Wisconsin Statute s. 89.05(2)(h) provides an exemption to veterinary licensure requirements for graduates of schools outside of the United States and Canada who are enrolled in the educational commission for foreign veterinary graduates certification program of the American Veterinary Medical Association (ECFVG) while completing the required year of clinical assessment under the supervision of a veterinarian. 

The final step of the ECVFG program, Step 4, is no longer a year of clinical assessment, but instead requires completion of a three-day clinical proficiency exam (CPE). The exemption from licensure is explicit and applies only while completing a year of clinical assessment as part of the ECFVG certification program, and it cannot be interpreted to apply to enrollees waiting to take their CPE. If there is not a year of clinical assessment, there is no licensing exemption.

The Veterinary Examining Board (VEB) understands that this exemption has been interpreted in the past to apply to enrollees in step 4 of the ECFVG awaiting to take their CPE.  However, as of the date of this notice, the Board’s position is that individuals who start Step 4 of the ECFVG after the date of this notice may not practice veterinary medicine within the exemption. This means enrollees in the ECFVG will not be able to practice veterinary medicine under the supervision of a licensed veterinarian. If working in a veterinary capacity, these individuals are treated by law as unlicensed assistants. An alternative for these individuals may be to pursue obtaining certification to become a certified veterinary technician through the alternative education pathway while completing the ECFVG program.

Individuals who start Step 4 of the ECFVG after the date of this notice and engage in the practice of veterinary medicine may be subject to penalties for unlicensed practice under Wisconsin Statutes ss. 89.079 and 89.08. Veterinarians who supervise such individuals and improperly delegate veterinary medical acts to them may be subject to discipline under Wisconsin Statute s. 89.07(1) and Wisconsin Administrative Code s. VE 1.58.

The VEB is not “rescinding” the status of ECFVG enrollees who are in Step 4 of the ECFVG and currently practicing veterinary medicine under the licensing exemption.  Those enrollees may continue to practice under the exemption until they take the CPE. If they do not pass the CPE, they may not continue to practice.   

The VEB may take action against such enrollees should their actions violate the laws governing unprofessional conduct.