New Policy on Not-for-Profits Delivering Veterinary Services

The AVMA Executive Board recently replaced two dated policies addressing delivery of veterinary services by not-for-profit or tax-exempt organizations with a more detailed, comprehensive policy that recognizes that such organizations help provide access to important medical and surgical services for animals owned by the indigent and otherwise underserved populations. However, the policy also calls for the organizations to comply with applicable federal, state and local regulations, including the Internal Revenue Code, and rulings applicable to tax exempt organizations providing fee-for-service veterinary care. The new policy states that not-for-profits should comply with state laws addressing organizations’ missions and funding,  ownership of veterinary practices by non-veterinarians and veterinary facility licensure and quality standards. Where applicable, means testing to determine eligibility should be conducted in compliance with each organization’s internal documents for clients accessing veterinary services.

The full text of the new policy is found at http://www.avma.org/issues/policy/delivery_of_veterinary_service_by_not_for_profit.asp.

 

13 thoughts on “New Policy on Not-for-Profits Delivering Veterinary Services

  1. The best New Policy on Not-for-Profits Delivering Veterinary Services,
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  2. i was recently charged $25.00 at a private vet practice for an antibiotic, something that if i had been given a prescription, i could have gotten at my local pharmacy for $4.00. the idea that if i make a certain amount of $$ i should pay a higher price for veterinary service is absurd & fast going by the wayside.

    if veterinaians are concerned about IRS & non profits, i, as a consumer, am concerned about monopolies and price fixing. be careful what you wish for.

  3. I agree with everything the other folks have contributed here. I personally participate in low-cost spay/neuter on a regular basis, and have been able to observe over the last few years how non-profits treat the vets they employ. What I see happening is that these ostensibly charitable organisations just use vets up – they pay very low salaries and expect vets to work for free because it is our “vocation”. Well, I’m not a nun, and I don’t see any of them offering to help me pay off my enormous vet school student loan, or paying my retirement or pension. That is something I have to do myself. Being a veterinarian in the US now carries no respect or status any more. I once had a kennel volunteeer tell me she “would have loved to go on that course you go on to be a vet!” Unlike the Royal College of Veterinary Surgeons in the UK, the AVMA seems to have done almost nothing to promote us as skilled professionals to the general public. Why is that? Are we not as intelligent or as skilled as MDs or as lawyers? Why am I billing less per hour for my services than my classic car mechanic, and being made to feel guilty for it? That’s my elephant in the room.

  4. I am not really sure if this is an issue that AVMA can have much influence over.Although many of the employees of the non-profts are veterinarians I believe that in most cases the administration officers of the non-profits are generally not veterinarians.I dont think the non-vets have any concerns about the potential negative effects on private practices that non-profits have.
    AVMA has an obligation to advise ALL veterinarains regardless of whether they work for private practices or non-profits.
    I truly believe the situations where non-profits operate at a significant competitive advantage pose a threat to the health of private practices.
    If it proven that these non-profits do not means test they should lose the financial incentives that the non-profit status carries. After all if they are given tax breaks to help indigent pet owners and dont means test they really are no different than a private hopsital and should be taxed accordingly.
    I think AVMA should lobby the IRS to ensure that unfair business practices are stopped.Ultimately it is up to the IRS if they decide to enforce this.
    The other issue here (and to me the real elephant in the room) is responsible pet ownership.Owning an animal is not a right and taking away SOME of the barrier to pet ownership (ie cheap spays) without comprehensive preventive health education and follow up is going to give us a generation of pets that have no direct veterinary supervision sinc e the owners cant afford regular care and especially cant afford to treat their pets when they get sick.

    We have a responsibility to our patients and our profession to advocate RESPONSIBLE PET OWNERSHIP.The notion that doing something for poor clients is better than doing nothing although noble does not fit with our goal of promoting responsible pet ownership

    Non-profits in many caases do not provide the relationship between a client and a veterinarian that is vital to ensure the welfare and health of their pets. A client can get a low cost spay, a free Rabies vaccine and pick something off the shelf at Walmart for parasite prevention, but what happens when their pet needs medical care? Are we really doing the pets any favors if we think that this scenario is good for the pet?

    I believe AVMA should be a strong advocate for the veterinary client patient relationship and we need to be aware of how this can be affected by facilities that do not provide comprehensive services to their clients.

    If we truly believe we are posed to be an important part of the one health concept we need to ensure we are the ones providing ALL of the veterinary care and information to our clients. Imagine a situation where canine influenza crosses species barriers. Most private practices would have a good way to contact clients and have the ability to provide information and/or treatment to their clients pets. This would prove difficult with clinics that only provide spay/neuter services and dont keep track of their client list.

    So I believe there is a lot AVMA can do to produce guidelines. Non profits are here to stay and I think they can provide a service, but we need to be sure we are involved in their decision making processes.
    We ultimately need to maintain our postion as the leaders in providing not only veterinary care, but preventive health care and justify our role as an important part of the one health philosophy by being the professional sentinels for zoonotic disease

  5. I appreciate that the AVMA wishes this statement to be brief. The problem that I see is that it is too brief! We need to educate the public on what the elephants are, because they do not know how to recognize one. Please listen to the people who are more eloquent than I am in stating these problems. I have worked for years in the veterinary field, only to see us slandered by PetMeds and the not for profits for WANTING TO MAKE A LIVING by helping people with their pets. This is not something that we should castigated for. Veterinary medicine is still one of the best bargains in health care – even in a traditional setting with full taxes paid. I do not expect to retire rich, but I would like to be able to support my family without going on food stamps.

  6. @Pat Wohlferth-Bethke DVM
    Pat,

    thanks for you additional comments and clarifications. I think that most of us agree on many issues that you have covered here.

    I don’t expect the AVMA to regulate or enforce rules as they pertain to non-profits, but it would be nice to see something of signifigance in a policy statement.

    I applaud and greatly respect my colleagues who donate their time for efforts such as these, but when I read all the work that has gone into creating this statement, I am left with the question of what is the point? It doesn’t seem to address anything, and if that is the case, why even bother with it?

  7. @Pat Wohlferth-Bethke DVM I guess the problem I have with the policy statement, is that it does not make clear the fact that many NFPs are currently violating IRS code and some state and local regulations. As Greg pointed out, it sounds odd to say “everyone should obey the laws” without an explanation of why such a simple statement is necessary. The specifics that are in the background paper, should be incorporated into the policy statement.

    I also think that if the NFPs tax exempt status is based on low income status of their clients, then needs testing should not be “according to the organization’s internal documents.” It should be according to IRS (federal) rules.

    Why is AVMA worried about “potential legal challenge” if the policy statements are “not regulations and are not intended as legal advice?” You say the policy statements are designed to inform AVMA members about various issues, and “provide other interested people with veterinary perspectives.” I don’t really think it accomplishes that goal. If I were a vet tech working at a HSUS spay neuter clinic, I don’t think this statement would help me to understand how my employer may be causing harm to the veterinary profession.

    I understand that much thought and effort and hard work are put into these statements, and I appreciate all steps in the right direction. Just trying to coax a little further progress on this issue.

  8. We understand and appreciate the concerns of those affected by businesses offering competitive services to clients at a lower cost, especially when so many are struggling in a down economy. We also understand that there is a need to provide basic veterinary services to those in financial need, and that much of practicing veterinarians’ concern is that the not-for-profits may be providing services without confirming true financial need, resulting in what the veterinarians in private practice perceive to be unfair competition.
    AVMA policies are developed to inform members and to provide other interested people with veterinary perspectives on a range of issues. They are not regulations and are not intended as legal advice. In crafting and adopting policy, volunteers in AVMA leadership (who largely are your veterinary colleagues) evaluate scientific evidence, various professional viewpoints, and legal and ethical considerations.
    In this particular case, the Council on Veterinary Service (CoVS) thoroughly considered the issue and sought input from the Animal Welfare Committee and the State Advocacy Committee. In addition, AVMA’s legal counsel reviewed tax and anti-trust laws to ensure the AVMA was not overstepping its bounds and opening itself or the profession to legal challenge based on the policy or backgrounder contents.
    Each business, whether it’s a not-for-profit or a private veterinary practice, operates under myriad local, state and federal laws. No two not-for-profit businesses are set up the same way. Regulations are in place to prevent abuse of the system. Each alleged infraction of the regulations has to be painstakingly investigated, taking into account the organization’s charter and appropriate laws. The Internal Revenue Service does not have the resources to keep an eye on each business for which they award tax exemptions. The investigation starts locally, with local and state veterinary organizations becoming involved as appropriate. These cases may take years to conclude, with varying results. Our latest backgrounder document, Delivery of Veterinary Services by Not for Profit/ Tax Exempt Organizations, found at http://atwork.avma.org/wp-content/uploads/2012/05/AVMA-Veterinary-Services-Backgrounder-5-1-12.pdf
    provides more information and insight into the complexities of the issue.
    Veterinarians, including veterinarians who work for not-for-profits, spend years learning how to care for animals and take an oath upon graduation to do so. As colleagues, we share the common goals of providing quality care for animals and good service for clients. As a profession, let’s focus on educating the public about its responsibilities toward animals and how the veterinary profession contributes to good animal (and human!) health and welfare. Business models may differ, but we all need to be fairly compensated for our skills while providing the variety of services society needs. There is ample opportunity for all of us to work together to achieve both goals.

  9. @Adrian
    Thank you for that information. It would seem that veterinarians have very good grounds for their objections to these businesses, and that the IRS agrees. Perhaps we should all start reporting these groups to the IRS and let them do the inquiries.

  10. I agree that this is far too wimpy of a statement. I was recently called by a new non profit organization that opened a veterinary clinic in town. They wanted to hire me for $50 per hour to provide veterinary services at the new clinic. When I asked what criteria were used to determine client use of the facility, the dirrector stated flatly that their doors were open to anyone who wanted to come in. She felt that such an open door policy was necessary because “vet care around here is so ridiculously expensive that no one can afford to take a pet to the vet.”
    I declined the offer and mentioned that perhaps part of the reason vets were expensive is that they have to PAY TAXES.
    This sort of competition is unfair and surely illegal. What is to stop all of us from becoming non-profits? We can still collect a decent salary (as the heads of HSUS and ASPCA do) and just avoid all those pesky taxes. Can’t AVMA take a stronger stand and encourage the IRS to investigate these groups? No doubt they have lots of clout and do lots of good things for animals, but operating fee for service veterinary clinics for the general public should not qualify as a 501c3 operation.

  11. I guess I don’t really understand what this means. The way I read it, you are stating that the AVMA’s new policy on non-profits is that they should follow federal,state, and local regulations/laws.

    Is that it? That seems like stating the obvious to me.

  12. While this policy is a good first step, it doesn’t go far enough and sugar coats many of the real issues. I feel the main underlying issue is that non-profit spay and neuter organizations feel traditional veterinary care is too expensive and that all we care about is making money. We, as a profession, have supported these causes for years only to have them bite us in the rear end with funding that is donated. I propose that these causes use their donations to support local veterinarians, not sabotage them. Use us! Let us give back to our communities in ways we can afford! Private practices are under assault from pharmaceutical companies too. Our financial challenges are every increasing. We need some real strong leadership from the AVMA, and I mean more than studies that take years to complete. There are elephants in the room.