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 Regulated Industries
BILL: SB 652
INTRODUCER: Senator Bradley
SUBJECT: Veterinary Professional Associates
DATE: March 11, 2025
ANALYST STAFF DIRECTOR REFERENCE ACTION
1. Baird Imhof RI Pre-meeting
2. AG
3. RC
I. Summary:
SB 652 creates the title “veterinary professional associate” and allows such individuals who have
obtained this title, working under the supervision of a veterinarian, to practice veterinary
medicine on a limited basis, as follows:
• Allows the title "veterinary professional associate" to be used only by an individual who has
successfully completed an approved program.
• Unless otherwise prohibited by federal or state law, authorizes a veterinary professional
associate to practice veterinary medicine while working under the supervision of a Florida
licensed veterinarian.
• Prohibits a veterinary professional associate from:
• Prescribing medicinal drugs or controlled substances.
• Performing a surgical procedure, except for sterilizations or dental surgeries.
• Makes supervising veterinarians using a veterinary professional associate liable for any acts
or omissions of the veterinary professional associate acting under the veterinarian's
supervision.
The bill provides an effective date of July 1, 2025.
II. Present Situation:
Practice of Veterinary Medicine
The Board of Veterinary Medicine (board) in the Department of Business and Professional
Regulation (DBPR) implements the provisions of ch. 474, F.S., relating to veterinary medical
practice (practice act). The purpose of the practice act is to ensure that every veterinarian
REVISED: BILL: SB 652 Page 2
practicing in this state meets minimum requirements for safe practices to protect public health
and safety.
1
A “veterinarian” is a health care practitioner licensed by the board to engage in the practice of
veterinary medicine in Florida
2
and they are subject to disciplinary action from the board for
various violations of the practice act.
3
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.
4
Veterinary medicine includes, with respect to animals:
5
• Surgery;
• Acupuncture;
• Obstetrics;
• Dentistry;
• Physical therapy;
• Radiology;
• Theriogenology (reproductive medicine); and
• Other branches or specialties of veterinary medicine.
The practice act does not apply to the following categories of persons:
• Veterinary aides, nurses, laboratory technicians, preceptors,
6
or other employees of a licensed
veterinarian, who administer medication or provide help or support under the responsible
supervision
7
of a licensed veterinarian;
• Certain non-Florida licensed veterinarians who are consulting upon request of a Florida-
licensed veterinarian on the treatment of a specific animal or on the treatment of a specific
case of the animals of a single owner.
• Faculty veterinarians when they have assigned teaching duties at accredited
8
institutions;
• Certain graduated intern/resident veterinarians of accredited institutions;
• Certain students in a school or college of veterinary medicine who perform assigned duties
by an instructor or work as preceptors;
1
Section 474.201, F.S.
2
Section 474.202(11), F.S.
3
Sections 474.213 & 474.214, F.S.
4
See section 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 or fertility or infertility of animals.
5
See section 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.”
6
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 also https://www.merriam-
webster.com/dictionary/preceptor#medicalDictionary (last visited March 11, 2025).
7
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.
8
Section 474.203(1)-(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. BILL: SB 652 Page 3
• Certain doctors of veterinary medicine employed by a state agency or the United States
Government;
• Persons or their employees caring for the persons’ own animals, as well as certain part-time
or temporary employees, or independent contractors, who are hired by an owner to help with
herd management and animal husbandry tasks; and
• Certain entities or persons
9
that conduct experiments and scientific research on animals as
part of the development of pharmaceuticals, biologicals, serums, or methods of treatment or
techniques to diagnose or treat human ailments, or in the study and development of methods
and techniques applicable to the practice of veterinary medicine.
10
Any permanent or mobile establishment where a licensed veterinarian practices must have a
premises permit issued by the DBPR.
11
Each person to whom a veterinary license or premises
permit is issued must conspicuously display such document in her or his office, place of
business, or place of employment in a permanent or mobile veterinary establishment or clinic.
12
By virtue of accepting a license to practice veterinary medicine in Florida, a veterinarian
consents to:
• render a handwriting sample to an agent of the DBPR and, further, to have waived any
objections to its use as evidence against her or him.
• waive the confidentiality and authorize the preparation and release of medical reports
pertaining to the mental or physical condition of the licensee when the DBPR has reason to
believe that a violation of this chapter has occurred and when the DBPR issues an order,
based on the need for additional information, to produce such medical reports for the time
period relevant to the complaint.
13
For Fiscal Year 2022-2023, there were 13,285 actively licensed veterinarians in Florida. The
DBPR received 484 complaints, which resulted in 16 disciplinary actions.
14
Immediate Supervision
The practice act defines “immediate supervision” to mean that a “licensed doctor of veterinary
medicine is on the premises whenever veterinary services are being provided.”
15
Veterinary tasks requiring immediate supervision include:
16
• Administering anesthesia and tranquilization by a veterinary aide, nurse, laboratory
technician, intern, or other employee of a licensed veterinarian.
9
See section 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 ....”
10
See section 474.203, F.S.
11
Section 474.215(1), F.S.
12
Section 474.216, F.S.
13
Section 474.2185, F.S.
14
Department of Business and Professional Regulation, Division of Professions Annual Report Fiscal Year 2022-2023,
http://www.myfloridalicense.com/DBPR/os/documents/Division%20Annual%20Report%20FY%2022-23.pdf (last visited
March 11, 2025).
15
Section 4764.202(5), F.S.
16
R. 61G18-17.005, F.A.C. BILL: SB 652 Page 4
• Administering certain vaccinations by a veterinary aide, nurse, technician, intern, or other
employee of a licensed veterinarian which is not specifically prohibited.
The following tasks may be performed without the licensed veterinarian on the premises:
17
• Administering medication and treatment, excluding vaccinations, as directed by the licensed
veterinarian; and
• Obtaining samples and the performance of those diagnostic tests, including radiographs, as
directed by the licensed veterinarian.
Veterinarian Shortage
According to a survey conducted by the American Pet Products Association (APPA), 70 percent
of U.S. households, or about 90.5 million families, own a pet. This is an increase from 56 percent
of U.S. households in 1988, and 67 percent in 2019.
18
As a result, experts say there is a shortage
of veterinarians in the U.S., which is expected to result in the need for approximately 15,000
veterinarians by the year 2030.
19
A study from Banfield Pet Hospital reveals an estimated 75
million pets in the U.S. may not have access to the veterinary care they need by 2030, with an
important factor being a critical shortage of veterinarians.
20
The University of Florida’s Dean of the College of Veterinary Medicine, Dana Zimmel, has
indicated that there is a shortage of veterinarians in Florida, which in addition to pets has “1.7
million beef cattle and dairy cows, more horses than Kentucky and an alarming decline of
manatee.” The state’s only veterinary medical college, the University of Florida, also reports that
due to limited capacity, it must turn away 1,500 qualified candidates a year.
21
According to the American Veterinary Medical Association (AVMA):
Conditions have pushed the idea of a midlevel practitioner to the fore as veterinary practices
have struggled to meet service demands. This issue has been compounded by continued
inefficiencies in practices as pandemic disruptions persist and client expectations for availability
and convenience. Inflation has also increased costs for labor and for products such as medical
equipment and medications, creating additional concern around clients’ ability to afford needed
17
Id.
18
Insurance Information Institute, Facts + Statistics: Pet Ownership and Insurance, https://www.iii.org/fact-statistic/facts-
statistics-pet-ownership-and-
insurance#:~:text=Seventy%20percent%20of%20U.S.%20households,and%2067%20percent%20in%202019. (last visited
March 11, 2025).
19
Spectrum News 13, Mobile ‘ElleVet’ clinic helps relieve veterinarian shortage,
https://www.mynews13.com/fl/orlando/news/2023/02/03/the-ellevet-project-
#:~:text=%E2%80%94%20Experts%20say%20there's%20a%20shortage,States%20may%20not%20get%20care. (last visited
March 11, 2025).
20
Banfield Pet Hospital, 75 million pets may not have access to veterinary care by 2030, New Banfield® study finds,
https://www.banfield.com/en/about-banfield/newsroom/press-releases/2020/75-million-pets-may-not-have-access-to-
veterinary (last visited March 11, 2025).
21
Dana Zimmel, Florida needs more veterinarians | Column, Tampa Bay Times (Jan. 3, 2022),
https://www.tampabay.com/opinion/2022/01/03/florida-needs-more-veterinarians-column/ (last visited March 11, 2025). BILL: SB 652 Page 5
care. Additionally, retention of veterinary practice staff members and attrition from the
profession are ongoing and increasing concerns.
22
The AVMA found that a midlevel practitioner may not be the best option to address these
concerns, and that
Time and effort should be spent on resources, tools, and programs designed to retain
veterinarians and credentialed veterinary technicians; further develop veterinary technician
specialties; help veterinary practices operate at optimum efficiency; and effectively collaborate—
within practice teams and across the profession—to meet clients’ needs for high-quality
veterinary services.
23
However, according to a study conducted by the National Library of Medicine:
The projected shortage of veterinarians has created a need to explore alternatives designed to
meet society's future demands. A veterinary professional health care provider, similar to the
human medical profession's physician assistant (PA), is one such alternative. It is suggested that
perhaps veterinary professional associates, modeled after PAs, could be employed to handle
routine veterinary care and thereby allow veterinarians additional time to focus on the more
demanding and challenging aspects of veterinary medicine. Perhaps a team approach, similar to
the physician/PA team, could help the field of veterinary medicine to better serve both clients
and patients. As veterinary medicine directs its attention toward the new challenges on the
horizon, creative solutions will be needed. Perhaps some variation of a veterinary professional
associate is worthy of future discussion.
24
Human Physician Assistants
According to the Mayo Clinic, Physician Assistants (PA) are “licensed medical professionals
who hold an advanced degree and are able to provide direct patient care. They work with patients
of all ages in virtually all specialty and primary care areas, diagnosing and treating common
illnesses and working with minor procedures. With an increasing shortage of health care
providers, PAs are a critical part of today’s team-based approach to health care. They increase
access to quality health care for many populations and communities. The specific duties of a PA
are determined by their supervising physician and state law, but they provide many of the same
services as a primary care physician. They practice in every state and in a wide variety of clinical
settings and specialties.”
25
22
American Veterinary Medical Association, AVMA News, Idea of midlevel practitioner rejected in favor of better support,
engagement of credentialed veterinary technicians (Jan. 10, 2023), https://www.avma.org/news/idea-midlevel-practitioner-
rejected-favor-better-support-engagement-credentialed-veterinary (last visited March 11, 2025).
23
Id.
24
Lori Kogan, Sherry Stewart, Veterinary professional associates: does the profession's foresight include a mid-tier
professional similar to physician assistants?, National Library of Medicine (2009),
https://pubmed.ncbi.nlm.nih.gov/19625672/ (last visited March 11, 2025).
25
Mayo Clinic College of Medicine and Science, Physician Assistant, https://college.mayo.edu/academics/explore-health-
care-careers/careers-a-z/physician-assistant/ (last visited March 11, 2025). BILL: SB 652 Page 6
In Florida, PAs are licensed medical professionals that are authorized to perform services
delegated by a supervising physician.
26
PAs are regulated by the Florida Council on Physician
Assistants in conjunction with either the Board of Medicine for PAs licensed under ch. 458, F.S.,
or the Board of Osteopathic Medicine for PAs licensed under ch. 459, F.S. During fiscal year
2023-2024, there were 11,890 actively licensed PAs in the state, and 1,339 initial PA licenses
were issued by the Florida Department of Health.
27
Veterinary Professional Associates in Other Jurisdictions
States
In 2024, voters of the state of Colorado approved a ballot measure to create a new, state-
regulated veterinary position (Veterinary Professional Associate) that was to address, in part, the
shortage of care, especially in rural areas, for pets.
28
Colorado’s proposition empowered the state
to create a regulatory scheme to license and regulate these Veterinary Professional Associates.
Similarly to what is being proposed in SB 652, Colorado would provide this Veterinary
Professional Associate pathway for those who complete a master’s degree in veterinary clinical
care, or an equivalent degree determined by the state board.
29
Universities
In 2022, The Lincoln Memorial University-College of Veterinary Medicine, created the first-of-
its-kind Master of Veterinary Clinical Care degree. As of the beginning of 2025, this is the only
program in the country that offers a Veterinary Clinical Care master’s degree.
Colorado State University is in the process of developing a similar program.
30
III. Effect of Proposed Changes:
SB 652 creates the title “veterinary professional associate” and allows individuals working under
the supervision of a veterinarian to practice veterinary medicine on a limited basis.
Accordingly, the bill defines the following terms:
• "Approved program" means a master's program in veterinary clinical care, or the equivalent,
from a school of veterinary medicine in the United States or in its territories or possessions.
• "Veterinary professional associate" means a person who has earned a master's degree from an
approved program and is authorized to perform veterinary medical services delegated by a
supervising veterinarian.
26
Sections 458.347(2)(e) and 459.022(2)(e).
27
Florida Department of Health, Division of Medical Quality Assurance, Annual Report and Long-Range Plan, Fiscal Year
2023-2024, https://www.floridahealth.gov/licensing-and-regulation/reports-and-publications/2024.10.28.FY23-24AR-
FINAL.pdf (last visited March 11, 2025).
28
Colorado Department of Regulatory Agencies, State Board of Veterinary Medicine: Proposition 129,
https://dpo.colorado.gov/Veterinary/Proposition129, (last visited March 11, 2025),
29
Id.
30
Colorado State University, About the Master of Science in Veterinary Clinical Care,
https://vetmedbiosci.colostate.edu/vpa/, (last visited March 11, 2025). BILL: SB 652 Page 7
The bill also provides that:
• The title “veterinary professional associate” may be used only by an individual who has
successfully completed an approved program and passed a national competency examination.
• Unless otherwise prohibited by federal or state law, a veterinary professional associate may
perform duties or actions in s. 474.202(9) and (13), F.S., (practice of veterinary medicine) in
which he or she is competent and has the necessary training, current knowledge, and
experience to perform the assigned duties. The associate may perform only the duties
assigned to him or her while under the supervision, as defined in s. 474.202, F.S., of a
licensed veterinarian, except when immediate supervision is required under the bill.
• A veterinary professional associate may not do either of the following:
o Prescribe medicinal drugs or controlled substances (unless authorized by state or federal
law).
o Perform a surgical procedure, except for sterilizations or dental surgeries that do not enter
a body cavity.
• Any surgery that is done must be performed under immediate supervision as defined in s.
474.202, F.S., of a licensed veterinarian.
Finally, SB 652 provides that a licensed veterinarian who assigns duties or actions to a veterinary
professional associate is liable for any act or omission of the veterinary professional associate
acting under the licensed veterinarian’s supervision.
The bill provides an effective date of July 1, 2025.
IV. Constitutional Issues:
A. Municipality/County Mandates Restrictions:
None.
B. Public Records/Open Meetings Issues:
None.
C. Trust Funds Restrictions:
None.
D. State Tax or Fee Increases:
None.
E. Other Constitutional Issues:
None. BILL: SB 652 Page 8
V. Fiscal Impact Statement:
A. Tax/Fee Issues:
None.
B. Private Sector Impact:
None.
C. Government Sector Impact:
None.
VI. Technical Deficiencies:
None.
VII. Related Issues:
The bill provides a new veterinary professional associate but does not provide a licensure
structure.
VIII. Statutes Affected:
This bill creates section 474.2126 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.