May 13, 2020
May 13, 2020
Historically, the Veterinary Medicines Regulations (VMR) and the Royal College of Veterinary Surgeons (RCVS) have restricted the prescription and sale of POM-Vs to animals that have had a clinical assessment. But recent temporary relaxations in the rules due to Covid-19 have meant that vets have a greater level of freedom to prescribe POM-V and POM drugs to animals without a hands-on physical examination.
Let’s take a little look at the RCVS guidance on the matter. The RCVS Code of Professional Conduct and Supporting Guidance states:
“4.4 POM-V medicines must be prescribed by a veterinary surgeon, who must first carry out a clinical assessment of the animal under his or her care.”
However, the VMR has never defined clinical assessment, leading the RCVS to interpret this meaning to include an assessment of clinical information, which may or may not need a physical examination:
4.12 The Veterinary Medicines Regulations do not define ’clinical assessment‘, and the RCVS has interpreted this as meaning an assessment of relevant clinical information, which may include an examination of the animal under the veterinary surgeon’s care.
The VMR also hasn’t defined ‘under his care’, leading to further interpretations by the RCVS:
4.9 The Veterinary Medicines Regulations do not define the phrase ‘under his care’ and the RCVS has interpreted it as meaning that:
4.11 A veterinary surgeon cannot usually have an animal under his or her care if there has been no physical examination; consequently a veterinary surgeon should not treat an animal or prescribe POM-V medicines via the Internet alone.
They also interpret ‘recently enough’ to be dependent on the professional judgement of the vet.
“4.10 What amounts to ‘recent enough’ must be a matter for the professional judgement of the veterinary surgeon in the individual case.”
So, pre-Covid-19, POM-Vs could only be prescribed if the vet had conducted a physical examination of the pet recently enough, and had made a clinical assessment of the needs of the animal.
Interestingly, this does not expressly disallow prescriptions to be made over video, assuming the pet has been clinically examined ‘recently enough’ for the vet to feel confident that they have prescribed correctly. For instance, when an owner phones to ask for prescription flea treatment, practices often check whether they’ve been seen ‘recently enough’ and then prescribe; remotely and without any further examination of the animal. In this situation, prescribing the same flea treatment over video call would follow the same guidelines and be allowable.
Due to the rise in telemedicine, the RCVS was to be undertaking a review of ‘under your care’ in order to agree whether remote prescription is ever suitable. This was disturbed by Covid-19 and it is not clear if the RCVS is still on track for a decision to be made in November.
With the outbreak of Covid-19, government guidance advised limiting non-essential contact with others. In order to assist vets in remaining open whilst limiting their contact, the RCVS decided to relax the rules on remote prescription of POM-Vs.
“RCVS Council has decided that there should be a temporary departure from this position and that remote prescribing of POM-V medicines (including medicines prescribed under the cascade and those imported under the Veterinary Medicines Directorate’s Special Import Scheme for veterinary imports) should be permitted where it is appropriate to do so.
However, before doing so, you must be satisfied that:
If you are satisfied regarding the above, you should then consider the following:
You should also ensure that:
In addition, they recommend that:
In cases where POM-V medicines are prescribed remotely, you should ensure that either you are in a position to examine the animal yourself or that it can be examined by another veterinary surgeon if its condition deteriorates to the point where remote support is inadequate. You should also provide the owner with all of the information they need to administer the medicine safely and ensure they have a means to contact you (or a colleague) in the event they have any questions or problems.”
In other words, prescription via remote means without a physical examination can be undertaken at the discretion of the vet if they can justify that it was necessary.
The RCVS has made it clear that the relaxation is temporary, subject to review on an ongoing basis. They have also stated that they will be re-assessing the situation no later than 30th June 2020. Whether this UK-wide experiment of remote prescription will affect their review of ‘under your care’ or not is yet to be seen – it’s likely that both some benefits and some problems will be brought to light with such a large ‘pilot study’!
Be prepared for the rules to change, and check in with the RCVS regularly to see where they currently stand. But for now, cautious prescription under justifiable circumstances is certainly allowed.
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