Can a registrant from one accredited facility “fill a prescription” for a registrant from another facility?

This is a common question, and one that creates a great deal of confusion in practice.    The path to the answer is laid out in detail in this blog, but for those who prefer the quick response:

Summary: Vets can prescribe and dispense to their own patients (or the facility patients that have a group VCPR with the other vets in the practice), but they are not allowed to dispense to patients of another facility if only presented a prescription.  We are not authorized to engage in “retail pharmacy”, for an animal owner’s convenience or for preferred prices.

However, in urgent and exceptional circumstances when other alternatives aren’t available, it is understood and accepted by the CVBC that it may be in the animal’s best interest for a vet to dispense prescriptions issued by other veterinarians from outside of their practice facility and this is accomplished by creating a narrow, defined VCPR for the purpose of dispensing in these situations (ie. they are now dispensing to their patient, as they have created a VCPR for that purpose). This should not be a blind “filling of a prescription” – the dispensing veterinarian bears responsibility for the veterinary service that is the dispensing activity.  It should be treated as a “stop-gap” measure to meet the animal’s needs until the owner can acquire medication directly from their prescribing veterinarian.  This should not be done routinely or as a matter of convenience.

And it’s important to understand that the above “exceptional” dispensing activity does not apply to controlled drug prescriptions.  Those should only be dispensed by a veterinarian to their own clients, for their own patients, and on the basis of their own prescription. Otherwise, they should be filled by a pharmacist.  If requested to fill a controlled drug prescription for another facility, the registrant should decline, or examine the patient and establish a full VCPR, then decide whether or not to prescribe and dispense the controlled drug for their patient.

Now the long explanation:

It can be a tough one to sort through, with so many overlapping regulatory bodies, Acts and Bylaws playing into it. 

Definitions are important here and using the correct terms.  From the BC Pharmacists Act:

“practitioner” means a person authorized under the law of any province to practise medicine, dentistry, podiatry or veterinary medicine;

“prescription” means a direction from a practitioner that a specified amount of a specified drug be dispensed;

“dispense” includes the preparation and release of a drug prescribed in a prescription and the taking of steps to ensure the pharmaceutical and therapeutic suitability of a drug for its intended use;

“pharmacy” means a place where drugs may be dispensed, stored or sold to the public;

Veterinarians are considered practitioners under federal and provincial legislation.  We may prescribe to our patients, and we are granted an exception within pharmacy regulations to dispense these drugs as well.  Under the Veterinarians Act and CVBC Bylaws and Standards, this is practicing veterinary medicine and must be done through an accredited facility.

The Pharmacists Act and The Pharmacy Operations and Drug Scheduling Act (PODSA) are the regulations that dictate what and to whom we, as practitioners within the granted exceptions, are allowed to dispense.

Under the PODSA, you will find this section:

26  Nothing in this Act, the drug schedules, the regulations or the bylaws prevents

(a) a practitioner from directly dispensing a drug to the practitioner’s patient or to the owner, or an agent of the owner, of an animal for which the drug has been prescribed, or…

The underlined portion would appear to clear the way to dispensing to an owner for a prescription provided by another practitioner.  However, the College of Pharmacists of British Columbia has published the Standards for Dispensing Practitioners  which, among other things, clarify that practitioners (of one facility) are allowed to dispense to only to their patients/clients.  They are not permitted to act as a dispensing pharmacy for other practitioners’ prescriptions.   

This all boils down to: Veterinarians, as practitioners, prescribe a drug to our patients, and then either a pharmacist, or we ourselves, can dispense the drug to our patient/client.  We are not granted an exception to dispense to another practitioner’s patient. 

But then we get into ethics and the fact many of our veterinary drugs are not available at human pharmacies, and animals may suffer if they don’t receive the medication.  And the real-world common-sense knowledge that people go on holidays and forget their pet’s meds, or something is backordered and the facility down the road has some and your client is about to run out.   Ethical concerns and common sense understandably may cause a veterinarian to feel the need to step outside the Dispensing Standards.

And that is where the Exception in the CVBC’s Professional Practice Standard:  Veterinarian- Client-Patient Relationship comes into play.  If extenuating and exceptional circumstances as outlined in the VCPR Standard exist, a vet who is asked to dispense a drug for a patient that is not theirs can take steps to meet the expectations set out in Exception (e) of the Standard that will enable them to establish a limited VCPR within which to provide the veterinary service of dispensing the medication:

“Exceptions to the Requirement for a VCPR

Exceptions to the requirement that a legitimate VCPR must be established before a veterinarian can provide veterinary services (including prescribing, dispensing, or administering drugs) may exist in some circumstances. These include where a veterinarian:

(e) Administers or dispenses a drug pursuant to a prescription (other than for a controlled substance): 

• that was issued by another Canadian registrant, 

• where it is not reasonably possible for the client to obtain the drug from the prescribing member or from a human pharmacy; 

• where there are exceptional and extenuating circumstances and it is in the best interest of the patient to dispense without delay; 

• where the veterinarian has confirmed the registration status and facility affiliation of the prescribing veterinarian; 

• where the veterinarian has made reasonable efforts to discuss the matter with the prescribing veterinarian; 

• where a sufficient assessment of the animal’s circumstances is carried out; 

• where the quantity of the drug dispensed is no more than would reasonably enable the client to return to the prescribing member for future prescriptions; and

• where the veterinarian makes a written record of the transaction

These exceptions to the requirement for a VCPR in no way preclude the veterinarian from taking whatever steps he or she may deem necessary to confirm the appropriateness and safety of dispensing the prescribed medication to the animal in question, including but not limited to the performance of a physical exam and review of the medical records”.