The CMA report last week contained their proposed rule changes for vets around pricing – and overall, I think there are some really good ideas in there, especially around transparency of pricing and ownership.

However, there are also some changes to the way vets are being asked to handle medicines, and some of these are rather more complex than they look… 

What are the proposed changes? 

The most important proposals are that there should be a default expectation that vets will issue prescriptions – and inform clients about that; that there will be a cap on prescription fees at £16; and that common parasiticides should be price-checked on the practice website. 

Remedy 7 – Information measures to increase awareness of online pharmacies and the amount that can be saved by using an online pharmacy rather than purchasing from the FOP 

Essentially, the veterinary practices will be expected to publicise the availability of online purchasing options with a written prescription to their clients. This is not new – for nearly 20 years it’s been a requirement for a vet to offer a written prescription as long as doing so would not prejudice animal welfare (for example, writing a prescription for a life-saving drug needed right now). 

This time it’s going to be a bit more prescriptive – vets must inform clients orally and in writing, on invoices, on their websites, using posters, in their terms and conditions, and even in any messaging when appointments are booked or medicines are discussed.  

It is unusual for the CMA to force a business to provide free advertising for their competitors, but this isn’t really a massive issue. I think part of the problem is that as vets (not businesses) most of us sort of assume that clients know they can get a prescription anyway. After all, we’ve been going on about it long enough, and the online dispensaries have been advertising it hard enough! 

Remedy 8 – Measures to reduce barriers to pet owners purchasing online   

This boils down to providing a written prescription at the time of the consultation, or an emailed one by the end of the day. 

This is going to be a disaster. Prescription fraud is a huge problem, sadly, with people sending the same prescription to multiple dispensaries and getting multiple copies of the medication. The CMA could have addressed this by specifically permitting the current best-practice approach – that the vet practice send the prescription by email to the client’s preferred supplier. Alternatively, they could have set down a condition that the pharmacies should have documented methods to validate electronic prescription, or honour a “Original only” request on a prescription. But instead they have shrugged their shoulders of the whole business and said that prescription fraud doesn’t matter. 

Remedy 9 – Own brand medication 

This is a really good clause. Basically, it means that any practice selling their own-brand medication that isn’t available through an online retailer need to issue prescriptions that permit purchase of a differently branded alternative. This one is a great idea, as otherwise, practices can stock only an own-label version of a common generic, making it impossible to get anywhere else. 

Remedy 10 – Choice of default for repeat prescriptions   

This is an interesting approach – the idea is that clients of a vet practice should be able to choose whether their preference for ongoing medications is to buy them from the practice, or receive a written prescription. If they haven’t made an explicit choice, then the practice must assume that they want a written prescription and supply that.  

Remedy 11: Prescription price cap 

This is the big one: the CMA have decided to put a cap on the cost of a prescription at £16 – and rules meaning that only one prescription can be issued per consultation. It also says that practices must put “policies and procedures” in place regarding the duration of any prescription and the number of repeats. 

The second part of this I’m really happy with – too many practices judging by my inbox seem to play fast and loose with prescription durations, without explaining to the client what they’re doing. 

But a capped cost I’m much more uncomfortable with – at least, a capped cost that low. They claim that most independent practices charge less than this: and that’s not what our pricing data shows. Out of the 1539 prescription prices on our database, 919 are from non-corporate practices, and the mean average is £21.16 (Median £20).  

The reason this is a problem is because of the gloriously named “Waterbed phenomenon”: if prices for prescriptions are capped, then the time the vets spend writing them – which is often significant – will have to be recouped somewhere else. And that means that, across the board, pretty much all practices will almost certainly put their consult prices up. Then, people that are not actually requiring the vet to write the written prescription will be subsidising the rest, increasing the cost of vet care for a subset of clients who do not need medication, need to have it supplied by the practice due to timing, or for other reasons do not wish to use online pharmacies’ services – but the CMA just doesn’t see that. 

Things that weren’t in there… 

There were a number of things that didn’t come up, including regulation on online dispensary transparency, measures to address prescription fraud, or price caps on medications. Above all, they have backed away from any measures that might address the prescribing Cascade, one of the biggest issues around the price of medicine use and supply. 

How viable is all this? 

Well, the CMA certainly think it’s viable, and will almost certainly impose it. But having read the CMA’ Report’s Appendix J (all about veterinary medicines regulations and how they impact supply, two things jump put at me. 

The first is that the CMA seem not to have fully understood the regulations or the current dynamic context 

For example, they claim that all isooxazoline antiparasitics are prescription only (POM-V), ignoring the existence of products such as Frontpro (afoxalaner) and Advantage Chewable (lotilaner). They also display a degree of confusion between POM-VPS (for food producing animals) and NFA-VPS (for non-food animals), and do not seem to recognise the key differences in classification. Likewise, the important legal distinction between a pharmacy and a dispensary is not discussed, despite the critically important differences in regulation involved (especially where generic medications are concerned). They also seem to claim that online dispensary registration with the VMD is optional – in fact, since 2024 it has been mandatory.  

These may seem like minor issues (and in truth thy generally are), but it makes me doubt the conclusions drawn in areas where I don’t have the specialist knowledge to appraise the report’s justifications. 

Secondly, this is a really complex area, which the CMA have acknowledged, with lots of scope of unexpected effects 

The appendix to their report is full of phrases like “We recognise that there are potentially wider policy and clinical concerns…” or saying that “CMA may not be best placed to draw conclusions on the most effective weighting of competition (including consumer cost and choice) factors against the wider public policy issues involved.” To my eye, the translation seems to be “Oops, this is more complicated than we thought, let’s back away from this contentious issue”!  

In particular, after a great deal of sifting evidence – which seems to conclusively demonstrate the anti-competitive impact of the Prescribing Cascade (and how this makes true generic prescribing impossible), the CMA come up with a mealy-mouthed backtracking, saying only that “the public bodies responsible for regulating the prescribing of medicines (Defra, VMD, RCVS) should consider whether animal welfare, public health and environmental protection are appropriately weighted against the need to ensure veterinary services in the UK can deliver competitive prices, innovation and growth in step with technological change and consumer demand.”  

This was one area where the CMA could push through healthy changes to regulations, but they bottled it – apparently because they went in gung ho assuming they knew best and then found themselves in a legal, ethical and even diplomatic (because of  the phytosanitary EU harmonisation issues) minefield that they just weren’t prepared to deal with. 

So where is this going? 

Well, these are provisional steps, and may change – although I doubt it. 

However, despite some really good moves around transparency, when it comes to medicines, I think the losers are going to be pet owners. A lot of vets I’ve spoken to say that they have had enough of being told they’re overcharging while doing lots of quiet, background services without charging for them (e.g. telephone triage and advice, prescription reviews etc), and I suspect that if revenue from medication drops, fees for services will go up; and services which are currently free will start being charged for. 

And when people complain, the vet practices’ response will be – you asked for it. I think it’s really sad. But if we as a society want a true veterinary marketplace, perhaps that’s what we’re going to get.