November 2024

By Dr. Natalie Young, PharmD, BCSCP, FACVP, FSVHP, Director of Clinical Pharmacy Services at Vets Pets

In this VETgirl online veterinary continuing education blog, Dr. Natalie Young, PharmD, BCSCP, FACVP, FSVHP, Director of Clinical Pharmacy Services at Vets Pets, discusses the boundaries of a veterinary client-patient relationship when a patient requires a prescription refill but the primary veterinarian is unavailable. Read on to gain further understanding when meeting a pets needs when perhaps, you are not the originally prescribing veterinarian.

VCPR Boundaries: Addressing Prescriptions When the Primary DVM Is Away

Consider this common scenario: A 5-year-old Labrador retriever named Bark Twain has been under the care of Dr. Pawsworthy for chronic hypothyroidism over the past two years, with the condition well-controlled on levothyroxine. Recently, Dr. Pawsworthy took an extended leave of absence due to personal matters, leaving the rest of the veterinary team to manage his patients. Now, Bark Twain’s owner has contacted the clinic requesting a refill of the levothyroxine prescription, as the current supply is running low. Can another veterinarian within the same practice write a prescription for this animal without seeing the patient? This would be more convenient and cost-effective for the client, sparing them a potentially unnecessary trip when the patient is stable, and the primary veterinarian is temporarily unavailable.

Image by danielle828 from Pixabay

Veterinarians face more stringent prescribing standards than physicians, particularly regarding the establishment of a valid veterinarian-client-patient relationship (VCPR). All states, except Alaska, Connecticut, Michigan, Oklahoma, and the District of Columbia, require a VCPR before a veterinarian can prescribe or dispense medications. Even when not mandated by state law, a VCPR is federally required under 21 CFR 530.10 for extra-label drug use, 21 CFR 558.6 (a)(2) for Veterinary Feed Directive drugs, and 9 CFR 113.113 for autologous biologics.

Under 21 CFR 530.3, a valid VCPR requires that a veterinarian assumes responsibility for making medical decisions regarding the animal’s health, with the client agreeing to follow the veterinarian’s guidance. The veterinarian must also have sufficient knowledge of the animal to make a general diagnosis and be available for follow-up care, especially in cases of adverse reactions or failed treatments. This relationship can only be established if the veterinarian has recently examined the animal or conducted timely visits to the premises where it is kept.1

However, no federal statutes specifically address whether an associate veterinarian within the same practice can authorize prescription refills when the primary veterinarian is unavailable. State-specific regulations regarding VCPR can vary widely, complicating the issue. Most states restrict the VCPR to the individual veterinarian who established it, while others, like Arizona, Illinois, Indiana, Massachusetts, Minnesota, New York, Pennsylvania, and Virginia, extend it to any veterinarian within the same practice.2 In contrast, states like Alaska, Connecticut, Delaware, the District of Columbia, and Michigan do not clearly define the scope of the VCPR.2

While established rules must be followed, they often give rise to ethical and practical considerations. Continuity of care is critical for patient well-being, and veterinarians within the same practice share a responsibility to ensure this, especially when the primary veterinarian is unavailable. In cases where a patient is stable on chronic medication, is a thorough review of medical records sufficient to ensure continuity of care, prevent medication lapses, and minimize costs for clients? Can informed decisions be made based solely on the primary veterinarian’s treatment plan?

Image by Mirko Sajkov from Pixabay

One side of this debate emphasizes that while medical records are essential for continuity of care, they may not capture the animal’s current condition accurately. Records offer a snapshot of past interactions but may overlook recent changes in symptoms, behavior, or physical condition. Subjectivity in documentation can also affect clarity, as different veterinarians may emphasize different details, potentially omitting critical information. Additionally, records may lack nuances like the animal’s demeanor, client feedback, or subtle clinical signs that are best observed during in-person evaluations. Given how rapidly an animal’s condition can change, a direct assessment may be necessary before approving a new sequence of prescription refills.

Could a virtual visit be appropriate in these situations? Is the primary veterinarian’s VCPR sufficient to support telemedicine consults in this context? These questions introduce a new layer of debate about the evolving role of telemedicine in veterinary practice – an issue that extends beyond the scope of this article. However, it is worth noting that the AVMA recognizes telemedicine as a viable option for ongoing care once an in-person VCPR has been established, particularly for chronic conditions or minor concerns, offering both convenience and accessibility.3

So, how should veterinarians proceed based on the original scenario with Bark Twain?

In states where the VCPR is limited to the individual veterinarian who established it, maintaining compliance while ensuring continuity of care involves best practices such as clarifying VCPR limitations with clients, maintaining consistent communication, comprehensive record-keeping, developing a continuity plan for emergencies, adapting scheduling to accommodate follow-ups, and coordinating prescription management.

In states that allow any veterinarian within the same practice to provide care once a VCPR has been established, similar practices apply to ensure quality and compliance. These include thorough medical record reviews, open communication among veterinarians, consistent documentation, and clear client communication. By adhering to these strategies, veterinarians can strike a balance between regulatory compliance and patient-centric care, ensuring that even in challenging circumstances, the health and well-being of their patients remain the top priority.

References

  1. S. Food and Drug Administration. Code of Federal Regulations Title 21, Part 530.3: Definitions. FDA. Accessed October 21, 2024.
  2. Otto Veterinary. Veterinarian Client-Patient Relationship (VCPR) by State. Accessed October 21, 2024.
  3. American Veterinary Medical Association. VCPR: Why It Needs to Be Established in Person. AVMA. Published September 21, 2023. Accessed October 21, 2024.

Resource:

  1. S. Food and Drug Administration. Veterinarian-Client-Patient Relationships: Prescribing/Dispensing Animal Drugs and Telemedicine. FDA. Accessed October 21, 2024.

 

 

Only VETgirl members can leave comments. Sign In or Join VETgirl now!