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Veterinary Medical Board moves to raise unlicensed-practice citation amounts and remove cap; opens rulemaking to align regulations
Summary
The board voted to propose statutory and regulatory changes to increase civil penalties for unlicensed veterinary practice, add veterinary assistant and veterinary‑premises registrations to citation authority, and remove the current $5,000 per‑violation cap.
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The Veterinary Medical Board on Jan. 14 authorized a multi-step approach to strengthen penalties and enforcement tools for unlicensed veterinary practice.
What the board approved
- Statutory change: The board voted to submit a legislative proposal to amend Business and Professions Code section 48.75.2 to add veterinary-assistant‑controlled‑substances-permit (VACSP) holders and veterinary‑premises registration holders to the list of persons who can receive citations and to expand citation authority for unlicensed practice.
- New statutory section and penalties: The board also voted to add a new BPC section (proposed 48.75.7) to remove the single $5,000 cap that currently limits total civil fines for unlicensed‑practice citations. The change would allow citation amounts tied to each violation and eliminate the existing statutory ceiling.
- Regulatory cleanup: The board authorized a parallel change to remove outdated CCR Title 16 references that currently classify unlicensed‑practice citations as a class C violation with a $2,000–$5,000 range; the proposed action would eliminate the fixed classification so the statute could set ranges without being constrained by the classification language.
Why the board acted
Board members and investigators said the current $5,000 cap is insufficient to deter some unlicensed activity and that other member boards of the American Association of Veterinary State Boards do not impose a similar cap. Stakeholders who attended MDC meetings generally supported increasing citation ranges to better discourage unlicensed practice, the board staff reported.
Board action and next steps
The board voted to submit the legislative proposal and to initiate rulemaking to screen and align citations and CCR provisions with the proposed statute. If adopted, the changes would allow the executive officer to issue higher citation amounts for unlicensed practice and expand the board’s ability to cite VACSP and veterinary‑premises registration holders when appropriate.
Provenance (meeting transcript excerpts): - "The subcommittee recommends the attached legislative proposal to increase the range associated with unlicensed practice and removal, and remove the overall cap on unlicensed practice, citations." (MDC memo) - The board voted on the proposed statutory and regulatory changes and authorized staff to proceed with legislative submission and CCR amendments.

