Attorney General Paxton: A critical shortage of veterinarians is driving up costs and cutting off access to care for pet owners, animal shelters, farmers, and ranchers. The cause is structural: the state has delegated licensure to a private organization operating without public oversight. It Refuses Transparency. It Stands Accused of Misrepresentation, Abuse of Power, and Career-Ending Retaliation. Open an Investigation Now.

An open letter from Texas veterinarians, animal shelter operators and supporters, clinic owners, dairy and livestock producers, pet owners, and concerned citizens.

How we got here:
A single private organization — the International Council for Veterinary Assessment, or ICVA — controls the only licensing examination every Texas veterinarian must pass: the North American Veterinary Licensing Examination, or NAVLE. Texas depends on that exam. Texas candidates pay for it. Texas careers rise or fall on it. Yet the public cannot inspect it, audit its item-level validity, review its scoring, or appeal many of ICVA's most consequential decisions. That arrangement has now produced a public crisis.

The documented allegations:
A broad coalition of exam takers, veterinary educators, and advocacy groups has reported persistent and serious problems with the NAVLE — incoherent questions, content allegedly outside the published blueprint, scoring anomalies, unexplained invalidations, and outcomes inconsistent with candidates' demonstrated merit — in a 1,200-signature petition, a formal legal notice from a national plaintiffs' firm, public advocacy letters, and national veterinary press reporting. These sources did not coordinate. What they reported was strikingly consistent.

Abuse of power: the rules ICVA wrote for itself.

These allegations sit on top of something that is not alleged at all — ICVA's own published policies. Under those policies, ICVA may:

- Cancel or invalidate a passing score at its sole discretion, with no reason given, no recheck, and no appeal.

- Cancel a score or bar a candidate from the exam for violating "the moral norms of the general community" — a standard ICVA never defines and need not prove.

- Restrict candidate speech about the exam beyond proven copyright infringement including general discussion of exam anomalies and punish suspected violations through retroactive score cancellation or future exam bans.

- Demand candidates' personal documents, data, or electronic devices long after the exam, without judicial process or independent oversight — with refusal punishable, at ICVA's sole discretion, by retroactive score invalidation or exclusion from future exams.

The result is a system that can chill criticism and deter candidates from reporting irregularities. And when a decision alters a career, there is no meaningful path to challenge it.
The result is a system that can chill legitimate criticism, deter candidates from reporting irregularities, and leave affected individuals without a meaningful path to challenge decisions that may alter their professional futures.

How ICVA responded:
An apparent admission — the retake reset. In November 2025, ICVA reset its retake policy — every candidate's testing history effectively erased, five new attempts granted — citing "a comprehensive review of candidate feedback and NAVLE data." If that data justified rewriting thousands of testing histories, it is material: it may show problems with administration, scoring, fairness, or candidate outcomes. ICVA has not released the data or the analysis. Texas is entitled to know what ICVA found.

An apparent misrepresentation the "audit" claim:
In December 2025, ICVA's chief executive described the NAVLE as having been "audited," citing California's 2020 review as having "confirmed" that the NAVLE's "development, administration, and scoring fully met all applicable professional guidelines and technical standards." That characterization appears materially misleading. The 2020 California review was not a forensic audit: it examined no exam questions, ran no item-level fairness analysis, validated no scoring outcomes — and it expressly found ICVA out of compliance with California's own conflict-of-interest regulation. Yet ICVA has repeatedly used the language of "audit" in ways that appear designed to reassure the public without disclosing the records needed to test the claim.

The "independent audit" framing:
On December 1, 2025, amid escalating public criticism, ICVA announced an "Independent Audit" of the NAVLE. That announcement did not identify the auditor, commit to a specific scope, disclose a timeline, or state whether the public would receive the complete findings.

On June 4, 2026, ICVA disclosed that its law firm, Dorsey & Whitney LLP, was managing the process, had run the procurement, and had engaged the auditor: ACS Ventures, Inc.

That arrangement may create the appearance of legitimacy. In substance, it is potentially deceptive: running an audit through an organization's own litigation counsel is a well-known tactic for preventing disclosure, because both the scope and any findings would be protected by attorney-client privilege and attorney work product inaccessible to the public and to state boards. ICVA, through counsel, would have full discretion to decide what is released, what is withheld, what is summarized, and what is characterized for public consumption.

ACS is a respected psychometric firm. But the transparency and investigative disclosure it can deliver will be limited by the audit scope it was hired to assess — and by the discretion of ICVA and its law firm over what is ever released.

ICVA has stated that ACS will "consider and apply industry standards and best practices to evaluate fairness and validity throughout the exam cycle." To a reader demanding a forensic audit, that language sounds sweeping. But the same words could describe an audit of "procedures" as easily as a "forensic" audit of the actual data and ICVA has refused to disclose the audit's scope, or even the RFP used to secure the auditor.

That is not transparency. It is the architecture of managed disclosure. Whether it is also deceptive, fraudulent, anticompetitive, or otherwise unlawful is a question for your office to investigate.

Texas law makes that question especially direct. Texas Occupations Code § 801.254(b) requires the Board to "arrange for the written portion of the examination, if any, to be validated by an independent testing professional." Texas requires the NAVLE for veterinary licensure — yet neither Texas nor any other state can claim that the NAVLE has been validated by an independent testing professional, or reasonably assure exam takers that the exam is fair or that the allegations against it are untrue. On that basis, continuing reliance on the exam, pending such validation, would appear to be in violation of Texas law.

The financial scale tells you why this matters:
According to public filings cited in the supporting record, between fiscal years 2020 and 2025 ICVA's revenue nearly doubled — from approximately $5.3 million to approximately $10.15 million — while net assets grew from approximately $10.6 million to approximately $18.3 million. ICVA is a small private organization with no public accountability comparable to the power it exercises, and its revenue comes overwhelmingly from candidate fees: every retake, every failed score, and every cancellation that forces a retake generates another transaction. That does not prove misconduct. But it creates an obvious financial incentive that Texas cannot ignore when the same organization controls exam content, scoring, retake policy, invalidations, candidate discipline, audit framing, and public disclosure.

The conduct described in the supporting record may warrant investigation under:

- The Texas Deceptive Trade Practices–Consumer Protection Act, Tex. Bus. & Com. Code ch. 17.

- The Texas Free Enterprise and Antitrust Act, Tex. Bus. & Com. Code ch. 15.

- Federal wire-fraud principles, to the extent interstate-wire communications were used to obtain candidate fees through representations the underlying records do not support.

- Federal anti-racketeering law, to the extent a pattern of predicate acts, coordinated concealment, or repeated deceptive conduct can be established through compulsory process.

These are not findings. They are questions for law enforcement. They are not questions ICVA can be trusted to answer about itself.

Why the public record looks the way it does:
Almost no candidate can safely sign this letter under their own name. That fact is not evidence that the problem is small. It is evidence that the fear is real. ICVA has reserved the power to demand candidates' personal documents, data, and electronic devices long after the exam. It has reserved the power to cancel scores, bar future testing, and enforce undefined "moral norms" it writes for itself. It has reserved the power to punish speech about the exam beyond proven copyright infringement. For many candidates, speaking publicly is not civic participation. Due to ICVA's own policies it is a professional death sentence. That is itself a reason for Texas to investigate.

We are asking Attorney General Paxton to act on four fronts:

1. Seek immediate injunctive relief: until the NAVLE is independently validated, Texas should not rely on it as a condition of licensure. Texas has handed the gate to a lawful profession to a private organization the State does not supervise — an exam no Texas authority has ever validated or has any way to validate. The Texas Supreme Court has held that handing public power to private parties requires meaningful state oversight (Boll Weevil, 1997), and that occupational requirements the State cannot justify are unconstitutionally oppressive (Patel, 2015). Until Texas can validate the exam through a genuinely independent audit — its findings published — the NAVLE should not gate Texas licensure. This is not a request for new law; it is existing Texas constitutional law, and your office has express authority to seek this relief today (Tex. Bus. & Com. Code § 17.47).

2. Open a broad investigation.

Investigate ICVA's conduct under the Texas Deceptive Trade Practices–Consumer Protection Act and the Texas Free Enterprise and Antitrust Act, and refer the documented record to federal authorities for parallel review under federal wire-fraud and racketeering laws where warranted. We are not claiming ICVA is guilty of these violations. We are asking you to investigate — because only your office can compel the records that would answer the question.

3. Protect Texas candidates in the meantime.

Call on the Texas Board of Veterinary Medical Examiners to use Texas's existing provisional-licensure rules (22 Tex. Admin. Code § 571.11) so qualified candidates who have met every other requirement can practice under supervision while the exam is under investigation.

4. Open a second gate for veterinarians Texas already has.

Use the authority of your office to support a lawful pathway for internationally trained veterinarians already living and working in Texas — many as technicians, assistants, shelter workers, and clinical support staff — to obtain supervised licensure through recognized international veterinary accreditation and competency review.

Texas should not be forced to rely exclusively on AVMA-controlled pathways, including the ECFVG certification process and its backlogged, multi-day surgical examination, when qualified veterinary professionals are already here and Texas communities need care now.

This is not a request to lower standards. It is a request to recognize qualified local talent through a fair, supervised, transparent pathway that serves animals, rural communities, shelters, clinics, producers, and the public.

We are not asking Texas to lower the bar. We are asking Texas to verify the bar.
We are asking Texas to investigate whether a private organization has used control over an essential licensing gateway to mislead candidates, suppress criticism, manipulate public confidence, extract repeated fees, and deny qualified people entry into a profession Texas desperately needs.

ICVA's own published documents appear to contradict its public statements. Its policies appear to grant private disciplinary powers no public licensing body could exercise without due process. Its financial incentives are obvious. Its refusal to disclose the records necessary to verify its claims is unacceptable.

Open an investigation. Compel the records. Protect candidates while the investigation proceeds. Stop the ongoing harm now.

Read the full supporting record, with citations and documentation, at https://navec.org/texas-full-letter.html.