The New Licensing Rule and Veterinary Care for Dogs

Last Modified: February 18, 2024

In May 2020, APHIS published a new regulation, often referred to as the Licensing Rule (APHIS-2017-0062). The new rule changes the requirements for maintaining a license under the Animal Welfare Act and adds new requirements for watering and veterinary care of dogs. 

Specifically, all regulated facilities are required to work with their attending veterinarian to develop a written program of veterinary care for their dogs. This includes facilities that employ a full-time veterinarian. Facilities are also required to maintain medical records for dogs.

The new regulations for veterinary care can be found in Section §3.13 (3.67 MB) of the Animal Welfare Regulations.

The Written Program of Veterinary Care

The written program of veterinary care must include:

A scheduled visit by the attending veterinarian not less than once every 12 months.

  • The purpose of a facility visit is to ensure that the attending veterinarian is aware of the conditions of the animals and facilities; and has the information needed to ensure the provision of adequate veterinary care and to oversee the adequacy of animal care and use.
  • The attending veterinarian has the flexibility to determine the specific details and schedule of the facility visits. Annual visits are the minimum required in the new regulation; however, visits should occur as often as necessary to provide adequate oversight. Additional site visits may also be necessary for disease outbreaks; ill or injured animals; training of caretakers, or for the proper introduction of new animals.
  • Animals in need of care may be taken to the clinic or practice of the attending veterinarian. These visits do not replace the need for regularly scheduled visits to the regulated facility.

A complete ‘head to tail’ physical exam on all dogs not less than once every 12 months to ensure their health and wellbeing.

  • The physical examination is to be performed in accordance with the standard of veterinary medicine. The attending veterinarian has the flexibility to make determinations regarding the specific procedures associated with the physical exam.

Vaccination schedules for contagious and deadly diseases including rabies, parvovirus, and distemper.

  • Vaccination against rabies, parvovirus and distemper must be given because these are significant contagious and deadly diseases of dogs. Rabies is also a serious deadly disease to both humans and other animals. Vaccinations for additional pathogens may also be appropriate in some areas. Whether to include vaccinations for additional pathogens is at the discretion of the attending veterinarian.
  • The attending veterinarian has the authority to determine the most appropriate vaccination schedule for the facility. However, the schedule should also be in accordance with current professional or industry standards and/or recommendations made by the vaccine manufacturer.
  • The new regulations do not require that the vaccinations be given by the attending veterinarian. However, regulated facilities must also follow state and local regulations on canine vaccinations. Many states require that rabies be given by a licensed veterinarian.
  • The American Veterinary Medical Association manages an up to date resource on state requirements for rabies vaccination. This resource can be found on the AVMA website.

A schedule for sampling and treatment for parasites and other pests, including fleas, worms, coccidia, giardia, and heartworm.

  • The expectation is for adequate monitoring to prevent or minimize clinical illness.  Routine sampling must be done regardless of the presence or lack of clinical signs. 
  • Parasite sampling and testing methodology, the frequency of sampling, and the number of dogs sampled is at the discretion of the attending veterinarian.  This includes whether the testing may be performed by the licensee or registrant, or if it needs to be performed by a veterinary professional. 
  • Heartworm prevention is strongly encouraged but is not required.
  • Appropriate treatment is required for parasites, including heartworm.  Euthanasia may be an appropriate treatment, as long as it is an approved form of euthanasia and is directed by the attending veterinarian.

Preventive care program to ensure healthy and unmatted coats, properly trimmed nails, and clean and healthy eyes, ears, skin, and teeth for their dogs.

  • The attending veterinarian may exclude specific dogs for medical justifications; however, an attending veterinarian cannot exclude an entire facility of the listed vaccines, parasite testing or treatments.

Updating the Written Program of Veterinary Care

Due to the change in the licensing process, there has also been concern regarding whether a new written program of veterinary care would be required each time a facility applies for a new license. Facilities may use an existing written program of veterinary care when applying for a new 3-year license as long as they are still following the practices described. A new or revised written program of veterinary care would only be needed if there are changes to the veterinary care programs.

Medical Records

Facilities must maintain all medical records for their dogs and make them available during inspections.  Medical records need to include identification, records of routine husbandry (such as vaccinations and preventive medical procedures, testing, or treatments), and a description of any clinical veterinary issues.

Herd or group records may be used provided that all of the required medical record information is included and sufficient to determine the treatment or care that each animal has received.


In the Animal Welfare Regulations, the definition of a dog includes any dog-hybrid cross, including a wolf-hybrid.  Facilities must meet all of the dog requirements for these animals, including the “head to tail” physical exam and vaccinations.  Animal Care recognizes that sedation may be required to safely handle some dog-hybrid crosses.  It will be up to the AV to determine the best strategy for safely conducting annual physical exams.

Additional Resources