary basis.”
50
 
C. Government Sector Impact: 
The DBPR notes the bill has no fiscal impact on state government.
51
 
VI. Technical Deficiencies: 
None. 
                                                
50
 See Department of Business and Professional Regulation, 2023 Agency Legislative Bill Analysis for SB 722 at 4 
(Feb. 15, 2023) (on file with the Senate Committee on Agriculture). 
51
 Id. at 4-5.  BILL: SB 722   	Page 11 
 
VII. Related Issues: 
None. 
VIII. Statutes Affected: 
This bill substantially amends section 474.203 of the Florida Statutes. 
IX. Additional Information: 
A. Committee Substitute – Statement of Changes: 
(Summarizing differences between the Committee Substitute and the prior version of the bill.) 
None. 
B. Amendments: 
None. 
This Senate Bill Analysis does not reflect the intent or official position of the bill’s introducer or the Florida Senate.