The VCPR and Prescribing through Telemedicine – What does the CVBC Standard Say?

In exceptional circumstances, it may be reasonable to establish a VCPR via telemedicine but please be aware, the onus is on the veterinarian to use their professional judgement to justify such a decision.  This means, if you should receive a complaint about the care you have provided via telemedicine, you will have to justify to a committee of your peers why you felt it was reasonable to provide the service via telemedicine. 

Likewise, it establishes that prescribing via telemedicine where appropriate and justifiable can be done.  The guidelines provide a more in-depth discussion of circumstances so please take a moment to review. 

More on the CVBC Telemedicine Guidelines here!

Does Telemedicine need to be associated with a practice facility?

Short Answer – Yes

Veterinarians providing veterinary services in BC must be registrants of the CVBC and must only provide veterinary services at/through CVBC-accredited practice facilities– the accommodation for telemedicine does not eliminate these requirements.  

The primary focus of the CVBC when developing the telemedicine guidelines was the situation of a veterinarian using telemedicine as an additional tool to meet the needs of the clients and patients of their brick-and-mortar practice facility when in person access was difficult or not possible.   The challenges associated with veterinary and veterinary team member shortages have further driven veterinarians and practices to explore solutions to support their clients and patients. 

But what about telehealth platforms? In situations where veterinary services are being engaged through a telehealth platform and new VCPRs are being established via telemedicine, the intention is that the veterinarian does still have a brick-and-mortar facility through which a patient’s needs can be supported (whether by dispensing medication, performing diagnostics to supplement the telemedicine assessment findings, and coordinating in-person exams and treatments as necessary).

Refresh yourself on the CVBC VCPR Standard here!

Helpful guide on interpreting the VCPR Standard here!

How does a telemedicine prescription get filled?

How a telemedicine-issued prescription will be filled by the client (if circumstances make it impossible or impractical for the prescribing vet to dispense from their own practice facility) is a whole other question.   The privilege of veterinarians to engage in the act of pharmacy (an activity regulated under the Health Professions Act by the College of Pharmacists of BC) is allowed through an exception in the BC Pharmacy Operations and Drug Scheduling Act (PODSA) that allows that a practitioner (physician, dentist, veterinarian) is not deemed to be engaging in the unauthorized practice of pharmacy when they dispense to their patients (or, in the case of veterinarians, to an owner for an animal); the College of Pharmacists of BC’s Standard for Dispensing Practitioners further clarifies that, with regard to veterinarians, this exception is specific to clients for their own patients.    So the pharmacy act doesn’t permit veterinarians to engage in retail pharmacy, or to dispense medications based upon another veterinarian’s prescription.

So how would a client receive their prescribed medications?

Ideally, a client would have their prescription filled by their prescribing vet through their accredited practice facility.  If the client is not “local” to the prescribing vet’s practice location, the veterinarian could consider use of a bonded courier (not standard mail) to deliver the dispensed medication to the client.   If this isn’t possible or practical, the next best solution would be for the client to have it filled by a licensed pharmacist.  However, given the preferred use of veterinary-labeled medications whenever possible, this is not always practical or possible.  The CVBC recognizes that there will be situations where it is in the animal’s best interest for a veterinarian to dispense a medication to a non-client/patient based upon another veterinarian’s prescription, but this should be confined to “extenuating and exceptional circumstances” and should satisfy the list of expectations set out in item (e) on page 3 of the CVBC’s Professional Practice Standard: Veterinarian-Client-Patient Relationship, in the discussion about “Exceptions to the Requirement for a VCPR”.   In following the steps laid out in that part of the standard, the dispensing veterinarian is taking steps to establish a limited/narrow-scope VCPR with the owner and animal, in order to have sufficient understand to make the professional decision to dispense the medication.

Do I have to fill a prescription given to my client (or to a non-client) from a veterinarian not affiliated with my practice facility?

Short answer – No

While a veterinarian can fill a prescription within the expectations set forth above with respect to extenuating and exceptional circumstances, they are not required to.  If contacted by a veterinarian who is providing telemedicine services, or presented by an animal owner with a prescription written by a veterinarian via telemedicine or written by another veterinary practice, it is up to the veterinarian to decide whether they believe the expectations of the VCPR standard are satisfied and whether or not they feel comfortable and are prepared to fill it.     It is important to recognize that your facility is not merely acting as a dispensary for another veterinarian.  The veterinarian at your facility needs to authorize the dispensing (after considering the points in (e) of the VCPR standard), and that action is part of the practice of veterinary medicine.

Telemedicine is a rapidly developing and ever-evolving landscape right now.  The CVBC is actively engaging in efforts to recognize what those developments are and how we can manage them from a regulatory perspective, and we do expect our standards and guidelines to evolve.  If and when they do, veterinarians will be notified by eblast/newsletter and the updated documents will be uploaded to our website.

Stay tuned for Part 2 of our blog post which will discuss Telemedicine – medical records and ensuring continuity of care