8. Are POM-VPS covered by this guidance?

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.

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.

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]  

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