Maximizing your veterinary team capacity while staying within the CVBC Bylaws.

The pandemic, together with the veterinarian and Registered Veterinary Technologist (RVT) shortages have put a huge strain on the profession.   Many practice facilities are trying to find ways to utilize their RVT’s skills and expertise to their fullest extent.   However, it’s important to ensure delegation and supervision is always done in compliance with the Veterinarians Act and the CVBC’s bylaws (Part 4 – Ethics and Standards).

Primary considerations for how to involve RVTs should focus on potential for harm as a result of adverse reactions, unforeseen complications and/or human error, and the ability of the veterinarian to promptly intervene and respond when needed.  These considerations should always be the foundation for understanding the intention of the rules framed in the bylaws when you are considering delegation and supervision of staff.  Consideration of delegation under indirect supervision to RVTs working in a mobile practice setting, rather than in the controlled environment of a fixed, central facility location, requires particular scrutiny for risk of adverse reactions and unforeseen complications.

A summary of key requirements from the CVBC’s regulations (excerpts from the Act and bylaws are linked here for your convenience) include:

1. The Veterinarians Act establishes:
   • the definition of veterinary medicine (section 1, Definitions) and also
   • the practice of veterinary medicine as a regulated activity, only to be performed by registrants of the CVBC, except within a series of excepted scenarios, one of which is the treatment of an animal by an employee of a registrant under the supervision of a registrant (s. 46, Prohibitions regarding practice of veterinary medicine), and
2. The following expectations and requirement for practice are established through bylaws and Professional Practice Standards:

a. The Veterinarian-Client Patient Relationship

i. is defined within the CVBC Bylaws (Part 4 – Ethics and Standards, s. 199 Definitions).

ii. the ethical obligations of that relationship are established in Part 4, Division 4.2 – Code of Ethics, s. 204 Duties to Patients and Clients; and the requirements and obligations are clarified in the Professional Practice Standard: Veterinarian-Client-Patient Relationship

b. Delegation and Supervision

The foundation for delegation of treatments is the existence of a valid VCPR and an assessment, diagnosis and treatment plan by the veterinarian based upon their current knowledge of the patient.  A veterinarian’s decision to delegate part or all of a treatment or procedure to a staff person includes responsibilities of the veterinarian to delegate to someone they have deemed to be competent, to provide task-appropriate supervision (as framed in the bylaws) and acceptance that the veterinarian retains full responsibility for the outcome of the procedure or treatment.  Sections 259-266 of the bylaws (Part 4) establish the framework for delegating treatments and procedures to staff, as well as the minimum-required level of supervision for treatments and procedures of similar complexity, invasiveness and/or risk to the patient. 

c. Informed Consent

There must be proper informed consent from from the client (or an agent of the client) before veterinary services can be provided – the scope of information covered within that consent is elaborated upon in s. 211 of the bylaws (Part 4).

The bylaws The bylaws also specify that the informed consent discussion is between the veterinarian and a client – it is one part of practice that cannot be delegated to staff.

d. Unauthorized Practice

Any individual who is not a registrant and who is in breach of any part of sections 46-47 of the Act is engaging in the unauthorized practice of veterinary medicine. While a veterinarian is responsible for delegating appropriately, under necessary levels of supervision and for the outcomes of those delegated activities, if non-registrants are engaging in those aspects of veterinary medicine which cannot be delegated (diagnosis and treatment decisions), the CVBC may need to consider whether the activities have expanded beyond inappropriate delegation by the veterinarian and into the staff member engaging in the unauthorized practice of veterinary medicine.  A registrant’s responsibility for preventing and reporting unauthorized practice are established in sections 225 and 226 of the bylaws (Part 4).

e. Medical Record Keeping

Veterinarians should remember that the bylaws (s. 245) require that a registrant must create and maintain medical records, and that the author of an entry in the medical record would be the person who provided the service and could include any person authorized by the registrant to provide the service, or could be the registrant who supervised the provision of a service.   The Professional Practice Standards (PPS) for medical record keeping provide more detail on what should be included in a complete medical record:

• PPS: Medical Record Keeping
• PPS: Companion Animal Medical Records
• PPS: Equine Medical Records
• PPS: Production Herd/Clock Medical Records
• Guide to the PPS: Medical Records

With careful planning and attention to the foundation laid out above, it is possible to establish processes within your practice facility that increase involvement of your RVTs in daily appointments and procedures, while still ensuring that the veterinarian’s responsibilities under the Veterinarians Act and CVBC bylaws are met.