America has too few veterinarians — in some counties, none at all. Yet for half a century, one organization has forecast the opposite: a surplus. That same organization holds the lock on the gate into the profession — and the U.S. Justice Department has now told a federal court the arrangement is not above the antitrust laws.
In parts of rural America, there is no veterinarian at all — not a shortage of them, but none, for a sick animal or an emergency, across an entire county. Where the veterinarians are, in the cities and suburbs, a family with a sick dog can wait two or three weeks for an appointment, and clinics run help-wanted ads that go unanswered for a year. Animal shelters cannot staff the clinics they already operate. Ranchers across whole regions cannot find a large-animal veterinarian at any price, for any animal, in any season. This is not a projection or an advocacy talking point. It is the daily, measurable condition of the profession — and the federal government has certified it, in one form or another, for sixteen years without a break.
Here is the part that does not fit. The one institution best positioned to let more veterinarians be trained has spent the last fifty years warning of the opposite problem — a surplus, too many veterinarians. And that same institution holds one of the two locks on the gate into the profession: it decides, in large part, how many new veterinarians the country is allowed to produce.
An organization that believes there are too many veterinarians, deciding how many there may be. That is not a conspiracy theory; it is a matter of public record, and it is the specific arrangement federal antitrust law has learned to treat as a red flag. In December 2025, the U.S. Department of Justice told a federal court that this kind of structure is “not exempt from the antitrust laws.” What follows is how the gate was built, what its keeper has predicted for fifty years, and why the shortage in the exam room and the case in the courtroom turn out to be the same story, seen from two ends.
Begin with what cannot be argued. Since 2010, the U.S. Department of Agriculture has formally designated rural “veterinary shortage situations” — places with too few veterinarians to protect animal and public health. If the profession truly had a glut, that count should be falling toward zero. It has done the reverse. In 2025 the USDA declared 243 rural shortage areas across 46 states — the most ever recorded. Year after year, beef-cattle medicine is named the discipline most acutely short-staffed.
These are federal numbers, not NAVEC’s. There is a separate debate about exactly how large the shortage will grow in years to come — that involves modeling and forecasting, and reasonable people argue about it. This article does not rest on any of that. It rests only on what is already measured and on the record: clinics that cannot hire, shelters that cannot staff, ranchers who cannot find help, and sixteen straight years of federal shortage designations. The government’s own scoreboard is enough.
To see how the door got so narrow, stop thinking of a list of separate institutions and picture a single gate. To practice veterinary medicine in the United States, a person must, in almost every case, do three things in this order — and two of them are controlled by the profession itself, with essentially no public oversight.
This story turns on the first lock. The Council on Education, an arm of the American Veterinary Medical Association (AVMA), substantially determines how many veterinary colleges exist — and therefore, in large part, how many new veterinarians the pipeline can ever produce. It is the choke point on supply. And the body that holds it has spent fifty years insisting that supply was already too high.
That is not our characterization. It is a documented, repeating pattern in the AVMA’s own commissioned research — and the clearest catalog of it was written inside the AVMA itself. In 2013, Dr. Michael Dicks, then head of the association’s economics division, reviewed the record and concluded that the profession’s own habits “may have nudged the profession toward an excess of veterinarians.” Here is the ledger he was describing.
A forecast has one honest virtue: once its target year arrives, anyone can grade it. Several of these named specific years — 1990, 2000, 2009, 2025 — so they can now be checked against data from sources with no stake in the veterinary labor market. They did not just miss. They pointed the wrong way.
Start with the boldest testable claim: that veterinary pay would fall by roughly a quarter. It is the kind of prediction that cannot hide. Either paychecks shrank or they did not. Federal wage data give the answer.
Now step back and ask the simplest question a market can be asked. When there is too much of something, what happens to its price? It falls. A glut of anything — apartments, engineers, veterinarians — pushes prices and wages down and makes hiring easy. That is what a surplus looks like. For fifty years, the profession was told a surplus was here or coming. For those same fifty years, veterinary pay rose, decade after decade, and hiring became not easier but nearly impossible. Rising pay alongside unfillable jobs is not the signature of a surplus. It is the textbook signature of a shortage. The market was sending the opposite signal the whole time.
The other testable prediction fares no better. The 2013 workforce study projected that 11 to 14 percent of veterinary labor would sit unused through 2025. By 2025, the country instead had a record number of federal shortage areas and veterinarian unemployment under one percent. Here are both forecasts, held against what the independent data actually recorded.
And an independent federal auditor was on the record in the middle of the surplus era. In February 2009, the Government Accountability Office — which has no stake in the profession’s internal debates — found “a growing national shortage of veterinarians,” with federal food-safety agencies unable to fill positions and more than a quarter of the relevant federal veterinary workforce eligible to retire within three years. Even granting the most generous reading of the AVMA’s own metric — that “excess capacity” meant underused working hours rather than unemployed veterinarians — rising pay, sub-1% unemployment, and record federal shortage designations are simply not what a glut produces.
In 2024 the posture changed. The AVMA’s own commissioned study — the Brakke analysis, published in JAVMA that November — concluded the data “do not support an expectation of a continued shortage,” called existing colleges adequate through 2035, and warned against the supply growth new schools would bring. That placed the accreditor at odds with the very colleges it accredits: the association representing those schools had commissioned its own 2024 analysis, finding that new-graduate output would meet only about 73 percent of need through 2030 — a finding the AVMA publicly criticized.
Whether that 2035 forecast proves right is unknowable today; its deadline has not arrived. But notice the constant across the whole fifty years. Through “we have too many,” through a lived stretch of “we have too few,” and now through “we’ll have just enough,” one thing never changes: the recommended policy is always the same — do not expand the pipeline.
Now put the two facts side by side. The institution with a fifty-year record of forecasting oversupply is the same institution that holds the lever controlling supply. The body that believes there are too many veterinarians is the body that decides how many there may be.
Consider who a narrow gate helps and who it hurts. It hurts the family that cannot get an appointment, the rancher who cannot find help, the shelter that cannot staff its clinic, and the qualified would-be student turned away from a profession that needs them. It does not hurt everyone. When there are too few veterinarians, the veterinarians who already hold licenses face less competition, stronger bargaining power, and higher pay. NAVEC does not claim to know what any individual intended. But the incentives are not hidden, and the question is a fair one to ask out loud: how does an institution read the same market backwards for fifty years running — and land, every time, on the recommendation that happens to protect those already inside the gate?
To be precise, and fair: none of this proves that the AVMA restricted accreditation in order to limit supply, or that anyone acted with unlawful intent. NAVEC makes no such accusation. It does not need to — and neither does the law. What matters here is the structure, because the structure is exactly what antitrust law has learned to treat as dangerous regardless of anyone’s motives.
That is the plain lesson of a 2015 Supreme Court decision, North Carolina State Board of Dental Examiners v. FTC. Put simply: when a body run by the members of a profession gets to write the rules of competition for that same profession, the law will not simply trust it. It cannot claim immunity from the antitrust laws unless the state is actively supervising what it does. The reasoning had nothing to do with proving bad faith. A regulator staffed by competitors will always be tempted to regulate in the competitors’ favor — so the law demands real public supervision as the price of a free pass. In veterinary medicine, that supervision is essentially absent.
There is one more feature here that the dental case did not even have. In a normal market, a shortage cures itself: scarcity drives up pay, higher pay draws in new entrants, and supply rises to meet demand. In veterinary medicine, that self-correction is disabled. No matter how severe the shortage or how high the pay climbs, the number of new veterinarians cannot grow faster than the accreditation gate permits — and that gate is held by a body that has spent fifty years arguing against expansion. The exact mechanism a healthy market uses to fix a shortage is the mechanism a controlled gate holds shut. That is why the empty exam room and the antitrust filing are not two problems. They are one.
The examination half of the gate carries its own history of conflict-of-interest concern. The ICVA, which owns the NAVLE, began life in 1948 as a committee of the AVMA itself. It was separated in the mid-1990s for a reason directly on point: attorneys general in several states raised concerns about the profession’s trade association also controlling the licensing exam. The separation was real. But the ties did not disappear. The ICVA’s chief executive was recruited directly from the AVMA’s senior staff, and the AVMA’s Council on Education — the accreditation lock — holds a designated seat on the ICVA’s board.
NAVEC documented the examination half separately in The Gatekeeper No One Can Audit, which showed that the fairness of the NAVLE cannot be independently verified by anyone outside the ICVA — not even the state boards that condition licensure on it. Set beside the accreditation story, the shape is identical on both sides: two locks, both private, both tracing back to the same institution. A gate is only as independent as its least independent half.
None of this is a novel legal theory. It is the structure that established law already addresses — and that federal enforcers are now actively litigating.
The pieces line up. The 2015 decision supplies the rule: a self-interested private body regulating its own competition, without active state supervision, is open to antitrust scrutiny. The LMU complaint supplies the application: the COE is such a body, and its accreditation standards are the instrument. And what the public record had been missing — what this study adds — is the answer to the one question a skeptical court is bound to ask: why would the gatekeeper want the gate kept narrow? The answer is written in the AVMA’s own commissioned research and its own economists’ words: a fifty-year documented disposition to treat new veterinarians as “excess capacity.” That is motive in structural form — established without alleging a single secret agreement.
The shortage the public can see and the antitrust question the Justice Department has joined are not two stories. They are one structure, seen from two ends. At one end is the pet owner who cannot get an appointment, the rancher who cannot find a large-animal vet, the shelter that cannot staff its clinic. At the other is a gate into the profession held, on both sides, by private bodies governed by the established profession — and shielded, by their own grip on supply, from the market signal that scarcity would otherwise send.
NAVEC’s position is reform or replace. Reform, where these institutions can be made genuinely independent, publicly supervised, and open to verification — where the accreditation gate is separated from the trade association whose members it serves, where the exam is opened to real external audit, and where state boards reclaim the supervisory role the law already assumes they hold. Replacement, under the boards’ own authority, where reform fails. What cannot continue is the present arrangement: a half-century of forecasts that never arrived, writing the next half-century from behind a gate that no one outside the profession can open, supervise, or verify.
Read the full study → “The Gatekeepers and the Gate” — NAVEC’s complete Report No. 4, with the full forecast ledger, primary sources, the legal architecture, and the case for reform.This article summarizes a NAVEC research study built from primary sources and named third-party positions. It does not assert that any individual or entity entered an unlawful agreement or acted with anticompetitive intent. Its thesis is narrower and factual: the structure of the veterinary licensing gate — private control of both accreditation and examination, insulated from market correction and unsupervised by any state — is the structure that established antitrust and consumer-protection law now scrutinizes, and that structure warrants reform. NAVEC uses only public, citable data. It identifies issues for examination by regulators and counsel, and it is not legal advice.
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