The RAMP proposal will be published along with other responses and information on the following webpages https://www.gov.uk/government/consultations/vets-market-investigation-r…

RAMP would like to thank the CMA for the Remedies Working Paper sent out May 2025 and for
the wide research into the workings of the CQC and regulatory bodies.
RAMP would like to respond that the CMA's lack of analysis of the musculoskeletal (MSK) section
of the industry is disappointing. We would point out that the competitive forces within the
veterinary surgeon's realm has a serious impact on the MSK sector:
1. Most MSK professionals are themselves small businesses – in many cases, single person
freelance professionals. They are therefore vulnerable to these forces when referral or
delegation decisions are being made by veterinary surgeons.
2. We take it that your reference to physiotherapy at point 3.20 (b) “For example, where the
duration of a service (such as a consultation or physiotherapy session)...” applies to
employees of a veterinary business providing that service. This leaves aside the majority of
regulated MSK professionals (Chiropractors, Osteopaths and Physiotherapists) who work
outside such businesses.
3. RAMP strongly advises that all neuromusculoskeletal services should be provided to pet owner's
animals only by professionals qualified in that service (ie one of the 3 professions mentioned
above) to the industry standards as set by RAMP. These standards are understood by the
veterinary professional associations. DEFRA also supported this development in 2015, when
their RMPR consultation identified a need for regulation in the MSK sector: “MSK therapies
should only be carried out by those persons who are appropriately competent in order to do
so without causing any avoidable pain, distress or suffering to the animal.” On “4/8/16,
DEFRA released a statement saying “Defra welcomes the development of RAMP; an
industry-led solution to the MSK confusion. It meets the requirements of the current law,
meets the findings of the RMPR evidence-gathering exercise and meets the subsequent
outcomes which were sought.” RAMP has never received any challenge over their
development of these standards from the RCVS and so we take it that they are familiar with
these standards.
4. Historically, MSK has commonly been called “physiotherapy” (with a small 'p' to denote the
generic description rather than the profession) since the Exemptions Order 1966 and used to
describe all manual treatments (i.e. Chiropractors, Osteopaths and Physiotherapists – note the
capital 'P'). RAMP suggests that the use of this term “physiotherapy” (small 'p') is confusing,
vague and devalues the profession of Physiotherapy. RAMP now suggests the generic term
“musculoskeletal treatment” – ie “MSK” – to cover all three professions. This means that the
term “Physiotherapy” describes only the service provided by regulated professionals qualified in
that treatment mode.
5. Further, where veterinary businesses advertise the provision of “physiotherapy sessions” (as per
your example at 3.20(b)) they should only be utilising these regulated professionals to ensure
reliable, safe and high-quality services actually support animal health and welfare.
6. Where MSK professionals are employed by any veterinary practices, any complaints about them
should be managed by the MSK regulator (RAMP) rather than the vet's regulator. (RAMP's FTP
processes will be reviewed to update them in light of the current DEFRA review of VSA
reform.)
7. In parallel, where veterinary businesses do not employ suitably qualified and regulated MSK
professionals, they should at least sign-post local freelance MSK professionals to ensure pet
owners can make appropriate choices over treatments for their animals. This satisfies your
recommendations at 3.3 “Increased transparency could support pet owners to make more
informed decisions about which basic services and treatments they wish to purchase.”
Of course, some practices may wish to go further and develop good working relationships with
regulated MSK professionals in the surrounding area so that they can refer in a proper and
timely fashion (with the owner's consent).
8. We agree with your point at 2.38, “the regulatory framework does not help drive
competitive processes and good consumer outcomes (and consequent benefits to
animal welfare) in the way we would expect in a well-functioning market.” RAMP is
currently working with DEFRA to shape the reform of the VSA to empower MSK regulation in
order to match the levels of control over MSK provision that the RCVS has over medical
provision.
9. Your Remedy 25 recommends the establishment of a new Veterinary Ombudsman, which
RAMP previously suggested (Response to the 2024 CMA report: Veterinary Services for
Household Pets in the UK, April 2024, point 5: “One possible area of consideration is the
potential to create an Ombudsman Service for the veterinary industry. Given the widespread
ownership of pets in the UK, increasing complexity of veterinary practice ownership, the power
differential between householders and multinational corporations, the relatively recent intake of
vet nurses to the RCVS, the challenges in the regulation of veterinary MSK practitioners and the
recent complaints about vets' increased prices...”. We maintain that this would benefit pet
owners by creating an independent 'referee' for the industry.
10. In Remedy 28, you recommend the expansion of the role of vet nurses to help to “support
animal welfare, improve job satisfaction and career progression, and lessen the burden
on vets” (6.116). “Our current view is that it may be appropriate to recommend that
government seeks to legislate to expand the role of RVNs. While the exact scope of
any expanded duties is not for the CMA to prescribe, it appears to us that this could
have a positive impact on the veterinary profession, animal welfare, competition and
consumers.”(6.117). RAMP notes your choice of words “lessen the burden on vets” – this
suggests that medical procedures are central to this expansion idea. RAMP wishes to ensure that
the role expansion is not allowed to creep into the MSK domain, because this would introduce
under-qualified personnel – via a disconnected backdoor – into a regulated professional scope of
practice. This would then split the regulatory functions across two regulators (RAMP and the
Vet Nurse Council), creating confusions and duplications, and effectively lower the standards of
MSK treatment within vet practices.
These clarifications will have a positive effect on the supply of MSK professionals resulting in growth
of this sector of the industry, which is currently underutilised, as required by the current Chancellor of
the Exchequer. This means that supply will increase to meet demand and the MSK professions will
thrive, complementing the medical services for best animal welfare and easing the burden on vets.
Dr Vav Simon for the RAMP Council