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FAQs

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01.

Whether attendance at the premises/examination of one representative animal has occurred 'recently enough' will depend on the circumstances in any given case, for example the nature of the condition, the medication being prescribed and whether the health status of the wider group or disease challenges have, or may have, significantly changed since the previous visit to the premises.

In this respect, what is 'recently enough' for the purpose of prescribing antiparasitics is unlikely to be appropriate when prescribing antibiotics, for example.

In any event, the prescribing vet would have to ensure they had enough current information and knowledge to prescribe responsibly and effectively.

02.

Yes. In line with the RCVS’s guidance on mutual clients, if any vet becomes aware that an animal they are treating is registered with another vet, clinically relevant information should be shared.

03.

Alleged breaches of this guidance will be investigated and enforced in the same way as breaches of any part of the guidance and/or Code of Professional Conduct. More information about our investigations process can be found in our concerns section.

If members of the profession have concerns that a colleague is not following this guidance but are not sure how to proceed, they may contact the RCVS advice team to discuss the issue and any next steps.

Depending on the circumstances, the advice team may be able to issue formal advice to the veterinary surgeon in question reminding them of their obligations under this guidance and the Code of Professional Conduct. This conversation will be kept confidential and the professional seeking advice may remain anonymous if they so wish.

Professionals may also seek advice from our confidential reporting line, which allows veterinary professionals, including veterinary surgeons, veterinary nurses and other members of the veterinary team to have informal, confidential, discussions with members of the Professional Conduct Department about potential fitness to practise issues, short of formally raising a concern.

However, if a decision is taken to raise a formal concern about a veterinary surgeon or nurse, the person raising the concern will generally need to identify both themselves and the individual they wish to raise concerns about in order to take it through our investigation process.

Please note: there is a streamlined process for veterinary surgeons and nurses to raise concerns with us.

04.

Veterinary surgeons who provide veterinary services to animals in the UK are considered to be practising in the UK regardless of where there are physically based. This means that they must be an MRCVS on the 'UK-practising' category of the RCVS register, keep up to date with Continuing Professional Development (CPD) and have professional indemnity insurance (PII).

Even where a vet is properly registered, has completed CPD and has PII in place, there are still a number of barriers before POM-Vs could be prescribed from overseas as set out below. 

Under the new guidance, any vet who takes an animal under their care, must be able, on a 24/7 basis, to physically examine it and carry out any necessary investigations. This service should be provided within a reasonable timeframe, which could be immediately.

Clearly, veterinary surgeons based abroad would not be able to fulfil this obligation themselves and so they, or the company they are working for, would have to find a veterinary provider, based in the UK to provide this service.

It is the veterinary surgeon’s responsibility to make any such arrangement (it is not enough that the animal is registered at another practice) and it must be made in advance before veterinary services are offered with the terms confirmed in writing.

If the business is based online and clients are able to contact it from anywhere in the UK, they would have to ensure that the provision of 24/7 follow-up arrangements was available to all clients using their service.

Finally, even if an MRCVS based overseas was able to fulfil their obligations in terms of 24/7 follow-up care, they would not be able to supply any prescribed medicines. Under the Veterinary Medicines Regulations, these may only be supplied from Registered Veterinary Practice Premises, which, due to inspection requirements, can only be registered in the UK.

05.

Yes. This guidance will be reviewed by RCVS Council after it has been in place for 12 months.

We would therefore welcome any information or evidence that will assist with informing this review so that Council has as complete a picture as possible.

Please contact the advice team at [email protected]  

06.

Your legal obligations when prescribing POM-Vs

In line with the VMRs, POM-Vs may only be supplied where there is a valid prescription by a veterinary surgeon who has carried out a clinical assessment and has the animal under their care.

There is no specific form for a prescription: it can be oral, written as a script for the client to take away or written in the notes.

However, whatever form it takes, a prescription needs to include enough information so that the person supplying against it knows what to do, whether they are another veterinary surgeon, a pharmacist, RVN, SQP or lay member of staff.

With this in mind, the VMRs specify the information that written prescriptions must include (see paragraph 6 of Schedule 3) and templates are available from veterinary associations such as BSAVA and BEVA.

Records of oral prescriptions in clinical records

For oral prescriptions noted in the clinical records, much of the required information will already be available, for example, name and address of owner, animal identification, or will be added automatically, for example, veterinary surgeon’s details, authentication of the prescriber).

Where this is the case, there is no need to repeat this information under the heading 'prescription' or add it to the prescriptions tab on the practice management system.

In addition, some information may not be relevant, for example, withdrawal period or cascade use.

However, to be a valid prescription, the veterinary surgeon will need to include details of the medication they are prescribing as follows:

a. the product name

b. the pack size/volume/quantity of the product

c. the dosage instructions

d. any necessary warnings or instructions

e. either a frequency and time period, eg ‘1 bottle a month for the next 3 months’, or a number of repeats, eg ‘can be repeated twice’

f. an end time for the repeats, eg the decision on when you next want to see the animal

g. any other information you consider relevant

In view of this, entries in the notes such as 'OK for endos and ectos' or 'Recommend fleas and wormers for the next 12 months' are not valid prescriptions and supplying POM-V antiparasitics against this kind of entry does not comply with the VMR.

Generics and alternatives

The RCVS and VMD do not recommend noting prescriptions as mg/kg due to possible errors being made when the dose is calculated. However, where the generic active ingredient is prescribed in mg/kg, the prescribing vet will need to authorise this prior to the product being dispensed.

Generally, recording alternative or contingent prescriptions in the notes is not acceptable. However, for situations where listing one alternative might be appropriate, please see joint guidance published by the RCVS and Veterinary Medicines Directorate (VMD).

Further guidance

Further guidance on prescribing and supplying veterinary medicines is provided by the Veterinary Medicines Directorate.

If you have any concerns arising from the above information, please contact our advice team on 020 7202 0789 or [email protected].

Last updated: 9 February 2024

07.

Practice names are a form of advertising and as such, should comply with Chapter 23 of the supporting guidance to the Code of Conduct as well as any relevant UK advertising codes, including the UK Code of Non-broadcast Advertising, Sales Promotion and Direct Marketing (CAP Code).

Practice names that include the titles, ‘vet’, ‘veterinary’, ‘veterinary surgeon’, or ‘veterinary practitioner’ that are to be incorporated at Companies House will first require a letter of non-objection (LONO) from the RCVS. Please see Chapter 23 of the supporting guidance for further information. Failure to present Companies House with a LONO in the above circumstances will result in your application being rejected by Companies House. Please note that LONOs are not required for trading names/unincorporated practice names or practice names that do not include one of the above titles but are to be incorporated at Companies House.

To future proof practice names where there are aspirations to become Practice Standards Scheme (PSS) accredited in the future, the PSS Rules should also be considered. This is because further restrictions might become applicable only at the point of joining the scheme (which could require a name change prior to entering the scheme). Please see FAQ 2 below in relation the use of the titles ‘Hospital’ and ‘Veterinary Hospital’ which further illustrates the importance of considering the future of your practice when choosing a name.

Practice names and all relevant expectations should be considered at the earliest possible opportunity, i.e., at practice inception and before applying to become a registered veterinary practice premises (RVPP), attempting to incorporate at Companies House, and prior to marketing investment.

08.

If you are undertaking a procedure or technique that is likely to be of direct clinical benefit to the individual animal that you are treating, then this is RVP.

For non-food producing animals the following would be considered RVP or CVR (NB this is not an exhaustive list):

  1. Taking a series of biopsies for the purpose of diagnosis, or to monitor the efficacy of veterinary treatment, in order to inform the clinical management of the animal.
  2. Taking blood samples to assist in clinical management, e.g. diagnosis, metabolic profile, public health, legislative reasons, notifiable and other diseases.
  3. Giving veterinary treatment to an experimental animal when treatment is for the animal’s benefit.
  4. In the course of testing the safety and efficacy of an unauthorised vaccine in dogs, taking blood samples at the time of first vaccination, prior to second vaccination, post-vaccination course and at the time of the annual booster in order to test the vaccine’s success (An ATC from the Veterinary Medicines Directorate (VMD) is also required in this situation).
  5. Using clinical waste for research purposes, e.g. Use of excess synovial fluid from a sample collected during a surgical procedure (e.g., during the surgical repair of a ruptured cranial cruciate ligament) to carry out essential clinical investigations to inform on the treatment of the animal’s condition.

For food producing animals the following would be considered RVP or CVR (NB this is a not an exhaustive list):

  1. Taking blood samples from an animal or animals within a defined group e.g. herd or flock, to assist in clinical management, e.g. diagnosis, metabolic profile.
  2. Taking blood samples from an animal or animals within a defined group, e.g. herd or flock, to test the efficacy of veterinary treatment. If the blood samples are taken as part of a clinical trial testing the efficacy of a veterinary medicine, then an ATC from the VMD may be required.

Collection of blood for subsequent transfusion

Taking blood from healthy donors with the informed consent of the owner and with the intention of administering the blood or its products to a recipient animal is routine veterinary practice where there is an immediate or anticipated clinical indication for the transfusion. Such a clinical procedure would be acceptable on the scale of an individual veterinary practice or between other practices in the locality.

For there to be an ‘immediate or anticipated clinical indication’ for the transfusion the recipient must be identified at the time of collection. Where there is no identified recipient, or where the blood is taken from the donor based on an estimate of the demand, the donation is classified as blood banking and the guidance below should be followed.

The collection of blood for the preparation of blood products on a larger scale, including storage and supply of those blood products (i.e., blood banking) for transfusion in animals must be done in accordance with a Non-Food Animal Blood Bank Authorisation (NFABBA) under the VMR, granted by the VMD. Advice on whether authorisation is required can be sought from the VMD by contacting [email protected]

Due to the additional risk of harm to the donor, it would generally not be considered routine veterinary practice for sedation to be used to enable the collection of blood from a donor animal. The exception to this general rule would apply in an emergency, where the donor and recipient animals are both known to the veterinary surgeon, who is therefore able to conduct a comprehensive harm-benefit analysis, including an assessment of whether the harm potentially arising from sedation of the donor animal is outweighed by the benefits. These may include the benefits of sedation for the donor and benefits of transfusion for the recipient.

Note that the collection of blood for the preparation of blood products on a larger commercial scale for general diagnostic or therapeutic use in (animals or humans) or other scientific use or experimental purposes requires licences under the ASPA. Advice on whether work needs to be regulated can be sought from ASRU by contacting [email protected]

09.

Although veterinary practices are not required to close, in order to meet the most recent government requirements they must ensure they carry out their work safely, whilst maintaining biosecurity and social distancing.

This means reducing the number of face-to-face appointments as much as possible, and some practices may also be able to offer certain veterinary services remotely. 

Please be aware that we do not expect veterinary practices to offer business as usual for the time being.

If your practice is unable to offer certain services remotely, or with social distancing measures, your vet may to decide that a procedure should not go ahead unless there is a real animal health and welfare risk. Even then, they will need to consider any additional risks and the availability of personal protective equipment (PPE).

In light of this, please do not attend your practice unannounced. Please ensure that you call ahead so that your vet can make assess whether you need to attend in person or whether treatment can be delayed or dealt with remotely.

Last updated:  April 2021

10.

The Veterinary Medicines Regulations 2013 state that before prescribing POM-Vs, a veterinary surgeon must carry out a clinical assessment and the animal in question must be under their care.

The VMRs do not define ‘clinical assessment’ and ‘under care’, so it falls to the RCVS to do so via this guidance.

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