← This is the full letter, as submitted. Back to the open letter
To Attorney General Josh Kaul:
Executive Summary
The problem. A single private organization — the International Council for Veterinary Assessment (ICVA) — controls the only licensing exam every Wisconsin veterinarian must pass, with no public oversight. The AVMA controls the only U.S. veterinary-school accreditor and the only foreign-graduate credentialing program. The U.S. Department of Justice has publicly framed this kind of private gatekeeping as anticompetitive conduct subject to antitrust enforcement (DOJ Antitrust Division, Statement of Interest, Dec. 15, 2025).
Other states are confronting this. In January 2026, Texas became the first state in the nation to end the American Bar Association’s role as gatekeeper to the legal profession. The same principle applies here — a private body should not be the unaccountable gatekeeper to a publicly-required Wisconsin license.
ICVA’s conduct is documented and serious. Its own published policies authorize: cancellation of passing scores in sole discretion with no appeal; sanctions for behavior “contrary to the moral norms of the general community” as ICVA defines it; a sweeping speech ban on candidates; on-demand searches of candidates’ personal documents, data, and devices, with permanent disqualification for non-cooperation. A 1,200+-signature petition and an October 2025 pre-litigation notice from a national plaintiffs’ firm allege the NAVLE is “potentially anticompetitive, fraudulent, and discriminatory.”
A documented pattern of misrepresentation. On December 26, 2025, ICVA’s CEO made representations through interstate wires to VIN News — that the NAVLE had already been “audited” and “confirmed” to fully meet professional standards, that the new audit’s “goal” is “validation,” that NBME is responsible for scoring, and that ICVA is transparent. Each representation is contradicted by ICVA’s own published Candidate Handbook or by the underlying documents ICVA itself cites. The cited 2020 California OPES Review was not an audit, did not analyze fairness, and expressly found ICVA “not in compliance with” California Business & Professions Code § 139. On June 4, 2026, ICVA further disclosed an audit architecture under which its law firm engages the auditor (capturing findings as work product under attorney-client privilege), and the request-for-proposals defining what the audit is actually examining is being withheld from disclosure as, in ICVA’s response by email to a direct inquiry, “private.”
The financial stake is documented and direct. Public IRS Form 990 filings show ICVA’s annual revenue grew from $3.6M (FY2011) to $10.15M (FY2025); net assets stand at $18.3M, held by an organization with 9 employees; 91% of revenue comes from candidate fees; revenue grew 92% from 2020–2025 while NAVLE pass rates fell from ~95% to ~87%. ICVA earns essentially every dollar of its revenue from the very consumers its representations are calibrated to reassure.
What we ask. Open a formal investigation under Wis. Stat. § 100.18 (deceptive trade practices), Wis. Stat. § 100.20 (methods of competition and trade practices), and Wis. Stat. ch. 133 (Trusts and Monopolies); issue civil investigative demands under your office’s authority under § 100.18(11) and § 165.25; seek emergency injunctive relief before the next NAVLE administration; coordinate with the FTC, the DOJ Antitrust Division, and the DOJ Criminal Division for parallel review under federal wire fraud (18 U.S.C. § 1343) and, where the documented pattern supports it, RICO (18 U.S.C. §§ 1961–1962); and direct the Wisconsin Veterinary Examining Board to establish a provisional, supervised licensure pathway for affected candidates.
We are a coalition of Wisconsin veterinary clinic owners, veterinarians, hospital administrators, shelter leaders, dairy and livestock producers, animal-health professionals, pet owners, and concerned citizens. A single private organization controls the only gateway to a veterinary license in Wisconsin — and operates that gateway with powers no public licensing authority in this state would ever be permitted to hold.
Across Wisconsin, veterinary clinics are turning animals away — not because owners want to, and not because clients cannot pay, but because there are not enough veterinarians to see them. Practice owners work 70- and 80-hour weeks covering shifts no one is left to fill, until their health or their families give out; clinics with loyal, paying clients cut hours and close; and in much of rural Wisconsin a dairy farmer cannot find a large-animal veterinarian within an hour’s drive. This is not a problem of money. It is a problem of people — and the pipeline that should be producing those people is controlled, end to end, by private organizations that answer to no one. America is running out of veterinarians. Veterinary costs are up more than 60%. More than half of pet owners have skipped or declined care. USDA recognizes hundreds of veterinary shortage areas across 46 states. The country has lost roughly 90% of its large-animal and livestock veterinarians. This shortage jeopardizes public health and the integrity of the U.S. food supply. As America’s Dairyland — home to more than 5,500 dairy farms, roughly 1.2 million dairy cows, and approximately 14% of the nation’s milk supply, with agriculture contributing more than $116 billion annually to the state’s economy — Wisconsin’s stake is not measured only in clinic wait times. Without enough veterinarians, herd health, mastitis and reproductive management, zoonotic disease surveillance, food-animal inspection, and the safety of the dairy products that leave this state cannot be assured. And according to a recent U.S. Department of Justice filing, this shortage is not the natural product of market forces — it is the predictable product of monopoly gatekeeping. On December 15, 2025, in Lincoln Memorial University v. American Veterinary Medical Association, the DOJ Antitrust Division wrote that “accreditors and occupational and professional licensors can artificially limit the supply of service providers, thus reducing output, competition, and incentives for innovation,” and that this “ultimately harms consumers, who face higher costs and fewer choices.” DOJ was describing the AVMA’s control over which veterinary schools may exist. But the same private apparatus controls two more gates every Wisconsin veterinarian must pass through: a single private exam that decides who is allowed to practice, and a single private credentialing program that decides whether a veterinarian trained abroad — including one already living and working in Wisconsin — may ever be licensed at all. This letter concerns both.
That organization is the International Council for Veterinary Assessment — ICVA.
Every state that requires the NAVLE has handed this private monopoly the same unchecked power. States are beginning to confront private gatekeepers of public licensure. In January 2026, Texas became the first state in the nation to end the American Bar Association’s role as gatekeeper to the legal profession, when the Texas Supreme Court ruled that the ABA should no longer have the final say over who may sit for the bar — a change the Federal Trade Commission supported, calling the ABA a monopoly. The same principle applies here, and your office already holds the tools to act on it. Your office exists to protect a free and honest marketplace for Wisconsin consumers; Wis. Stat. § 100.18 (fraudulent representations and deceptive trade practices), Wis. Stat. § 100.20 (methods of competition and trade practices), and Wis. Stat. ch. 133 (Trusts and Monopolies) reach exactly this conduct. Your investigative authority under § 100.18(11) and § 165.25 extends to private and nonprofit entities whose practices harm Wisconsin consumers and markets, including the authority to compel testimony and documents.
Before the specific facts below, the economic stake should be on the table. ICVA is not a struggling nonprofit defending its mission. Public IRS Form 990 filings show ICVA’s annual revenue has nearly tripled since 2011, from approximately $3.6 million to $10.15 million in fiscal year ending May 2025. Net assets stand at $18.3 million, held by an organization with nine employees. Approximately 91% of ICVA’s 2025 revenue — over $9.2 million — came from candidate fees; ICVA solicits no contributions. Every dollar of ICVA’s revenue comes from the very candidates whose confidence its representations are calibrated to maintain. Every retake generates another fee. Every score cancellation that forces a retake generates another fee. Between fiscal 2020 and fiscal 2025, ICVA’s revenue grew by 92%, from $5.3 million to $10.15 million — while NAVLE pass rates fell from approximately 95% to roughly 87%. As consumer concerns about exam quality have grown, ICVA’s revenue and asset base have grown with them, not against them. CEO total compensation has roughly doubled over the same period. This is the financial frame in which the conduct described below should be evaluated.
What ICVA Is, and How It Operates
ICVA is a private 501(c)(3) nonprofit with absolute monopoly control over the design, administration, and scoring of the NAVLE — the exam Wisconsin and every other state require to practice veterinary medicine. It is run by a small group of industry insiders. No state, no licensing board, and no public regulator has oversight authority over any aspect of the exam, its administration, or its scoring. ICVA observes none of the transparency protocols common to other major U.S. licensing exams. It has never been audited by an independent third party. It publishes no detailed binding blueprint of exam content — and the limited blueprint materials it does publish are, by ICVA’s own admission, neither binding nor necessarily representative of the live exam. It does not publish an industry-standard detailed technical manual. It does not conduct fairness or item-level consistency studies, an industry standard for all high-stakes licensing exams. It does not release a reviewable bank of retired NAVLE questions — by comparison, NBME publishes approximately 1,400 reviewable retired USMLE Step 1 questions with answer explanations and posts a free 120-question USMLE sample set on usmle.org. It has never opened NAVLE data to independent peer-reviewed analysis: the only published study using NAVLE item-level data was a 2018 paper co-authored by ICVA’s own CEO and its testing contractor, NBME, and no comparable analysis of NAVLE fairness across schools, regions, or candidate groups has ever been published — even though NBME published exactly such an analysis of USMLE Step 1 in Academic Medicine in 2022. It reserves total discretion in scoring with no appeal and no transparency, and it reserves the unilateral right to invalidate or cancel a passing score with no justification owed to the candidate or to any state veterinary board. Every candidate must accept ICVA’s Candidate Agreement or be permanently barred from the profession; it is not a negotiated contract but a condition of entry imposed by a private, out-of-state organization on the terms of entry into a Wisconsin-licensed profession. Based on a wide and converging range of allegations and ICVA’s own confirmed practices, the NAVLE is the textbook case for why anti-monopoly laws were enacted in the first place. The specific abuses follow.
The exam itself is documented as defective. A public petition signed by over 1,200 candidates, veterinarians, and educators documents that the live NAVLE contains “confusing and poorly written questions,” “content not matching the published blueprint,” and questions with no defensible correct answer. A major national plaintiffs’ firm, after “review of scores of records, interviews with dozens of candidates, and a review of publicly available data,” corroborated the same exam-construction problems in a formal written notice to the American Veterinary Medical Association on October 23, 2025.
The published allegations point to outcomes a fairly scored exam would not produce. The same firm’s notice concludes that the NAVLE “as currently designed, administered, scaled, and used, is potentially anticompetitive, fraudulent, and discriminatory,” and that the pattern of outcomes “appear[s] designed, unlawfully, to limit who has access to a career in veterinary medicine.” The same notice reports, on the record of a sourced senior veterinarian whistleblower, that a NAVLE grader “has bragged that his work includes failing test takers of color, stating not to worry because ‘I will keep the brown ones out.’”
ICVA has granted itself powers over candidates no public body could lawfully hold.
*Cancel or invalidate a passing score at sole discretion — with no reason, no recheck, and no appeal. *ICVA reserves the right to withhold, cancel, or invalidate a score based on internal statistical models it never shows the candidate, and its own policy confirms no rescore or appeal is permitted. A candidate who believes a computer error or scoring mistake on ICVA’s own end cost her the result has no right to a recheck, is owed no explanation, and has no one to appeal to. A qualified Wisconsin veterinarian can lose her license-qualifying score to a private model she will never see.
*Ban a candidate for violating “the moral norms of the general community” — without ever defining what that means. *ICVA’s November 2025 policy authorizes it, in its sole discretion, to investigate and sanction a candidate for conduct contrary to “the moral norms of the general community” — a standard ICVA never defines, with no connection to the exam, to cheating, or to anything ICVA could have witnessed. By what right does a private testing vendor that has never met the candidate claim authority to judge personal morality and end a veterinary career over it? It is an open-ended morality clause whose meaning is left entirely to the discretion of the organization that controls the score, with no external review.
*Punish a candidate for discussing the exam at all — even to expose its flaws. *ICVA’s ban on discussing exam content is so broad it requires no allegation of cheating or copyright theft. A candidate violates the agreement simply by telling a classmate that the exam did not match the published blueprint, or that a particular question had no defensible correct answer. ICVA has made it a punishable offense to document the very defects that would prove the exam is broken.
*Search a candidate’s personal documents, data, and electronic devices on demand — long after the exam is over. *ICVA reserves the right to compel candidates to “produce all documents, data, and materials reasonably requested by ICVA,” with no defined scope, no time limit, no warrant, no probable cause requirement, and no requirement to suspect cheating or copyright violation. Failure to comply is itself grounds for permanent score cancellation and disqualification — making the “production” request, in practical effect, a coerced search by a private body that holds the career-ending leverage.
No one has ever independently verified this exam — and ICVA has built it so no one can. Wisconsin requires the NAVLE, yet:
No state board or independent body has ever conducted a forensic audit of the live scoring, or so much as seen ICVA’s raw score-production logs, item-level data, or equating outputs.
ICVA does not publish the identities of the subject-matter experts who write its questions or the volunteers involved in scoring and review. The people deciding who becomes a veterinarian are anonymous and unaccountable.
Every other major licensing exam supports candidates with detailed content manuals and books of retired questions. ICVA offers a vague blueprint and a handful of sample questions. Candidates must pass a high-stakes exam they are given little legitimate means to prepare for, and no way to verify it matched the blueprint they were told to study.
Because ICVA discloses no meaningful data and treats discussion of the exam as a punishable offense, no candidate, state board, or attorney general can determine whether the NAVLE is fair, accurate, or lawfully administered without compelled access and a forensic audit.
The coalition does not assert that every allegation against ICVA above is proven. We cannot independently verify them. But neither can ICVA’s defenders, the state veterinary boards, the AVMA, or your office disprove them — because the data needed to test them has never been independently audited, has never been published, and is held exclusively by ICVA. That is itself the indictment. A licensing system whose most serious allegations cannot be tested against the evidence, because the only entity holding the evidence refuses to release it, is a licensing system operating without oversight. The remedy is not to dismiss the allegations. It is to compel production of the records that would resolve them. Wisconsin’s antitrust and consumer-protection statutes give your office exactly that authority.
One documented pattern illustrates exactly why the sealed data matters. Tuskegee University has trained veterinarians for more than eighty years and has educated a large share of the nation’s veterinarians from underrepresented backgrounds. Its NAVLE pass rate, long near 90%, fell year after year to a low of roughly 51% in 2024 before recovering to about 72% in 2025. A sudden, sustained decline of that magnitude at a respected, long-established institution is precisely the kind of pattern any sound licensing system would examine and explain. But only ICVA holds the underlying item-level and scoring data, and it has not released it. As a result, no one — not the school, not the state boards, not your office — can determine whether the cause lies with the candidates, with the examination, or with something else. The coalition does not claim to know the answer, and is not suggesting Wisconsin lower its standards. The point is narrower and harder to dismiss: because the data is sealed, no explanation can be confirmed and none can be ruled out. A licensing monopoly that affects this many careers, and this many Wisconsinites who depend on veterinary care, should be able to answer that question in the open — and only compelled production of its data can make that possible.
ICVA has effectively admitted its own data shows a problem — then refused to say what. After the legal notice, ICVA issued a sweeping retake reset: five new attempts for every candidate, all prior attempts erased, pending waivers voided. ICVA said the change rested on a “comprehensive review of candidate feedback and NAVLE data.” If “NAVLE data” justified erasing the testing histories of thousands of candidates, that data shows something. ICVA has not published it, named the reviewers, described the method, or shared the findings with state boards. A public licensing system cannot run on private confessions paired with private silence.
ICVA answered scrutiny with more power, not more transparency. Eight days after the retake reset, ICVA adopted the broad investigation-and-discipline policy described above — expanding its unilateral control over candidates rather than opening its books. Accused of unreliable outcomes; admitted its own data justified rewriting the rules; responded by arming itself to discipline the people raising concerns.
The “audit” is now disclosed — and the disclosure makes the deception worse. The December 1, 2025 announcement initially named no auditor, defined no scope or methodology, set no timeline, committed to publish no findings, and promised review of no raw item data, score holds, invalidations, equating, or subgroup outcomes. When candidates and clinic owners pressed ICVA for the audit’s basic terms, the answer changed each time. First, the RFP was “not yet finalized.” Then, the RFP was “confidential.” On May 14, 2026 — more than five months after announcing the audit — ICVA wrote directly to a veterinary clinic owner by email: “We have engaged outside counsel to oversee the search, engagement, and audit process, and they are currently in the final stages of selecting the independent, third-party auditor.” Then, on June 4, 2026, ICVA disclosed the architecture in a public update on its own website. In ICVA’s own words: ICVA “has asked Dorsey & Whitney LLP to manage the audit process. Dorsey issued a request for proposals and selected ACS Ventures, Inc., to conduct the audit.” The auditor is engaged by ICVA’s law firm, not by ICVA directly. The auditor’s drafts, working papers, and conclusions become the law firm’s work product, captured under attorney-client privilege from the moment of creation. Nothing the auditor produces is required to be released; ICVA, through counsel, decides what is released and what isn’t. The same June 4 announcement states ACS Ventures “will consider and apply industry standards and best practices to evaluate fairness and validity throughout the exam cycle” — language that, to a reader who has spent a year demanding an independent forensic audit of how the exam is constructed and scored, sounds like a forensic audit. ICVA has committed to nothing of the kind. The RFP — the document that actually defines what ACS was hired to examine — has not been disclosed. When ICVA was directly asked by email to disclose the RFP, ICVA responded that the RFP is “private.” Not privileged under any legal doctrine. Just private. For a procurement document that defines the scope of a public audit announced in response to public concerns, “private” is not a legal position. It is a choice. ACS will examine whatever its engagement requires it to examine. If that engagement defines the work as a procedural review of ICVA’s policies and procedures — the kind of review California’s OPES already conducted in 2020 — ACS will conduct a procedural review. And ICVA’s chief executive has already publicly demonstrated her willingness to call a procedural review an “audit” when she needs to. The pattern is the prediction. The deception is documented in the next section.
A Pattern of Misrepresentation — and Why Wisconsin Law Reaches It
The conduct described above is not merely an abuse of monopoly position. ICVA is a vendor. The NAVLE is a product. The candidates are consumers — Wisconsin consumers, in significant numbers, who pay ICVA $825 or more for U.S. registration and up to $1,220 for international registration, in reliance on ICVA’s public claims that the exam they are required to purchase is fair, audited, and held to recognized professional standards. Wisconsin’s deceptive trade practices statute, Wis. Stat. § 100.18, prohibits “any assertion, representation or statement of fact which is untrue, deceptive or misleading” made with intent to induce the public to enter into a transaction — and the Wisconsin Supreme Court has long held that the standard for § 100.18 looks to the net impression created in a reasonable consumer, not to literal falsity alone. Wis. Stat. § 100.20 reaches unfair methods of competition and unfair trade practices in business. Both reach exactly the conduct at issue here.
Based on the documented public record, we believe ICVA’s representations to Wisconsin candidates and to the national press meet that standard. Made through email and other interstate wires to influence consumer purchasing decisions and public confidence — in support of the candidate-fee revenue stream documented at the outset of this letter — they raise serious additional questions under federal wire fraud (18 U.S.C. § 1343), which treats schemes to obtain money or property by false or fraudulent pretenses, transmitted by interstate wire, as a federal offense. The federal Racketeer Influenced and Corrupt Organizations Act (18 U.S.C. §§ 1961–1962) treats a pattern of two or more such predicate acts, committed by an enterprise affecting interstate commerce, as actionable. We do not allege in this letter that any court has adjudicated such violations to have occurred. We allege that the documented facts below give your office reason to believe such violations may have occurred — the threshold under Wis. Stat. § 100.18(11) and § 165.25 for exercising your civil investigative authority — and warrant concurrent referral to federal authorities for parallel review.
The four representations
On December 26, 2025, ICVA’s chief executive Dr. Heather Case made a series of representations to VIN News by email — an interstate wire — that were then published nationally to influence the consuming public. Each is contradicted by ICVA’s own published policies or by the underlying documents ICVA itself cites.
1. The OPES “audit” claim. Case told VIN that “in 2020, the California Veterinary Medical Board, through the Department of Consumer Affairs’ Office of Professional Examination Services, reviewed the NAVLE’s suitability for ongoing use in California’s licensing process. It confirmed that the NAVLE’s development, administration, and scoring fully met all applicable professional guidelines and technical standards.” The actual OPES document — titled Review, not audit — is a California state-board procedural-compliance review whose stated primary intent, in its own Executive Summary, was “to evaluate the suitability of the NAVLE for continued use in California licensure.” OPES did not examine the question bank, did not analyze item-level data, did not review scoring outcomes by candidate group, did not conduct Differential Item Functioning or any other fairness analysis, and did not investigate any of the specific concerns now being raised. Its methodology, in OPES’s own words, was to “receive and review documents provided by ICVA.” And OPES did not give the NAVLE a clean bill of health: it expressly found ICVA “not in compliance with OPES 18-01 as mandated by B&P Code § 139” — California’s own conflict-of-interest regulation — and recommended that ICVA phase out the use of faculty members and educators in NAVLE exam development and passing-score setting. Case’s representation that OPES “confirmed” the NAVLE “fully met all applicable professional guidelines and technical standards” omits this non-compliance finding and converts a narrow procedural review into a categorical fairness validation the underlying document does not support. This matters beyond the past tense. ICVA’s chief executive has publicly demonstrated her willingness to call a procedural review an “audit” when she needs to — establishing the pattern by which whatever ACS Ventures produces under the audit architecture disclosed June 4, 2026, however limited its actual scope, may be characterized to the public when its findings are released.
2. The predetermined-conclusion audit framing — confirmed by the architecture ICVA later disclosed. In the same exchange, Case represented: “We expect the independent third-party audit to affirm the integrity of the NAVLE. … Our goal is to provide clear, objective validation that our processes are rigorous, fair and aligned with best practices.” An independent audit, by definition, does not begin with the goal of validating a predetermined conclusion. ICVA’s subsequent conduct confirms that the December representation was not a misstatement. On June 4, 2026, ICVA disclosed the audit architecture: a law firm — Dorsey & Whitney LLP — manages the process; the law firm issued the request for proposals; the law firm selected and engaged the auditor — ACS Ventures, Inc. The auditor is the law firm’s contractor, not ICVA’s. The auditor’s drafts, working papers, and conclusions are captured as the law firm’s work product, under attorney-client privilege, the moment they are created. ICVA, through counsel, decides what is released. ICVA’s same June 4 statement says ACS Ventures “will consider and apply industry standards and best practices to evaluate fairness and validity throughout the exam cycle” — language that, to a reader who has spent a year demanding an independent forensic audit, sounds like a forensic audit. ICVA has committed to nothing of the kind. The request-for-proposals — the document that actually defines what ACS was hired to examine — has not been disclosed. When ICVA was asked directly, by email, to disclose the RFP, ICVA responded that the RFP is “private.” Not privileged under any legal doctrine. Just private. A public audit announcement made in response to public concerns, whose defining scope document the announcing organization withholds without legal basis, is not a communication failure. It is a representation that uses words a reasonable consumer will perceive as meaning a forensic audit while concealing whether the work commissioned bears any resemblance to one — the textbook pattern of producing-tendency-to-deceive analyzed under Wis. Stat. § 100.18. The structural choices — law-firm management, work-product privilege over findings, RFP withheld as “private,” no commitment to publish, a fifteen-month timeline to Q1 2027 — are precisely what would be required to deliver the predetermined “affirmation” Case publicly committed to in December.
3. The scoring deflection. Case told VIN that NBME is responsible for “key components” of the NAVLE, “including item editing, technical review, and scoring and score report creation.” The net impression for a reasonable consumer is that scoring decisions — including decisions to cancel or invalidate scores — are made by a separate, non-ICVA entity. ICVA’s own published Candidate Handbook (2026–27, page 36) directly contradicts that impression: “ICVA reserves the right to cancel, invalidate or withhold any NAVLE® score if, in its sole judgment: there is a reasonable basis to question the exam score’s validity,” and “ICVA is not obligated to further investigate the matter.” NBME performs scoring computation; ICVA reserves to itself the authority to cancel, invalidate, or withhold the resulting scores — the decisions that actually end careers.
4. The transparent-process claim. Case represented that ICVA “produces public documents about how the exam is designed, tested and administered, such as a candidate bulletin, and implements an ‘in-depth practice analysis’ every seven years.” A candidate bulletin is not a technical manual. ICVA publishes no technical manual of the type the AERA/APA/NCME Standards for Educational and Psychological Testing require for high-stakes licensure exams, no item-level psychometric data, no Differential Item Functioning analyses, no comparable peer-reviewed fairness studies, and no binding blueprint. A practice analysis is a periodic review of what an entry-level veterinarian needs to know — it is not a fairness audit. The comparator record is unambiguous: the National Conference of Bar Examiners and the National Board of Medical Examiners both publish detailed technical manuals and substantial banks of retired questions with answer explanations. The claim that ICVA’s published materials place it among “transparent” exam administrators cannot be sustained against that record.
The pattern is itself the evidence
At the time of the four representations above, ICVA had in hand: a formal pre-litigation notice from a national plaintiffs’ firm alleging the NAVLE is “potentially anticompetitive, fraudulent, and discriminatory”; a public petition with over 1,200 signatures documenting specific exam-construction defects; public letters from a coalition of Black veterinary candidates and from the Latinx Veterinary Medical Association calling for an independent third-party audit; and — by its own later admission — internal data sufficient to support a sweeping retake-policy reset. Faced with this specific, documented consumer ask, ICVA’s chief executive made representations through interstate wires whose cumulative effect was to reassure the consuming public that the concerns lacked basis, that the exam had already been audited and validated, that the new audit would simply confirm what was already known, that scoring was someone else’s responsibility, and that ICVA was a transparent organization. Each representation was made with full knowledge of what the consuming public was asking for and what ICVA’s own published policies and the underlying cited documents actually said. A pattern of representations made in the face of a specific public consumer ask, all running in the same direction, by an organization that controls both the message and the underlying record — and that earns essentially all of its over-$10-million annual revenue from the consumers being reassured — is the structural evidence Wisconsin and federal courts use to find the deceptive intent required by both state DTPA law and federal wire fraud law.
We respectfully submit that this record meets the §§ 15.10 and 17.61 threshold for your office’s civil investigative demand authority, and that the documented federal interstate-wire conduct warrants concurrent referral to the U.S. Department of Justice and the Federal Trade Commission for parallel review under 18 U.S.C. § 1343 and, where the documented pattern supports it, 18 U.S.C. §§ 1961–1962.
The Same Pattern Repeats at a Second Gate — and It Is Wasting Veterinarians Wisconsin Already Has
The accreditation body has used its power the same way the exam board has. Acting on its own authority — without the agreement of the schools it governs — the AVMA’s Council on Education moved to impose new accreditation standards that many veterinary schools could not realistically meet. This was not a collaborative effort to raise quality through a standard the schools could actually achieve; it was a requirement handed down by decree. The U.S. Department of Justice has told a federal court that this is precisely how a profession’s own insiders can suppress competition: the same December 2025 filing warns that accreditors “typically consist of interested market participants who develop standards in closed doors” and “face an inherent conflict of interest when regulating admission into a profession,” and that such conduct “is not exempt from the antitrust laws merely because states require veterinarians to graduate from accredited schools.” The country’s largest veterinary school is challenging those standards in federal court now. We do not ask your office to take up the accreditation of veterinary schools, which is recognized at the federal level — but the episode confirms the pattern: a private, insider-run apparatus sits astride every gate into this profession, and exercises its power unilaterally, with the documented potential to limit how many veterinarians the country produces.
The same private apparatus controls a second gate, and the harm there is not hypothetical — it is happening now, to people already living in Wisconsin. Wisconsin does not allow a veterinarian who earned a degree abroad to be licensed on the strength of that degree and the NAVLE alone. Unless they graduated from one of roughly three dozen schools the AVMA itself has accredited, they must first obtain a certificate from the AVMA-run Educational Commission for Foreign Veterinary Graduates (ECFVG) or its counterpart — a process that culminates in the Clinical Proficiency Examination, a multi-day, seven-section hands-on practical that includes performing live surgery.
The bottleneck is by design and it is severe. The Clinical Proficiency Examination is offered at only two sites in North America, with a few hundred seats per year, more than half of them consumed by candidates forced to retake sections. The majority of candidates fail at least one of the seven sections on their first attempt, at roughly $1,450 per section, and applicants routinely wait more than a year — in documented cases, several years — simply to sit for it. More than two thousand internationally trained veterinarians are enrolled in this pipeline, many of them already lawfully in the United States, some living in Wisconsin right now and working as veterinary technicians and assistants — doing a fraction of the work they were trained to do — because a single private credentialing program controls whether they will ever be allowed to practice. In a state and a country with a documented, worsening veterinarian shortage, qualified professionals who are already here are being kept on the sidelines by the same kind of private gatekeeper this letter is otherwise about.
This is not how the higher-stakes professions treat foreign-trained applicants. A physician trained abroad is not required to repeat medical school or to pass a hands-on clinical-skills examination; the United States Medical Licensing Examination’s clinical-skills component was discontinued in 2021. A foreign-trained doctor qualifies by graduating from a medical school recognized through an established chain of national and international accreditors and by passing the standard written licensing exam. Wisconsin itself has already embraced this approach for physicians. In March 2024, Governor Evers signed 2023 Wisconsin Act 168 (AB 954), creating a pathway for internationally trained physicians with five years of foreign practice to obtain a provisional Wisconsin license and full licensure after three years of supervised practice — precisely to relieve a workforce shortage, with no requirement to repeat a United States residency. Wisconsin is one of approximately seventeen to eighteen states that have enacted such laws for physicians as of 2025–2026. If Wisconsin will trust that framework to put a foreign-trained physician in front of human patients, it is difficult to defend forcing a veterinarian already living in Wisconsin to spend years and many thousands of dollars repeating a surgical practical that the medical profession abandoned — administered by a private board with only a few hundred seats a year.
There is a straightforward, proven fix, and other states are already using it. New York does not force foreign-trained veterinarians through the AVMA’s ECFVG and its backlogged surgical exam at all; it evaluates the applicant’s education directly against its own standards, and it has not suffered any resulting collapse in quality. New Hampshire, Nevada, and others grant supervised conditional licenses that let qualified foreign-trained veterinarians work under a licensed veterinarian while completing any remaining requirements. Wisconsin can do the same — and it can go further by recognizing, for licensure purposes, graduation from a foreign veterinary school accredited by a strong national or regional veterinary accrediting body that meets recognized international standards. Such bodies already exist and are well regarded: the Royal College of Veterinary Surgeons in the United Kingdom; the European Association of Establishments for Veterinary Education across Europe; the Australasian Veterinary Boards Council; CONEVET, which accredits veterinary schools in Mexico, including the National Autonomous University of Mexico; and ARCU-SUR, the regional accreditation system covering Mercosur countries in Latin America. A Wisconsin veterinarian who graduated from a school accredited by a recognized body of this kind, and who passes the licensing examination, should not also be required to complete the AVMA’s ECFVG or its Clinical Proficiency Examination as a condition of practicing in Wisconsin. This mirrors exactly how the United States already treats foreign-trained physicians: it trusts a recognized accreditor rather than forcing every individual through a single private body’s redundant practical.
This Is Not About Lowering the Bar. It Is About Whether the Bar Is Real.
A genuine merit standard is one that can be verified — consistent, replicable, transparent, and auditable. ICVA has made verification impossible at every step: no exam review, no rescore, no appeal, no published fairness analysis, no access to raw scoring data, and a self-run audit it has not even started. An unverifiable standard is not a high standard. It is an arbitrary one.
We are not asking Wisconsin to lower the bar. We are asking ICVA to prove the bar is real. If it is, ICVA loses nothing by opening its records. Its refusal is the tell.
A private association should not be the unaccountable gatekeeper to a licensed profession that Wisconsin requires its citizens to pass through. That principle stands on its own, and it applies at both gates: the exam that decides who may practice, and the credentialing program that decides whether a veterinarian trained abroad may practice at all. America’s promise has always been that a person may earn their place through demonstrated merit, measured against standards that are public, fair, and applied to everyone alike. A system in which one private board can end a qualified person’s career through a process it refuses to show them, and a second private board can force a veterinarian already serving Wisconsinites to spend years repeating a surgical exam the medical profession has abandoned, is not the kind of standard a country built on earned opportunity should accept. Wisconsin has never been content to let unaccountable private gatekeepers decide who may work. It should not start now.
What We Ask Your Office to Do
Demand provisional, supervised licensure now — and protect Wisconsin from a possibly defective exam. Call on the Wisconsin Veterinary Examining Board to establish an interim, supervised licensure pathway for candidates who have satisfied every Wisconsin requirement except a NAVLE result that is itself under serious question — so qualified veterinarians are not permanently shut out of a profession in documented shortage. This pathway should remain available until the NAVLE is independently validated as fair, consistent, and compliant with Wisconsin law.
Open the second gate for veterinarians Wisconsin already has. Call on the Wisconsin Veterinary Examining Board to stop requiring the AVMA-run ECFVG certificate and its Clinical Proficiency Examination as a condition of licensure for veterinarians who graduated from a foreign veterinary school accredited by a recognized national or regional accrediting body meeting international standards — such as the Royal College of Veterinary Surgeons, the European Association of Establishments for Veterinary Education, the Australasian Veterinary Boards Council, CONEVET, or ARCU-SUR — and who pass the licensing examination. In the interim, and for graduates of schools outside those recognized systems, the Board should create a supervised conditional-license pathway, modeled on New York’s direct-evaluation approach and the conditional licenses already operating in New Hampshire and Nevada, so that qualified veterinarians already living in Wisconsin can practice under supervision rather than waiting years in a backlogged private queue. This relief is for people already lawfully here; it is a fix for wasted local talent, not an immigration measure.
Open a formal investigation under Wis. Stat. ch. 133 (Trusts and Monopolies), Wis. Stat. § 100.18 (deceptive trade practices), Wis. Stat. § 100.20 (methods of competition and trade practices), and your office’s nonprofit and consumer-protection authority, into ICVA’s role in Wisconsin licensure — governance, candidate contracts, score-invalidation practices, the retake-rule change, the new investigation-and-discipline policy, audit representations, communications with AAVSB, AVMA, NBME, and Wisconsin licensing authorities, and the pattern of representations to Wisconsin-domiciled candidates and to the national press regarding the NAVLE’s audit history, transparency, and fairness — and into the AVMA-run ECFVG and its Clinical Proficiency Examination as a condition Wisconsin imposes on foreign-trained veterinarians, including its capacity constraints, costs, wait times, pass rates, and competitive effects on the supply of veterinarians in Wisconsin.
Issue civil investigative demands under Wis. Stat. § 100.18(11) and § 165.25 for: raw item-level response data; score-production and quality-control logs; equating records; score-hold and invalidation files; candidate-investigation files; the “NAVLE data” review underlying the retake reset; all audit contracts, scope, and auditor-selection records, including the request-for-proposals issued by Dorsey & Whitney LLP defining the scope of the ACS Ventures engagement, ICVA’s engagement letter with Dorsey & Whitney, and all communications between ICVA and Dorsey & Whitney concerning the audit scope, methodology, and findings-disclosure provisions — with the explicit position that an audit promised to the public as “independent” cannot be simultaneously withheld on attorney-client privilege or work-product grounds, and that a procurement document characterized to the public as “private” without any asserted legal basis is not shielded from civil investigative demand; ICVA’s full email and other correspondence with national veterinary news outlets, including VIN News, from October 2025 forward; all internal ICVA communications, drafts, and review records concerning the December 26, 2025 statements to VIN News, the December 1, 2025 audit announcement, and the June 4, 2026 audit-architecture update; all written communications from ICVA representatives to journalists, candidates, or the public characterizing the RFP, the audit scope, or any audit-related materials as “private,” “confidential,” “privileged,” or otherwise withheld from disclosure; the underlying documents ICVA relied on to support its representations regarding the OPES 2020 review; and all ICVA representations to Wisconsin-domiciled candidates regarding the fairness, audit history, and grievance procedures of the NAVLE. Wis. Stat. § 100.18(11) and § 165.25 expressly empower the Attorney General, upon reason to believe a violation has occurred, to compel testimony and documents by civil investigative demand.
Seek emergency injunctive relief before the next NAVLE administration, barring ICVA from withholding, canceling, invalidating, or delaying any score used for Wisconsin licensure unless the candidate receives written findings, access to the evidence relied on, independent review, and a meaningful right to appeal.
Coordinate with the Federal Trade Commission, the DOJ Antitrust Division, the DOJ Criminal Division for parallel review under federal wire fraud (18 U.S.C. § 1343) and, where the documented pattern supports it, federal RICO (18 U.S.C. §§ 1961–1962), and other state Attorneys General. Wisconsin has worked with federal authorities before, and it should not wait to do it again.
The Bottom Line
There is one national veterinary licensing exam. Wisconsin requires it. ICVA controls it. Candidates must sign ICVA’s contract or be barred from the profession. By that contract, ICVA can cancel a passing score in its sole discretion, bar a candidate under a morality standard it writes itself, and punish a candidate for discussing the exam — none of it requiring proof of wrongdoing, none of it appealable. ICVA rewrote the national retake rules based on data it refuses to disclose. It announced an audit on December 1, 2025; six months later, on June 4, 2026, disclosed that its law firm Dorsey & Whitney LLP manages the process, ran the procurement, and engaged the auditor; and continues to withhold from disclosure the request-for-proposals that defines what the audit will actually examine — characterizing that defining document, in response to a direct email inquiry, as “private.” ICVA’s chief executive has made representations to the national press about the NAVLE’s audit history, transparency, and scoring authority that are contradicted by ICVA’s own published policies and the underlying documents ICVA itself cites — representations made through interstate wires while ICVA earns essentially all of its revenue, now over $10 million annually, from the consumers being reassured. And the same private apparatus runs a second gate — the AVMA’s ECFVG and its backlogged surgical exam — that keeps qualified veterinarians already living in Wisconsin working as technicians instead of practicing, even as the state faces a documented veterinarian shortage. Wisconsin has no public way to know whether this exam is fair, whether its scoring is accurate, or whether qualified veterinarians are being wrongly kept out of the clinics, shelters, ranches, and food-supply jobs that need them.
ICVA’s own published documents contradict its public statements.
The conduct alleges crimes under both state and federal law.
Open an investigation. Stop the ongoing harm. Now.
Respectfully,
North American Veterinary Ethics Council (NAVEC)
with the undersigned Wisconsin veterinary clinic owners, veterinarians, hospital administrators, shelter leaders, dairy and livestock producers, animal-health professionals, pet owners, and concerned citizens