Following a wide-ranging, lengthy and comprehensive review, the Council of the Royal College of Veterinary Surgeons (RCVS) yesterday approved new guidance on the interpretation and application of an animal being under the care of a veterinary surgeon, and the provision of 24/7 emergency cover, ensuring that it protects animal health and welfare and complies with legislation.

‘Under Care’

Prescribing POM-Vs

This section provides guidance on what it means to have an animal under your care and what is required when carrying out a clinical assessment before prescribing POM-Vs. This section also includes a requirement for veterinary surgeons who have an animal under their care to have the facility to physically examine the animal should it become necessary.

1. According to the Veterinary Medicines Regulations 2013 (VMRs), to prescribe POM-Vs, a veterinary surgeon must carry out a clinical assessment of the animal and the animal must be under their care.  The terms ‘clinical assessment’ and ‘under…care’ are not defined by the VMRs, however the RCVS has interpreted them in the following way.

2. An animal is under a veterinary surgeon’s care when the veterinary surgeon is given, and accepts, responsibility for the health of an animal (or a herd, flock or group of animals) whether generally, or by undertaking a specific procedure or test, or by prescribing a course of treatment. Responsibility for an animal may be given by the owner, client or keeper, statute or other authority. A veterinary surgeon who has an animal under their care should have a 24/7 facility to physically examine the animal or visit the premises in the case of production animals, farmed aquatic animals and game. Veterinary surgeons should also be prepared to carry out any necessary investigation in the event that the animal does not improve, suffers an adverse reaction or deteriorates. Veterinary surgeons should provide this service within an appropriate timeframe depending on the circumstances, which could be immediately.

3. Where a veterinary surgeon is not able to provide this service set out in paragraph 2 themselves, another veterinary service provider may do so on their behalf. It is the veterinary surgeon’s responsibility to make these arrangements and it is not sufficient for the client to be registered at another practice. This arrangement should be in line with paragraphs 3.4 -3.6 of the supporting guidance, made in advance before veterinary services are offered and confirmed in writing as part of the conditions of service agreed by the client.

4. Where an animal is under the care of more than one veterinary surgeon, those veterinary surgeons should keep each other informed of any relevant clinical information (see Chapter 5: Communication between professional colleagues for further guidance on mutual clients).

5. A clinical assessment is any assessment which provides the veterinary surgeon with enough information to diagnose and prescribe safely and effectively. A clinical assessment may include a physical examination, however this may not be necessary in every case.

6. Whether a physical examination is necessary for the prescription of POM-Vs is a matter for the veterinary surgeon’s judgement depending on the circumstances of each individual case (please note that the Animals (Scientific Procedures) Act 1986 should be followed where it applies). When deciding whether a physical examination is required, the following factors are relevant, however veterinary surgeons should note this list is not exhaustive: 

a. The health condition(s), or potential health condition(s), being treated and any associated risks (see further guidance below at paragraph 5 and 6)

b. The nature of the medication being prescribed, including any possible risks and side effects (see further guidance below at paragraphs 7 and 8)

c.Whether the medication is being prescribed under the cascade (for further guidance on this, see paragraph 4.16 of Chapter 4: Veterinary medicines)

d. When the animal was last physically examined by a veterinary surgeon, or premises physically inspected in the case of production animals, farmed aquatic animals or game

e. Whether there is access to the animal’s previous clinical history or, in the case of production animals, farmed aquatic animals and game, knowledge of the health status at the premises

f. The understanding and knowledge of the owner/keeper

g. Whether the individual animal, herd, flock or group of animals is/are known to the veterinary surgeon and/or whether there is an existing relationship with the client or animal owner/keeper

h. The practicality of a physical examination for individual animals

i. The health status of the herd, flock or group of animals

j. The overall state of the animal’s health

k. The impact of any prescription made without physical exam on the ability to gather subsequent diagnostic information

7. The more complex or unusual the health needs of the animal, or where a differential diagnosis includes serious conditions not yet ruled out, the more likely a physical examination will be necessary.

8. In respect of paragraph 4(a) above, a physical examination is required where a notifiable disease is suspected or part of a differential diagnosis.

9. In respect of paragraph 4(b) above, and given the importance of minimising the development of antimicrobial resistance (please note that in this part of the guidance, ‘antimicrobials’ includes antibiotics, antivirals, antifungals and antiparasitics in line with the definition given by the World Health Organisation):

a. A physical examination is required in all but exceptional circumstances where a veterinary surgeon prescribes antimicrobials for an individual animal or group of animals that are not agricultural animals.  Veterinary surgeons should be prepared to justify their decision in cases where antimicrobials are prescribed without a physical examination and record this justification in the clinical notes.

b. When prescribing antimicrobials for production animals, farmed aquatic animals and game, veterinary surgeons should ensure they have an in-depth knowledge of the premises, including its production systems, the environment, disease challenges and the general health status of the herd, flock or group.  Veterinary surgeons should have attended and inspected the premises and physically examined at least one representative animal immediately prior to prescribing, or where this is not possible, recently enough to ensure they have adequate information and knowledge to prescribe responsibly. In exceptional cases where this is not possible and antimicrobials are prescribed without conducting a physical examination, veterinary surgeons should be prepared to justify their decision and to record this justification in the clinical notes. For the factors relevant to whether a physical examination is required, please see paragraph 4 above.

Note: For more information about responsible prescribing to minimise antimicrobial resistance, please see Chapter 4: Medicines, paragraphs 4.23 and 4.24.

10. In respect of 4(b) above, when prescribing controlled drugs to an animal in the first instance, veterinary surgeons should carry out a physical examination in all but exceptional circumstances and be prepared to justify their decision where no physical examination has taken place. This justification should be recorded in the clinical notes. It is acceptable to issue a repeat prescription for controlled drugs without a physical examination, however veterinary surgeons should carry out a further clinical assessment to ensure they have enough information to do so safely and effectively.

11. Veterinary surgeons must maintain clinical records of animals, herds, flocks or other groups of animals under their care.