Attorney General Kaul: 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 Wisconsin 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 licensing-examination gateway Wisconsin veterinary candidates must clear to enter the profession. Wisconsin’s own licensure materials instruct new graduate applicants not to apply for a Wisconsin veterinary license until they have passed both the NAVLE and the Wisconsin state exam, and state that both exams are administered through ICVA. Wisconsin’s materials also state that ICVA provides passing score reports to the Wisconsin Veterinary Examining Board when candidates apply through Wisconsin.

Wisconsin candidates pay ICVA. Wisconsin careers rise or fall on ICVA-administered results. Yet the public cannot inspect the exam, audit item-level validity, review scoring records, or obtain independent public review of ICVA’s most consequential decisions.

Wisconsin has placed an essential licensing gateway in the hands of a private organization whose internal records remain largely beyond public scrutiny. That arrangement has now produced a public crisis.

What the broader coalition has reported:
A broad coalition of exam takers, veterinary educators, and candidate advocacy groups has reported persistent and serious problems with the NAVLE: incoherent questions, content allegedly falling outside the published blueprint, scoring anomalies, unexplained invalidations, and outcomes inconsistent with candidates’ demonstrated merit.

These concerns are compounded by ICVA policies that appear to give the organization extraordinary power over candidates, with little transparency, independent review, or meaningful appeal. Those policies allow ICVA to:

* Cancel or invalidate a passing score at its sole discretion, without providing a reason, a recheck, or an appeal.

* Cancel a candidate’s score or bar them from the exam for violating “the moral norms of the general community,” without defining that standard or requiring clear proof.

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

* Investigate suspected violations by requiring candidates to produce personal documents, data, or electronic devices long after the exam is over, without judicial process or independent oversight. Refusal to comply may result, at ICVA’s sole discretion, in retroactive score invalidation or exclusion from future exams.

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.

This pattern has been raised in a 1,200-signature petition, a formal legal notice from a national plaintiffs’ firm, public letters from candidate advocacy groups, and reporting by the national veterinary press. These sources did not speak with one voice or from one institution, yet the concerns they reported were strikingly consistent.

How ICVA reacted:
ICVA’s response has been marked by public statements that appear incomplete, misleading, or inconsistent with the underlying record.

The apparent admission:
In November 2025, ICVA reset the NAVLE retake policy. Beginning with the March 2026 testing window, all candidates were granted five new opportunities to take the NAVLE, regardless of prior testing history. ICVA also stated that attempts before December 1, 2025 would not count toward the new five-attempt limit, and that the change was based on “a comprehensive review of candidate feedback and NAVLE data.”

If that data justified rewriting thousands of testing histories, then it shows something. It may reveal problems with prior administration, scoring, access, fairness, validity, candidate outcomes, or retake policy. ICVA has not released the underlying data or analysis supporting the reset.

Wisconsin candidates paid for the exam. Wisconsin licensing depends on the exam. Wisconsin is entitled to know what ICVA found.

The apparent deception:
In December 2025, ICVA’s chief executive claimed the NAVLE had 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 of the NAVLE. It did not examine exam questions. It did not conduct an item-level fairness analysis. It did not independently validate scoring outcomes. And it expressly found ICVA out of compliance with California’s own conflict-of-interest regulation.

A procedural review is not a forensic audit. A limited state review is not proof that the exam is fair, valid, or free from the defects candidates have reported. 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 audit process, had issued the request for proposals, and had selected ACS Ventures, Inc. to conduct the audit. ICVA also stated that ACS would evaluate fairness and validity throughout the exam cycle and that the audit was expected to be completed in the first quarter of 2027.

That arrangement may create the appearance of legitimacy. In substance, it raises serious questions. If the audit is managed through ICVA’s litigation law firm, then the auditor’s work may be treated as attorney-client privileged or attorney work product from the moment it is created. ICVA, through counsel, may then decide what is released, what is withheld, what is summarized, and what is characterized for public consumption.

ICVA says 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. ICVA has committed to nothing of the kind. The RFP defining what ACS was actually hired to examine has not been disclosed. When asked, ICVA responded by email that the RFP is “private.”

For a procurement document defining what ICVA itself has publicly called an independent audit of a licensing examination used by Wisconsin, “private” is not a legal position. It is a choice.

A public statement using words a reader will perceive as meaning a forensic audit while the document defining the audit is withheld by choice, by the same organization that controls the statement, the engagement, the scope, the release of findings, and the historical use of the word “audit” itself is the architecture of fraud.

We are not asking your office to make that determination. It is our duty to point it out. It is yours to investigate.

The financial scale tells you why this matters:
Between fiscal 2020 and 2025, ICVA’s revenue nearly doubled — from approximately $5.3 million to approximately $10.15 million — and net assets grew from approximately $10.6 million to approximately $18.3 million, according to the public filings cited in the supporting record. ICVA’s own website identifies it as a 501(c)(3) not-for-profit corporation and publishes annual reports and Form 990 materials.

ICVA is a small private organization. It accepts no public accountability comparable to the power it exercises. Its revenue comes overwhelmingly from candidate fees. Every retake generates more revenue. Every failed score creates the possibility of another paid attempt. Every score cancellation that forces a retake creates another transaction.

That does not prove misconduct. But it creates an obvious financial incentive Wisconsin cannot ignore when the same organization controls exam content, scoring, retake policy, invalidations, candidate discipline, audit framing, and public disclosure.

ICVA’s documented conduct described in the supporting record warrants investigation under:

• Consumer fraud under Wis. Stat. § 100.18, Wisconsin’s fraudulent-representations statute. Wisconsin’s Bureau of Consumer Protection describes § 100.18 as broadly prohibiting advertising or sales claims that are “untrue, deceptive or misleading.”

• Antitrust abuse under Wis. Stat. ch. 133, Wisconsin’s trusts-and-monopolies law. The Wisconsin Legislature states that Chapter 133 is intended to safeguard the public against monopolies and foster competition by prohibiting unfair and discriminatory practices that destroy or hamper competition.

• Wire fraud under federal law, to the extent interstate-wire communications were used to obtain fees through representations the underlying records do not support.

• A pattern of racketeering under 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 matters for your office to investigate. They are not matters for ICVA to investigate.

Why the public record is what it is:

Almost no candidate will sign this letter under their own name. ICVA has reserved the power to demand candidates’ personal devices, documents, and data long after the exam and to end any career under a moral standard ICVA writes itself. These ICVA policies create an environment is which cost for any candidate to speak out can be career ending. That is itself a reason to investigate.

We are asking Attorney General Kaul to act on three fronts:

1. Seek immediate injunctive relief: until the NAVLE is independently validated, Wisconsin should not rely on it as a condition of licensure. Wisconsin has handed the gate to a lawful profession to a private organization the State does not supervise — an exam no Wisconsin authority has ever validated or has any way to validate. And Wisconsin law speaks to this directly. Wis. Stat. § 89.065 commands that veterinary licensing examinations “shall be objective and reliable,” and it permits the examining board to require a national examination only “if the examination meets basic standards of objectivity.” No Wisconsin authority has ever independently verified that the NAVLE meets the condition Wisconsin’s own statute imposes — and none can, because ICVA withholds the records verification would require. The Wisconsin Supreme Court has held for nearly a century that delegated power must be tied to real standards and procedural safeguards (Wisconsin Inspection Bureau v. Whitman, 1928, reaffirmed in Becker v. Dane County, 2022), and it has struck down laws that hand lawmaking power away wholesale (Gibson Auto Co. v. Finnegan, 1935). Until Wisconsin can validate the exam through a genuinely independent audit — its findings published — the NAVLE should not gate Wisconsin licensure. This is not a request for new law; it is Wisconsin’s own statute and settled Wisconsin doctrine, and your office has express authority to seek this relief today (Wis. Stat. § 100.18(11)(d)).

2. Open a broad investigation: Investigate ICVA’s conduct under Wis. Stat. § 100.18, Wisconsin’s fraudulent-representations statute, and under Wis. Stat. ch. 133, Wisconsin’s trusts-and-monopolies law, 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 Wisconsin candidates in the meantime: Call on the Wisconsin Veterinary Examining Board to use the temporary-permit authority Wisconsin law already provides — Wis. Stat. § 89.06(1) allows candidates who qualify for examination to practice in the employment and under the supervision of a licensed veterinarian — so qualified candidates who have met every other requirement can practice under supervision while the exam is under investigation. Qualified veterinarians should not be shut out of a profession in documented shortage while Wisconsin investigates whether the private licensing gatekeeper has acted lawfully.

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

Wisconsin has already accepted the principle. Its statute recognizes two credentialing pathways for internationally trained graduates the AVMA’s ECFVG program and the AAVSB’s PAVE program (Wis. Stat. § 89.06(1)) and it already allows ECFVG candidates to practice under a veterinarian’s supervision during their required clinical year (Wis. Stat. § 89.05(2)(h)). What remains is to make the second gate real: Wisconsin should not be left dependent in practice on the AVMA-controlled ECFVG certification process and its backlogged, multi-day surgical examination, when qualified veterinary professionals are already here and Wisconsin’s dairy farms, livestock producers, shelters, and rural 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 Wisconsin to lower the bar. We are asking Wisconsin to verify the bar. We are asking Wisconsin 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 Wisconsin urgently 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.

Read the full letter to Attorney General Kaul, with citations and supporting documentation, at navec.org/wisconsin.