The Case For and Against the Mid-Level Practitioner, Fairly Stated

"Veterinary professional associate" (VPA) is Colorado's statutory term; "mid-level practitioner" (MLP) is the generic term critics and commentators use for the broader category. They read as synonyms only when the subject is Colorado law, where the role now formally exists.

Elsewhere, MLP describes any proposal to place a new mid-scope profession between credentialed technicians and licensed veterinarians.

The idea has a specific origin.

It surfaced in Colorado's 2021–2022 sunset review of its veterinary practice act, and in summer 2022 state Rep.

Karen McCormick — a veterinarian — convened a working group of roughly 35 stakeholders that met biweekly to shape a legislative proposal.

It never became one.

After six months, most previously undecided participants had concluded against the role, and proponents pivoted to a citizen ballot initiative instead.

That initiative, Proposition 129, passed on November 5, 2024 with 52.76% of the vote, writing the framework directly into Colorado statute.

It defines a VPA as someone holding a master's degree in veterinary clinical care "or the equivalent," and requires board registration for anyone practicing as one from January 1, 2026.

Colorado State University's Master of Science in Veterinary Clinical Care is the only announced pathway to that degree anywhere: five semesters — three online, one with 416 hours of in-person training, then a 540-hour clinical internship — with applications for its first cohort of 20–30 students opening February 3, 2026.

The published admission baseline is a bachelor's degree plus 150 hours of verifiable veterinary experience; a technician credential is not required.

Everything beyond the degree, though, is what this page is about: whether the role should exist at all.

The argument has run through Colorado's ballot, its legislature, and every national association in the profession, and both sides have stated their positions in unusually explicit terms.

The base role the debate rearranges is covered in what a veterinarian does.

The access argument is the official one.

Colorado's Blue Book — the nonpartisan voter guide — summarized the case for in these words: "Many Coloradans struggle to get veterinary care for their animals, especially in rural and agricultural communities... Veterinary professional associates could provide needed relief to overworked veterinarians, allowing them to delegate additional tasks and take better care of animals in Colorado." The same guide noted the role "may create more training and career opportunities for veterinary professionals, leading to expanded access."

The campaign behind the measure, "All Pets Deserve Vet Care," drew its funding primarily from two animal-welfare organizations: the Dumb Friends League (roughly $1 million) and the ASPCA, with about $1.4 million in total contributions reported by election day, per secondary coverage of Colorado's campaign filings.

Its workforce evidence leans on a Mars Veterinary Health report (August 2023) projecting that the U.S. will need as many as 55,000 additional veterinarians by 2030 to meet companion-animal care demand.

Colorado State's own program page frames the job as proponents intend it: VPAs would "deliver routine care under the supervision of a licensed veterinarian" and "focus on front-line assessments, freeing up veterinarians to focus on complex cases." Even the Association of American Veterinary Medical Colleges — whose March 2024 workforce statement predates Colorado's VPA and endorses no specific model — called for the profession to "initiate a profession-wide discussion to consider a new mid-level professional, similar in concept to a nurse practitioner or physician assistant."

The shortage numbers behind this argument are contested, and the counter-case is substantial — that fight is covered in rural practice and shortage-area incentives.

The related retention argument, that overworked veterinarians are leaving clinical practice outright, is treated in leaving clinical practice without leaving the field.

The opposition is broad and formal.

AVMA's position: "Creating a veterinary midlevel position (MLP) is neither a sufficiently targeted nor practical approach to address existing workforce issues. More expedient and sustainable solutions are available." It opposes initiatives authorizing "a midlevel position or other nonveterinarian to diagnose, prognose, develop treatment plans, prescribe, and/or perform surgery," and as of September 2026 lists every state veterinary association — all 50 states plus DC and Puerto Rico — among the opposed.

AVMA's stated reasons, in its own sequence: the role is not needed, because delegation to existing credentialed staff already covers the work; it is not safe yet, because no accredited program, national test, or complete regulatory structure existed when the measure went to voters; and it is not the physician-assistant analogue proponents invoke — "human medicine and veterinary medicine are NOT the same," and the proposed training is "not comparable" to a PA's or APRN's.

It also flags liability, since the supervising veterinarian bears legal responsibility for a VPA's acts and omissions; staffing, since a VPA needs technician support and competes for the same scarce labor; and its own 2023 National Pet Owner Survey, in which 79% of pet owners said they want a licensed veterinarian, not a midlevel employee, overseeing their pet's care.

The Colorado association went furthest: "CVMA strongly opposes the mid-level veterinary practitioner as a new professional, and opposes any education program that would educate and graduate such a professional" (position adopted 2022, updated January 2023).

Its objections: expand delegation to existing credentialed technicians instead; no competence-assessment system for a new role exists and building one would "take years"; and the projected $80,000 VPA salary "does not fit the current reality" — AVMA reported in 2022 that only 43% of all 2021 graduates earned $80,000 or more (how graduates are actually paid is covered in new-grad veterinarian salary).

AVMA separately calculated the CSU program's tuition at roughly $34,430 in-state / $77,151 out-of-state — an estimate built on a pre-launch 65-credit-hour curriculum figure, not a price CSU itself has published.

The technicians' own association does not support it either, from a different direction.

NAVTA's formal position (March 12, 2026): "NAVTA does not support the current Veterinary Professional Associate (VPA)/Mid-Level Practitioner (MLP) model," favoring instead "a progressive, Veterinary Technician-centered education and career pathway" through accredited bachelor's and master's-level programs and specialty credentialing.

In NAVTA's own 2022–2023 member survey, creating a midlevel position ranked seventh of eight priorities.

AAVSB holds the most complicated position in the debate, and both halves matter.

Its 2025 resolution calls shortage concerns "overblown," notes twelve new veterinary schools are projected to add 300–500 graduates, and warns the role "could erode the integrity and defined scope of practice" of credentialed technicians — yet the same body voted in June 2025 to fund development of Colorado's national VPA exam, a carve-out its chief executive says the resolution itself preserves.

Neither half of that position is citable without the other.

Colorado's official ballot guide stated the case against plainly: the education and training requirements are "vague and do not differentiate veterinary professional associates from existing veterinary care professionals"; no academic programs existed in the state, so "it is unclear when anyone would be eligible to work as a veterinary professional associate"; and "creating a new and untested profession could increase risk for animals."

Strip out the rhetoric and the enacted statute is more constrained than either side's framing.

Under HB25-1285 (signed May 30, 2025; effective January 1, 2026), a VPA practices veterinary medicine only under immediate or direct supervision by default — indirect supervision must be earned through clinical-hour benchmarks the board has not yet set — on the same premises as the supervising veterinarian unless those benchmarks are met, with no telesupervision permitted and a hard cap of three VPAs per supervising veterinarian at any one time.

A written supervisory agreement must be filed and kept on record with both parties.

Two powers stay out of the VPA's hands entirely.

The veterinarian-client-patient relationship can be established only by a licensed veterinarian — a VPA cannot originate one.

And Colorado's prescriber definition for electronic controlled-substance prescribing (C.R.S. 12-30-109(4)) names only the licensed veterinarian; the VPA appears nowhere in it.

That is the clearest statutory evidence that the role carries no independent prescribing authority — anything claiming otherwise contradicts the statute as of 2026.

The scope itself is defined differently from any existing role's.

A technician's boundary is a fixed statutory negative list — no diagnosing, prognosing, prescribing, or surgery, in every state (what only a veterinarian can do).

A VPA's boundary is case-by-case: only duties delegated by the supervising veterinarian, for which that veterinarian judges the individual VPA to be trained.

It is the delegation duty practices already owe (what you can legally delegate), pointed at a new role — and that flexibility is precisely what AVMA and the ballot guide's argument against both call vague.

The statute also answers one employer-side worry: no corporation, employer, director, or officer may require a veterinarian to enter a VPA supervisory agreement or to supervise a VPA as a condition of continued employment (2025 amendment).

Practicing as a VPA without registration is a class 2 misdemeanor, and the "VPA" and "RVPA" titles have been protected since January 1, 2026.

And the timeline, from the regulator itself: Colorado DORA states the baseline Proposition 129 rules are complete and effective January 1, 2026, but the more detailed HB25-1285 rulemaking — the indirect-supervision hour threshold, credentialing-organization approval, scope specifics — remained pending; as of April 2026, secondary coverage of the board's discussions reported that no credentialing or testing organization had been finally approved yet.

DORA's licensing guide (February 2025) says VPA registrations "may not be obtained until sometime in late 2026," because the required national exam — in development with AAVSB's 2025 funding commitment — must first exist and be passed.

No one has registered as a VPA anywhere.

One other state has legislated on this seriously.

Florida introduced mid-level-practitioner bills in both 2025 (SB 652 / HB 729, filed February 2025) and 2026.

The 2026 Senate bill — CS/SB 796, the "Veterinary Workforce and Innovation Act" — cleared all three Senate committees with bipartisan votes (9–0, 11–0, 21–1) before dying on the calendar on March 13, 2026; its House companion died the same day.

That makes Florida the most legislatively advanced non-Colorado effort to date — a proposal with real committee momentum, not a fringe measure, but not law.

Per AVMA's own state-legislative tracking (reported in secondary coverage), Colorado and Florida were the only two states with mid-level-practitioner bills in the 2025 or 2026 sessions.

As of September 16, 2026, Colorado remains the only U.S. jurisdiction with an enacted VPA framework.

The full dated state-by-state status — every row, plus the registration bottleneck that keeps anyone from practicing under Colorado's law yet — is the mid-level role state tracker's subject.

For all the volume, the disagreement is narrower than it looks: both sides claim the same ground — better use of the existing team.

CVMA "supports increased utilization and education of veterinary technicians." NAVTA wants advancement through structured technician education rather than a parallel profession.

AAVSB's 2023 survey found most North American veterinarians and technicians favor better technician utilization over creating a new mid-level role.

The actual dispute is whether that requires a new profession or better deployment of the credentialed one already on the payroll.

Both sides also argue from workforce projections the other rejects: 55,000 additional veterinarians needed by 2030 (Mars Veterinary Health) against a Brakke Consulting analysis finding no dire shortage, which notes the companion-animal share of the profession grew from 61% to 73% between 2001 and 2023 and that new schools will add supply only slowly.

Neither number settles anything — both are methodological contests, not measurements.

What would actually move the debate is dated and checkable: final approval of a VPA credentialing organization and national exam; the Colorado board's pending rulemaking on indirect-supervision hours; CSU's first cohort, whose applications opened February 3, 2026; and the first VPA registration, which the regulator says cannot happen before late 2026.

Until then, each side's strongest claim stays untestable — proponents cannot demonstrate access gains from a role no one holds yet, and opponents' safety concerns remain predictions until someone does.