Reduced disease activity and logistical pressures have prompted federal and Wisconsin state officials to ease avian influenza testing requirements for dairy cattle — but at least one leading animal health expert warns that the rollbacks may reflect bureaucratic strain as much as genuine progress against the virus.
The U.S. Department of Agriculture has removed the mandatory pre-movement testing requirement for lactating dairy cows traveling between states that hold “unaffected” status under the National Milk Testing Strategy (NMTS), its federal H5N1 surveillance program. Wisconsin is among 41 states now classified as unaffected, meaning cattle can move in or out of the state without prior avian flu testing. Separately, Wisconsin’s Department of Agriculture, Trade and Consumer Protection (DATCP) has rescinded a 2024 state order requiring lactating cows to be tested before attending fairs and exhibitions. The state has also scaled back farm-level testing from monthly to bimonthly intervals.
Wisconsin Officials Cite Lower Risk, Reduced Burden on Producers
Wisconsin State Veterinarian Dr. Darlene Konkle said the changes were appropriate given the dramatically reduced prevalence of H5N1 in dairy herds compared to the outbreak’s early months. H5N1 in dairy cattle was first confirmed in the United States in March 2024, triggering sweeping testing mandates and significant disruption to interstate cattle movement. Wisconsin has been among the least-affected dairy states, with only one confirmed farm infection.
“It removes some financial burden from both USDA and producers for moving their cattle in what’s now a lower risk situation than we were in, say, a year ago,” Konkle said. “We’ve got lots of surveillance numbers and good amounts of testing and not a lot of additional cases over the past months.”
Konkle noted that state veterinarians across the country — including herself — had formally requested that USDA reconsider the interstate movement testing requirement. She also said Wisconsin’s continued monthly testing through the spring was driven by the seasonal increase in wild bird migration, which historically elevates avian flu activity. With that risk window narrowing, officials felt a bimonthly schedule was justified.
Diagnostic Lab Director Flags Deeper Concerns About Federal Capacity
Keith Poulsen, director of the Wisconsin Veterinary Diagnostic Laboratory — which conducts all avian influenza testing in the state — acknowledged the dairy industry’s progress but raised pointed concerns about the future of the broader surveillance infrastructure.
“They’re hedging everything on the success of the National Milk Testing Strategy and the continued use,” Poulsen said. “The problem is that we don’t really know what the National Milk Testing Strategy looks like three months from now, six months from now, or a year from now.”
His concern centers on the Trump administration’s sweeping workforce reductions at USDA. More than 24,000 USDA employees have left (or been forced out of) the agency since January 2025, according to federal data — cuts that Poulsen says are already straining the logistics of running and funding surveillance programs.
“We just don’t have enough people to move even just dollars from column A to column B to support some of these programs,” he said. “Wisconsin has the best surveillance program in the country or the world, but it’s expensive.”
Poulsen suggested that some of the current testing reductions may have less to do with a genuine assessment of risk and more to do with a federal agency operating with significantly fewer people to administer the programs.
Lawsuit Over Trump Administration ‘Anti-DEI’ Grant Conditions Threatens USDA Cooperative Grant Funding for States
A separate legal conflict could further destabilize Wisconsin’s surveillance capacity. State Attorney General Josh Kaul, along with counterparts in 20 other states, has filed suit challenging new conditions attached to USDA grants and cooperative agreements. The contested provisions require recipient states to comply with federal policies on immigration, gender identity, and diversity — conditions the states argue are unlawful.
Poulsen warned that Wisconsin’s participation in the lawsuit could prevent DATCP from signing new cooperative agreements with USDA, potentially halting the collection of samples and the funding of testing for avian flu and other diseases.
Konkle acknowledged the uncertainty but said she does not expect a complete funding cutoff. “I think for industry to continue moving, and for animal health to remain at a high level within the U.S., that partnership needs to continue,” she said.
The erosion of surveillance infrastructure carries significant implications. Early detection of new variants or renewed spread depends on consistent, well-funded monitoring at the farm level. If the NMTS falters due to staffing shortfalls or funding disputes, gaps in the nation’s animal disease early-warning system could widen at precisely the wrong moment.
Sources and further reading:
Federal, state officials relax testing for avian flu on dairy farms – Wisconsin Public Radio
National Milk Testing Strategy (NMTS) – USDA APHIS
Recent H5N1 bird flu variants show increased ability to infect dairy cattle – Phys.org