Selling an emergency or specialty veterinary hospital

This guide is general information about selling an emergency or specialty veterinary hospital, not legal, tax or financing advice. FTC orders, state permit, x-ray and non-compete rules, and SBA lending rules change over time, so confirm how they apply to your sale with your attorney, your CPA and the buyer's lender.

Who buys emergency and specialty veterinary hospitals?

Large veterinary groups. The table shows how four of them describe their hospitals on their own pages; Pathway Vet Alliance's count is from its 2020 announcement and is not a current size. VetFirm Sales is not a buyer and does not buy practices.

The FTC's orders name more buyers: the groups that took the clinics consolidators had to sell. They were National Veterinary Associates, Pathway Partners Vet Management Company and PetVet Care Centers in 2017, MedVet Associates in 2020, and United Veterinary Care and Veritas Veterinary Partners in 2022.

How far corporate ownership reaches in referral medicine is only roughly known. In 2018, JAVMA News reported a Brakke Consulting analyst's estimate that corporations owned about 10% of general companion animal practices and 40% to 50% of referral practices; that 2018 estimate is now out of date. Mandelbaum Barrett, a law firm that advises on veterinary practice sales, said in a 2024 presentation that practices with specialty services or emergency care have higher demand, and that average corporate targets have three or more doctors and gross $1.5 million or more.

The FTC's 2022 complaint on JAB Consumer Partners' Ethos deal alleged that JAB, which the FTC identifies as the parent of NVA and Compassion-First Pet Hospitals, regularly monitors local markets across the U.S. for potential small and large acquisitions of specialty and emergency clinics. That is an allegation in a case settled by consent order, not a finding.

Equine referral hospitals

Equine practice consultant Amy Grice, VMD, MBA, wrote in January 2026 that most large equine referral practices are now owned by global corporations, though some private hospitals still exist. That is her view, with no data behind it. The equine section of the guide to what a practice is worth covers ambulatory and solo equine sales.

A veterinarian or a group of veterinarians

If one veterinarian or several buy your hospital with an SBA 7(a) loan, three rules matter more at hospital size. The largest standard 7(a) loan is $5,000,000, and SBA applies that cap to the buyer and its affiliates together. When the price is $3 million or more, not counting owner-occupied real estate, and the buyer is not already one of your co-owners, the lender must also get an independent quality of earnings report with a cash proof covering the trailing 12 months and the last two fiscal years.

The buyer and your hospital together, affiliates included, must also fit SBA's size standard. For veterinary services that is $10.0 million in average annual receipts, though a buyer can qualify instead under an alternative test of net worth and net income. The $5,000,000 cap is on the loan, not the price, so a higher price needs other money, such as more buyer equity or a seller note. The guide to selling to an associate or another veterinarian covers SBA terms.

What is an emergency or specialty veterinary hospital worth?

No source we could verify publishes a current valuation multiple for emergency or specialty hospitals, so this guide gives none. Mandelbaum Barrett's 2024 deck reports higher demand for them without a separate multiple. Its attorneys wrote in December 2023 that, before corporate buyers pulled back as interest rates rose in 2022, multiples for some specialty or referral practices went higher than those for companion animal practices, again without a figure.

The published ranges, and what moves a practice within them, are in the guide to what a veterinary practice is worth. The valuation estimator applies the same ranges to emergency and specialty hospitals as to other practices and says so.

One appraiser view carries extra weight in a 24-hour or referral hospital. Simmons & Associates' appraisers say a multi-doctor practice whose associates stay after the sale is worth more than a solo practice whose seller leaves at closing, and that buyers pay for income rather than equipment, so extra or very expensive equipment does not raise value. In an emergency or specialty hospital, that puts the weight on the doctors who produce the income, not on the CT or the surgical suite.

Which buyers need FTC notice or approval to buy a specialty or emergency hospital?

Mars, Compassion First and JAB Consumer Partners. FTC consent orders from 2017 to 2022 require each to give the FTC advance notice of certain specialty or emergency clinic purchases for 10 years, and require JAB to get FTC approval for some. JAB's notice term covers its NVA and Ethos businesses. The orders cover specialty and emergency clinics only, not general practices, and bind only the companies named in them.

What prior notice and prior approval mean

Prior notice. Under its 2022 orders, JAB must tell the FTC in writing 30 days before acquiring any specialty or emergency clinic within 25 miles of a JAB clinic anywhere in the U.S., for 10 years, when the deal does not already have to be reported under the Hart-Scott-Rodino Act. The earlier orders require Mars and Compassion First to give 10 years of advance notice of certain specialty or emergency clinic purchases, in Mars' case in geographic areas set in its order.

Prior approval. For 10 years, JAB must get the FTC's approval before buying a specialty or emergency clinic within 25 miles of a JAB clinic in California or Texas under the SAGE order, and, according to the FTC's announcement of the Ethos order, in California, Colorado, the District of Columbia, Maryland and Virginia.

At least one deal has ended after a notice. The FTC reported in 2022 that NVA filed a notice under the 2020 order for a later acquisition and abandoned that acquisition after FTC staff raised competition concerns. The FTC did not name the practice, and it is one case. Either step can add time to a sale to a buyer under an order, by an amount no one can promise in advance.

What to do about it

• Before you share financials, ask each buyer whether an FTC order covers its purchase of your hospital, and whether it owns a specialty or emergency clinic within 25 miles of yours.
• If notice or approval applies, have the letter of intent say when the buyer will file, how long you will wait, and what happens if the FTC raises concerns.
• Ask your attorney to read the current order itself. The FTC's releases summarize the orders, and the orders set their own terms and dates.

This matters most at the letter of intent. Attorneys Peter Tanella and Eileen Funnell of Mandelbaum Barrett wrote in December 2023 that sellers to consolidators typically sign a nonbinding letter of intent whose only potentially binding term is often an exclusivity period, which mainly benefits the buyer; they recommend negotiating a breakup fee. If an FTC step applies, set the exclusivity period and any breakup fee with it in mind.

State health care transaction laws

Oregon, Washington and New York require notice or review of some health care transactions, and California's Health Care Affordability chapter defines the providers it covers. None of the statutes or agency guidance we read mentions veterinary practices, so none of them says whether a veterinary deal is covered.

Washington's comes closest: its provider definition borrows a list of professions that includes those under its veterinary board, but notice turns on groups that represent seven or more providers in contracting with health insurers or third-party administrators. Oregon's and New York's laws also have revenue thresholds. Ask your counsel whether any of them applies to a large hospital or a group sale.

How do you show buyers your 24-hour veterinarian coverage?

Shift by shift. For the last 12 months, list who covered each overnight, weekend and holiday shift, which of those DVMs are employees, and how many shifts you covered yourself. If your own overnight shifts hold the schedule together, plan who takes them before you sign anything.

The closest published yardstick is voluntary. Under the Veterinary Emergency and Critical Care Society's facility certification, a Level II facility must be open to emergency patients 24 hours a day, 7 days a week, 365 days a year and employ at least one full-time internal medicine specialist and one full-time surgery specialist. Level I adds at least one full-time emergency and critical care specialist and two full-time VTS (ECC) technicians, plus a CT scanner and backup power, among other items.

Certification is self-documented, without site visits, and VECCS has voted to end the program: its page says no applications will be accepted after November 1, 2026 and all certifications expire December 31, 2028. A buyer may ask whether your hospital holds it; with the program closing, it is not something to start for a sale.

Relief veterinarians

The FTC has dealt with relief coverage directly. After public comments, it changed its final Mars and VCA order in December 2017 so on-call or relief veterinarians could work at both Mars clinics and the divested clinics; the change applied to that order only. List every relief DVM who covered shifts in the last year, with the number of shifts each covered, and say which have agreed to keep working after a sale.

Open positions

In a 2022 AAHA industry survey, filling a vacant associate veterinarian role took an average of more than 15 months, and a credentialed technician role almost 13. Those are 2022 figures, from near the peak of hiring demand, and may not hold today. Note each open DVM and technician position and how long it has been open.

The veterinarian named on the premises permit

Several of the states we checked tie a hospital's permit to a named veterinarian, which matters if that veterinarian is you. In California the premises registration depends on a named licensee manager, and the Veterinary Medical Board must deny, suspend or revoke it if the manager stops being responsible and no substitute has been named by application. Virginia voids an establishment's registration when its veterinarian-in-charge changes and requires a new application five days before the change. North Carolina requires 20 business days' written notice before a planned change of ownership or supervising veterinarian.

North Carolina also sets a presence rule. At a facility open 160 hours a month or more, which every 24-hour hospital is, the supervising veterinarian must be physically onsite at least 40 hours a month, and the time must be documented. If you are the named veterinarian and plan to step back after closing, agree on your successor before you sign. The guide to who can own a veterinary practice covers permits state by state.

Will your specialists stay after the sale?

Plan for the question early. In its 2017 complaint on Mars' purchase of VCA, the FTC said new clinics were unlikely to arrive in time to offset the deal's harm to pet owners, partly because opening a specialty or emergency clinic requires recruiting specialist veterinarians with considerably greater training than general practice veterinarians. That was an allegation in a case settled by consent order. Board-certified specialists are a small part of the profession, as the AVMA's year-end 2025 counts show.

When the FTC ordered clinics sold, it also tried to keep their doctors in place. The Mars order required reasonable financial incentives for key employees to stay and barred Mars for a year from contracting with any specialty or emergency veterinarian affiliated with a divested clinic; the 2020 order barred Compassion First for a year from hiring them. The FTC's analysis of the 2022 JAB and SAGE order says such incentives may include guaranteed retention bonuses for specialty veterinarians at the clinics being sold.

Those terms applied only to clinics sold under FTC orders. They are not a market norm for an ordinary sale, and the one-year bars are not general non-competes on veterinarians.

What to have ready on each specialist

• Board certification, FTE and years at the hospital
• The employment agreement: term, notice period, how pay is set, and whether it can be assigned to a buyer
• Any non-compete or non-solicitation clause, and which state's law governs it
• Any ownership stake or promised equity
• Which referring practices ask for that specialist by name

Non-competes in specialist contracts may not hold. Maryland voids non-compete and conflict-of-interest clauses in employment contracts with licensed veterinarians and veterinary technicians, though not agreements about taking or using client lists or other proprietary client information. Utah voids veterinarian non-compete agreements entered into on or after May 6, 2026 unless the veterinarian owns at least 5% of the business, and voids non-solicitation agreements with veterinarians from the same date. The FTC's nationwide non-compete rule never took effect and was removed in February 2026, so state law governs these clauses, and the FTC can still act case by case.

Buyers have other ways to keep doctors. AAHA's Trends magazine reported in July 2024 that some consolidators offer equity or buy-in options for associate veterinarians. AmeriVet, a group that buys practices, says closing conditions can include staff committing in writing to stay. Decide with your attorney when to tell each specialist about the sale, since a buyer may make their agreement a condition of closing.

If you practice as a specialist yourself, the same questions apply to you. Tanella and Funnell wrote in 2024 that unless the offer contemplates your immediate retirement, a corporate buyer will most likely require an employment agreement setting how long you stay and how many clinical hours you work, usually with a non-compete. The guide to selling to a corporate buyer covers employment terms and rollover equity.

How do buyers judge a specialty hospital's referral base?

By where the cases come from. A specialty hospital's caseload depends on primary-care veterinarians choosing to send patients, so show which practices refer, how much, and how steady that has been. Build a referral report from your practice-management software before you talk to buyers:

• New referred cases and revenue by referring practice, for each of the last three years
• The share of cases from your top five and top ten referring practices
• Emergency walk-ins and after-hours transfers, counted apart from scheduled specialty referrals
• Which referring practices belong to a group, and which group
• Cases referred to a named specialist, so a buyer can see which work follows which doctor

The last two items matter most in a sale. Referrals from practices owned by a group that also runs specialty or emergency care nearby may move to that group's hospital, and cases referred to a specialist by name may follow that specialist if they leave.

Lenders look at concentration too. When an outside buyer's 7(a)-financed purchase is $3 million or more, the required quality of earnings report must assess revenue quality, including customer concentration. In a referral hospital, the closest equivalent is likely a few referring practices sending most of the cases. Corporate buyers run their own quality-of-earnings analysis and ask for detailed revenue and expense data, according to Tanella and Funnell.

Plan the handover to referring doctors as well: who tells each top referring practice about the sale, when, and who their contact is afterward.

What happens to CT, imaging equipment and equipment leases?

A practice's price includes its working equipment, Simmons' Doyle Watson writes, but on his firm's view above, a CT unit adds value through the cases it brings in, not through what it cost.

Leased and financed equipment needs its own list, because each agreement sets its own terms for a sale. For each CT, digital radiography unit, ultrasound, endoscope, anesthesia machine or lab analyzer under a lease or loan, note:

• The lessor or lender, the payment, the months left and the payoff
• Whether it is a lease or a loan, and who holds title
• Whether assigning it to a buyer needs the lessor's consent
• Service contracts and software licenses tied to it, including your imaging archive

Line up consents early. Even the FTC's Mars order required Mars and VCA to secure all third-party consents, assignments, releases and waivers the divestiture buyers needed to run the clinics they bought.

X-ray and radiation registrations

In the four states we checked, an x-ray registration does not simply pass to a buyer.

Ask your state's radiation control program what a change of ownership requires for each unit, and give the buyer time to register before closing.

Tax on equipment

Gain on depreciated equipment is ordinary income, not capital gain, up to the depreciation allowed or allowable on it; equipment sold for less than its adjusted basis produces none. Applying that to imaging and surgical equipment is our reading, not the IRS's; the amount depends on the price allocated to equipment, generally Class V on Form 8594, so model it with your CPA before you agree to the allocation.

Should you sell the hospital building with the practice?

Decide before you go to market, because buyers split on it. Simmons & Associates says a selling veterinarian's real estate is typically sold with the practice in a private sale, while corporate investors typically do not buy it, though other buyers will. Mandelbaum Barrett's 2024 deck says most corporate buyers do not buy real estate and require a fair-market lease, checked by their own rent appraisal, with the rent deducted from EBITDA.

Keep the two values apart. The building's value is separate from the practice's, and the two are not added into one multiple. If the buyer uses an SBA 7(a) loan, the lender's business valuation leaves out owner-occupied real estate, which gets its own commercial appraisal, and only the real estate portion of a blended loan may run past 10 years, up to 25.

Setting the rent

Simmons' Doyle Watson puts a fair-market return on practice real estate at about 7% to 10% of the property's value, under a triple-net, arm's-length lease in which the tenant pays most repairs and maintenance and all property taxes and insurance. He warns that when the real estate's value approaches or exceeds the practice's revenue, rent begins to eat into earnings. Other Simmons and Mandelbaum Barrett material uses 8% to 11% and 8% to 10%, and a local rent study governs in a real deal.

A higher rent lowers the EBITDA a corporate buyer multiplies, so the rent you charge and the price you get move against each other. If you lease the building to the buyer, have your own attorney review the term, the renewal options, who maintains the generator, HVAC and other systems a 24-hour hospital runs on, and whether the buyer can assign the lease if it later sells the hospital.

Owners who keep the building

Among owners who answered the AVMA's 2024 practice owner survey, 54.9% held the practice in one legal entity and the land and building in another. Keeping the building can be part of the deal: when Heartland Veterinary Partners bought Family Vet Group, a multi-site group, in July 2022, the sellers' family ownership group kept the real estate and became Heartland's real estate partner. If you rent from an outside landlord instead, AmeriVet says a buyer may ask you to work with the landlord to bring the lease up to date before closing.

What should you prepare before selling an emergency or specialty hospital?

Start with what a consolidator asks for. Tanella and Funnell list historical financial statements, cash-flow breakdowns, detailed revenue and expense data, receivables, payables and inventory reports, tax returns, corporate documents, licenses, permits, contracts, insurance policies and employee benefit plans. For an emergency or specialty hospital, add:

• A year of DVM and technician shift schedules, with relief shifts and your own shifts marked
• A specialist roster: certification, FTE, agreement terms, notice periods, non-competes and any promised equity
• A three-year referral report by referring practice
• An equipment list with every lease, loan, payoff, service contract and x-ray registration
• The premises permit and the veterinarian named on it, and the DEA registration for each location that stocks controlled substances
• The real estate entity, any lease to the practice, and an estimate of fair rent
• Which nearby specialty or emergency hospitals belong to groups under FTC orders

On the DEA point: each principal place of business or practice that stocks or dispenses controlled substances generally needs its own registration, and a registration cannot be assigned or transferred to a buyer without DEA's written consent. The veterinary practice due diligence checklist covers DEA, x-ray and medical records in any practice, and the guide to selling a veterinary practice covers the full sequence, from choosing a buyer to closing.

Sources

All sources accessed October 27, 2026.

1. Mars Veterinary Health, Stronger together: Introducing our family of veterinary practices
2. National Veterinary Associates, Home
3. U.S. Federal Trade Commission, FTC Requires Mars to Divest 12 Veterinary Clinics as a Condition of Acquiring Pet Care Company VCA Inc., August 30, 2017
4. U.S. Federal Trade Commission, Agnaten SE, Compassion First and NVA; Analysis of Agreement Containing Consent Orders To Aid Public Comment (85 FR, Feb. 25, 2020), February 25, 2020
5. U.S. Federal Trade Commission, FTC Acts to Protect Pet Owners from Private Equity Firm’s Anticompetitive Acquisition of Veterinary Services Clinics, June 13, 2022
6. U.S. Federal Trade Commission, FTC Takes Second Action Against JAB Consumer Partners to Protect Pet Owners from Private Equity Firm’s Rollup of Veterinary Services Clinics, June 29, 2022
7. Morgan Stanley Investment Management, TSG Consumer Partners Acquires Pathway Vet Alliance from Morgan Stanley Capital Partners, April 3, 2020
8. American Veterinary Medical Association, The corporatization of veterinary medicine (JAVMA News), November 14, 2018
9. Mandelbaum Barrett PC, Peter Tanella, Mandelbaum Barrett PC: presentation slides ('Current Trends in the Market – 2024'), hosted by GeniusVets
10. EquiManagement, Business Briefs: Creating a Succession Plan for Your Equine Practice, January 14, 2026
11. U.S. Small Business Administration, SOP 50 10 8.1, Lender and Development Company Loan Programs with Technical Policy Updates, September 25, 2026
12. U.S. Small Business Administration, Table of Small Business Size Standards Matched to North American Industry Classification System Codes (effective March 17, 2023)
13. Today's Veterinary Business, How to Avoid a Messy Separation (Legal Lingo column), December 1, 2023
14. Simmons & Associates, Unraveling the Mystery of Practice Appraisals, Published March 19, 2024
15. U.S. Federal Trade Commission, JAB Consumer Partners/Ethos Veterinary Health; Analysis of Agreement Containing Consent Orders To Aid Public Comment (87 FR, Aug. 5, 2022), August 5, 2022
16. Oregon State Legislature, Oregon Revised Statutes chapter 415, section 415.500 (2025 edition)
17. Washington State Legislature, Revised Code of Washington chapter 19.390 (Health care entities: notice of material change), sections 19.390.020 and 19.390.030, Definitions last amended 2026 c 222 s 1
18. California Legislative Counsel, California Health and Safety Code section 127500.2 (Health Care Affordability definitions), amended by Stats. 2025, Ch. 641 (AB 1415), effective January 1, 2026
19. New York State Department of Health, Public Health Law Article 45-A, Material Transactions Frequently Asked Questions, revised March 2025
20. Veterinary Emergency and Critical Care Society, Facility Certification, page current as of October 27, 2026
21. U.S. Federal Trade Commission, FTC Alters Final Consent Order in Response to Public Comments, Preserving Competition for Specialty and Emergency Veterinary Services in 10 U.S. Localities, December 19, 2017
22. American Animal Hospital Association, Staff Retention: Stay, Please (Trends magazine), January 2024
23. California Veterinary Medical Board, California Veterinary Medicine Practice Act, 2026 Edition: Bus. & Prof. Code § 4853.6(a)(1), (b)
24. Virginia General Assembly, 18VAC150‑20‑181(B)‑(C), Requirements for veterinarian-in-charge (see also 18VAC150‑20‑180), current as posted at access
25. North Carolina Office of Administrative Hearings, 21 NCAC 66 .0902(h) (Veterinary Facility Permits) and 21 NCAC 66 .0207(b) (minimum facility standards), Rule .0902 effective June 17, 2024, amended effective October 1, 2024
26. American Veterinary Medical Association, Veterinary specialists in the U.S., 2026
27. American Veterinary Medical Association, U.S. veterinarian numbers, 2026
28. U.S. Federal Trade Commission, JAB/SAGE Veterinary; Analysis of Agreement Containing Consent Orders To Aid Public Comment (87 FR, June 27, 2022)
29. Maryland General Assembly, Maryland Code, Labor and Employment section 3‑716, Veterinary provisions added by 2024 Md. Laws Ch. 378 (HB 1388), effective June 1, 2024
30. Utah State Legislature, S.B. 111 Veterinary Post-employment Amendments, Enrolled Copy (2026 General Session)
31. Federal Trade Commission, Noncompete Rule (rule summary page)
32. Federal Trade Commission, Revision of the Negative Option Rule, Withdrawal of the CARS Rule, Removal of the Non-Compete Rule To Conform These Rules to Federal Court Decisions (FR Doc. 2026‑02866), February 12, 2026
33. American Animal Hospital Association, Practice Ownership Exit (and Entry) Strategies (AAHA Trends magazine), July 1, 2024
34. AmeriVet, Everything You Need To Know About Companies That Buy Veterinary Practices, November 20, 2025
35. Today's Veterinary Business, Legal Lingo: Navigating a Corporate Takeover, May 21, 2024
36. Simmons & Associates, How can the “perfect” veterinary practice have little to no value? April 26, 2024
37. Ohio Legislative Service Commission, Ohio Adm.Code 3701:1‑38‑03 Application and renewal of registrations for handlers of radiation-generating equipment, Rule effective January 20, 2022
38. Pennsylvania Code & Bulletin, 25 Pa. Code § 216.2 Registration of radiation-producing machines, last amended October 26, 2018, effective January 24, 2019
39. Texas Department of State Health Services, Regulatory Guide 8.2: Guidelines for Issuing Certificates of Registration Due to a Change in Name and/or Ownership, revised 09/30/2009
40. Minnesota Department of Health, X-ray Registrant Change of Ownership, 4/21/2022
41. Internal Revenue Service, Publication 544 (2025), Sales and Other Dispositions of Assets, 2025 edition
42. Internal Revenue Service, Instructions for Form 8594 (Rev. November 2021), revised 11/2021
43. Simmons & Associates, Four Methods to Sell Your Veterinary Practice, Published June 27, 2024
44. American Veterinary Medical Association, Economic State of the Veterinary Profession 2025 (p. 39), January 2025
45. Gryphon Investors / Heartland Veterinary Partners, Gryphon-Backed Heartland Veterinary Partners Acquires Family Vet Group, July 25, 2022
46. Office of the Federal Register / National Archives, 21 CFR 1301.12 Separate registrations for separate locations, eCFR current as of October 23, 2026
47. Office of the Federal Register / National Archives, 21 CFR 1301.52 Termination of registration; transfer of registration; distribution upon discontinuance of business, eCFR current as of October 23, 2026