As the deadline looms to submit comments on the American Veterinary Medical Association’s (AVMA) proposal to remove the farriery exemption from the Model Veterinary Practice Act (MVPA), two of the largest farrier associations issued statements on the issue Monday.
The American Farrier’s Association (AFA) released its official response to the proposed changes, which was submitted to the AVMA. The American Association of Professional Farriers (AAPF) detailed four options as guidance for its membership in submitting comments to the AVMA.
In its official response to the AVMA’s proposed changes, AFA President Travis Burns acknowledged statements from AVMA officials that, “The proposed removal of ‘farriery’ from the exemption section to the MVPA is in no way an attempt to ban farriers working independently or require a veterinarian to be involved in shoeing a horse. Rather, it is an acknowledgement that farriery exists well outside of the definition of veterinary medicine and does not need to be included in the MVPA.”
While the AFA views the AVMA’s statement as “an endorsement of our profession,” it is not represented in the proposed changes as many other proposals are.
“Nevertheless, the aforementioned statement is unlikely to resonate with individual states if it is not part of the MVPA itself,” according to the AFA’s statement. “The AFA respectfully requests that the AVMA incorporates the statement that ‘farriery exists outside the realm of veterinary medicine’ within the MVPA. This will help prevent state[s] from making rash decision[s] about the oversight of farriery, especially without the aid of organizations such as the American Farrier’s Association.”
The AAPF issued its official response Feb. 9.
“Without hesitation, we remain strongly opposed to the current proposed modifications, specifically relating to the elimination of the ‘art or profession of farriery’ exemption,” according to the AAPF’s statement. “In addition, we are unwilling to compromise in our commitment of having farriers recognized for their expertise and professionalism which they offer to the equine industry. We firmly believe that with farriers working cooperatively with veterinarians, horse owners, trainers, grooms, and fellow farriers, it will result in the continued good health of the horses which we care for on a daily basis.”
The Northeast Association of Equine Practitioners (NEAEP), which has a membership that consists of equine veterinarians and farriers — issued its official response Feb. 14.
“The Northeast Association of Equine Practitioners was the first organization to include farriers in our definition of ‘equine practitioners’ and to actively foster the relationship between veterinarians and farriers,” according to a statement attributed to David Dawson, NEAEP’s executive director and CEO. “We are in active communication with multiple professional organizations to present a united voice in support of the current art of farriery exemption. The NEAEP will continue to advocate for the betterment of both professions.”
In addition, the AAPF offered its membership guidance on submitting comments to the AVMA regarding its proposal. The AAPF suggests that its members “cut and paste” the option that is preferred or create a personalized response. The four options offered by the AAPF are:
“Option 1: I am firmly committed to the professionalism of the art, science, and technology of the farrier profession. I would ask that the AVMA recognize this professionalism which exists in our two professions and retain the exemption for farriery in your proposed Model Veterinary Practice Act of 2018,” according to the statement.
“Option 2: The veterinarian and farrier have enjoyed a long-term relationship and I would hate to see the elimination of the ‘art or profession of farriery’ exemption in your proposed Model Veterinary Practice Act. I would ask that you respectfully reconsider this proposed elimination.
“Option 3: As a professional farrier I enjoy excellent relationships with the veterinarians and horse owners which I work with on a daily basis. We have established platforms upon which we offer a dialogue which ultimately benefits the horses which we serve. Please reconsider the elimination of the exemption for farriery in your proposed 2018 Model Veterinary Practice Act.
“Option 4: I have a tremendous amount of respect for the veterinarians which I get to work with on a daily basis. These same vets have shown me an equal amount of respect for the professionalism which I bring to the overall health of the horses which we work on. I believe making a change like eliminating the exemption for the art or profession of farriery from the proposed Model Veterinary Practice Act would not be a positive step for our two professions. Please reconsider your proposal.”
The AVMA unveiled its proposed MVPA on Jan. 19, 2018, and asked for comments from its members, non-member vets and the public before the March 25, 2018 deadline.
“At the close of the 60-day review period, a working group will review all submitted comments and forward recommendations to the Council on Veterinary Service for further review,” according to the AVMA. “A final draft of the revised MVPA will be sent to the AVMA board of directors for consideration. It is likely the board will ask the AVMA house of delegates to review and approve any revisions.”
The proposed elimination of the farriery exemption from the MVPA is significant because the current AVMA defines “practice of veterinary medicine,” as:
“a. To diagnose, prognose, treat, correct, change, alleviate, or prevent animal disease, illness, pain, deformity, defect, injury, or other physical, dental, or mental conditions by any method or mode; including the:performance of any medical or surgical procedure, or
i. prescription, dispensing, administration, or application of any drug, medicine, biologic, apparatus, anesthetic, or other therapeutic or diagnostic substance, or
ii. use of complementary, alternative, and integrative therapies, or
iii. use of any procedure for reproductive management, including but not limited to the diagnosis or treatment of pregnancy, fertility, sterility, or infertility, or
iv. determination of the health, fitness, or soundness of an animal, or
v. rendering of advice or recommendation by any means including telephonic and other electronic communications with regard to any of the above.
b. To represent, directly or indirectly, publicly or privately, an ability and willingness to do an act described in subsection 16(a).
c. To use any title, words, abbreviation, or letters in a manner or under circumstances that induce the belief that the person using them is qualified to do any act described in subsection 16(a).”
The MVPA is not biding law; however, states use it as a guide when updating its respective Veterinary Practice Acts (VPA).
According to the AVMA, 17 state VPAs — Alaska, Arkansas, Florida, Georgia, Idaho, Iowa, Maine, Maryland, Minnesota, Mississippi, New Hampshire, North Carolina, Ohio, Oklahoma, Pennsylvania, Texas, Vermont — specifically exempt farriery, horseshoeing, hoof trimming and trimming feet.
Another 12 state VPAs — Colorado, Delaware, Illinois, Louisiana, Massachusetts, Montana, Nevada, New Mexico, Rhode Island, Tennessee, West Virginia — exempt accepted livestock management practices and animal husbandry practices.
The remaining 20 states and the District of Columbia — Alabama, Arizona, California, Connecticut, Indiana, Kansas, Kentucky, Michigan, Missouri, Nebraska, New Jersey, New York, North Dakota, Oregon, South Carolina, South Dakota, Virginia, Washington, Wisconsin, Wyoming — make no mention of farriers, farriery, horseshoeing or livestock management practices.
To read the proposed MVPA, visit https://www.avma.org/KB/Policies/Documents/Model-Veterinary-Practice-Act-Draft-2018-01-12.pdf. To comment on the proposal, visit https://www.avma.org/KB/Policies/Documents/AVMA-Model-Veterinary-Practice-Act-Comment-Form.pdf. The AVMA is accepting comments from the public before the March 25 deadline.
For more coverage of the AVMA’s proposed changes to the MVPA, read “Farriers Question AVMA’s Proposed Elimination Of Exemption” in the March 2018 issue of American Farriers Journal, as well as continuing coverage in the upcoming April 2018 issue.