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'Under care' - new guidance
Our new guidance on 'under care' and prescribing prescription-only veterinary medicines (POM-Vs) came into effect on 1 September 2023.
As agreed on 7 September by RCVS Council, the implementation of the specific part of the new 'under care' guidance concerning the prescription of anti-parasitic POM-Vs will now come into place on 12 January 2024 in order to help practices comply with the VMRs.
For more information about this extension, and what it means in practice, please visit the news story in News & Views.
In this section, you can find the new guidance itself, plus a variety of resources to help you understand how it should be followed in different practice scenarios, and in relation to different species.
The five key changes are:
- You will no longer need to carry out a physical examination to take an animal under your care. Under the new guidance, an animal is taken under your care when you are given, and accept, responsibility for it. (See FAQ 3)
- When you take an animal under your care, you or another veterinary service provider on your behalf, must be able to provide in-person follow-up care on a 24/7 basis. (See FAQ 5)
- As now, before prescribing POM-Vs, you will have to carry out a clinical assessment. From 1 September, it is up to you to decide whether this clinical assessment needs to include a physical examination, in all but a number of circumstances (see point 4, below).
- You must always perform a physical examination in the following circumstances:
- where a notifiable disease is suspected
- when prescribing controlled drugs (unless there are exceptional circumstances)
- when prescribing antibiotics, antifungals, antiparasitics or antivirals (unless there are exceptional circumstances)*.
*NB The proximity of physical examination to prescribing will be slightly different depending on the species being treated (see FAQ 4 and FAQ 6).
- It is your decision, once you have assessed the situation, whether or not to prescribe medicines remotely. To support you in using your professional judgement, we have set out a list of factors to consider when deciding whether a physical examination is necessary (see paragraph 6 of the new guidance, below).
Our new guidance on 'Prescribing POM-Vs', 'Limited Service Providers', and 'Information and advice-only services' came into effect on 1 September 2023, and is now incorporated into our supporting guidance to the RCVS Code of Professional Conduct.
It is also set out below for reference:
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 to be able, on a 24/7 basis, to physically examine animals under their care, or attend the premises in the case of production animals, equines, farmed aquatic animals and game, should it become necessary.
4.9 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.
4.10 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 must be able, on a 24/7 basis, to physically examine the animal, or visit the premises in the case of production animals, equines, farmed aquatic animals and game. Veterinary surgeons should also be prepared to carry out any necessary investigation in the event that animals taken under their care do not improve, suffer an adverse reaction or deteriorate. Veterinary surgeons should provide this service within an appropriate timeframe depending on the circumstances, which could be immediately.
4.11 Where a veterinary surgeon is not able to provide this service set out in paragraph 4.10 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 Chapter 3: 24-hour emergency first-aid and pain relief, made in advance before veterinary services are offered and confirmed in writing as part of the conditions of service agreed by the client. Veterinary surgeons should provide clients with full details of this arrangement, including relevant telephone numbers, location details, when the service is available and the nature of service provided.
4.12 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).
4.13 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.
4.14 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 4.15 and 4.16)
b. The nature of the medication being prescribed, including any possible risks and side effects (see further guidance below at paragraphs 4.17 and 4.18)
c. Whether the medication is being prescribed under the cascade (see further guidance below at paragraph 4.23)
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 in relation both to animal health and welfare, and the importance of open and honest communication with the veterinary team
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
4.15. 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.
4.16 In respect of paragraph 4.14 (a) above, a physical examination is required where a notifiable disease is suspected or part of a differential diagnosis.
4.17 In respect of paragraph 4.14 (b) above, and given the importance of minimising the development of resistance to antimicrobials and anthelmintics, and minimising the potential negative environmental impact of antimicrobials and antiparasitics:
a. A physical examination is required at the time of prescription in all but exceptional circumstances where a veterinary surgeon prescribes antibiotics, antifungals, antiparasitics or antivirals for an individual animal or group of animals that are not production animals, farmed aquatic animals or game. 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 antibiotics, antifungals, antiparasitics or antivirals 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 prior to prescribing, or recently enough to ensure they have adequate current information and knowledge to prescribe responsibly and effectively, taking into account any available production data and diagnostic laboratory results. In exceptional cases where this is not possible, or in sectors such as large-scale commercial poultry and fish enterprises, 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 4.14, above.
c. Where samples are obtained for the purpose of testing following a physical examination (or, in the case of production animals, farmed aquatic animals and game, following a physical examination which was carried out 'recently enough'), it is acceptable for a veterinary surgeon to prescribe antibiotics, antifungals, antiparasitics and antivirals based on the results of those contemporaneous tests without the need for a further physical examination.
Note: For more information about responsible prescribing to minimise antimicrobial resistance, please see paragraphs 4.30 and 4.31 below).
4.18 In respect of 4.14 (b) above, when prescribing a controlled drug to an animal, veterinary surgeons should in the first instance 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 further prescription for that controlled drug 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 (see RCVS Controlled Drugs Guidance - A to Z for further guidance on controlled drugs).
4.19 Veterinary surgeons must maintain clinical records of animals, herds, flocks or other groups of animals under their care.
Limited Service Providers
3.49 A limited service provider is a practice that offers no more than one service to its clients and includes, but is not limited to, vaccination clinics or neutering clinics. For these purposes, a 'practice' is a Registered Veterinary Practice Premises (RVPP) as entered into the register held by the RCVS.
3.50 Limited service providers should provide, or provide access to, 24-hour emergency cover that is proportionate to the service they offer. This means that veterinary surgeons working for limited service providers should ensure that the 24-hour emergency cover provision covers any adverse reaction or complication that could be related to procedures or examinations carried out, or medicines prescribed or used. Limited service providers do not have to provide this service themselves and may engage another veterinary provider to do so on their behalf. Where another provider is engaged, the arrangement should be in line with paragraphs 3.4 - 3.6, above, made before veterinary services are offered and confirmed in writing as part of the conditions of service agreed by the client.
Information and advice-only services
2.33 Veterinary surgeons regularly give advice as part of their work and in a variety of contexts. Advice can range from very general, for example, writing in a magazine column, to very specific, for example, to an existing client as part of an ongoing course of treatment. Veterinary surgeons may only give advice to the extent appropriate based on the information they have about the animal and should bear in mind the general guidance on veterinary care and in relation to prescribing medicines. Where advice is given remotely and there is no ability to monitor the animal, for example, because it is provided as part of an online-only service, veterinary surgeons should ensure that the client understands the limitations of this service and that animal welfare and/or subsequent veterinary care is not compromised.
2.34 General information taken from standard texts or articles (source acknowledged and subject to copyright law) may be disseminated via the internet, either by way of a distance-learning CPD project for veterinary surgeons, or for the general public who are seeking information about a particular condition, treatment or medication.
In our live webinars earlier this year, we explained the new guidance and tried to answer as many of your questions as time allowed.
We held one webinar on 15 June and repeated it on 17 July, a recording of which you can view below.
Our Advice team and Standards Committee have produced a range of practice-based scenarios to help explain how the new guidance should be followed in various circumstances, and in relation to different species.
The origins of this new guidance date back to 2016 and the Vet Futures project - a joint initiative between the RCVS and British Veterinary Association.
There followed a wide-ranging, three-part review that began in 2019 and, after a two-year delay caused by the pandemic, concluded in early 2023 with Council's approval of the new guidance.
Read more about our review of 'under care' and 24/7 emergency cover.
- RCVS Council approves new guidance on ‘under care’ and 24/7 cover [20 January 2023]
- Under Care Review: Council approves implementation and review for new guidance [20 March 2023]
If you have any questions about our new guidance, please contact our Advice team.
Frequently Asked Questions
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.
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.
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 must be able, on a 24/7 basis, to physically examine the animal, or visit the premises in the case of production animals, equines, farmed aquatic animals and game.
Veterinary surgeons should also be prepared to carry out any necessary investigation in the event that animals taken under their care do not improve, suffer an adverse reaction or deteriorate.
Veterinary surgeons should provide this service within an appropriate timeframe depending on the circumstances, which could be immediately.
The general rule under the new guidance is that whether a physical examination is required prior to prescribing POM-Vs is a matter of judgement for the veterinary surgeon taking into account the factors set out in the guidance.
However, there are some notable exceptions to this rule:
a. When a notifiable disease is suspected.
b. When prescribing antibiotics, antifungals, antiparasitics and antivirals (unless there are exceptional circumstances).*
c. When prescribing controlled drugs (unless there are exceptional circumstances).
*In terms of the proximity of physical examination to prescribing, the rules are slightly different depending on the species being treated [see paragraphs 9(a) and (b) of the guidance].
Under the new guidance, when a veterinary surgeon takes an animal under their care, they must be able, on a 24/7 basis, to physically examine the animal, or visit the premises in the case of production animals, equines, farmed aquatic animals and game.
Veterinary surgeons should also be prepared to carry out any necessary investigation in the event that animals taken under their care do not improve, suffer an adverse reaction or deteriorate. Veterinary surgeons should provide this service within an appropriate timeframe depending on the circumstances, which could be immediately.
Where a veterinary surgeon is not able to provide this service [set out in paragraph 2 of the new guidance] 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. Veterinary surgeons should provide clients with full details of this arrangement, including relevant telephone numbers, location details, when the service is available and the nature of service provided.
The aim of this provision is to ensure that animals always have somewhere to go if needs be, for example, if the issue cannot be dealt with remotely, their condition deteriorates, or they have an adverse reaction to any medicines prescribed remotely.
This requirement was added in response to concerns that allowing remote prescribing might enable online only businesses to prescribe medicines to animals without any ‘back up’.
Apart from the clear animal welfare issue, there was also concern that this would put pressure on physical practices asked to deal with any adverse consequences arising from interventions by remote-only prescribers.
Due to the overarching requirement to provide 24-hour emergency first-aid and pain relief, the new 24/7 in-person care requirement should not place any additional burden on existing organisations providing clinical services.
Instead, it ensures that businesses, which may not operate during normal working hours or have a physical premises, cannot take an animal under their care and prescribe POM-Vs without having appropriate follow-up care in place should it become necessary.
We realise that there are differences in opinion within the profession regarding the inclusion of antiparasitics in this part of the guidance.
There are a range of factors set out in the guidance to be taken into consideration when prescribing POM-Vs, and we understand that the opinion of some is that these can simply be applied to antibiotics and antiparasitics to ensure responsible prescribing.
However, it is our view that these medicines should be treated differently to other POM-Vs because the risk of uncontrolled use is greater, for example, resistance and environmental impact.
As such, the guidance requires a physical examination in order to positively impact prescribing behaviours and change attitudes to these medicines.
Yes, so long as a physical examination is carried out at the time the prescription is made.
Please note that because the new guidance requires that a physical examination is carried out at the time of prescribing antiparasitics, a prescription for the whole period to be covered should be made at the time of the physical examination and include directions on when the instalments should be dispensed, for example, a 12-month prescription to be dispensed at quarterly or monthly intervals.
No, this guidance only relates to the prescription of prescription-only veterinary medicines (POM-Vs).
Although this guidance does not cover POM-VPS, these should of course be prescribed responsibly and in line with the requirements of the Veterinary Medicines Regulations (VMRs).
9. How does prescribing antibiotics, antifungals, antiparastics and antivirals for wildlife fit in with this guidance?
Given the unique challenges of treating wildlife, the Standards Committee has decided that groups of wildlife brought into wildlife centres may be treated as an exception to the general rule contained within paragraph 9(a) of the new guidance, which says a physical examination should be carried out at the time of prescribing.
Instead, the Committee’s view was that they may be treated in a similar way to production animals [see paragraph 9(b) of the new guidance]. The basis for this being that wild animals should be kept at the centre for as short a time as possible with handling kept to a minimum and, once released, cannot be monitored to 'see how they go'.
We are also mindful that depending on the circumstances, releasing animals without treatment might cause additional problems in the species population.
In practice, this means that when prescribing antimicrobials for wildlife in rescue centres the veterinary surgeon does not have to examine the specific animal being prescribed for, but does need to have attended the premises and examined at least one representative animal recently enough to have current information and knowledge.
They also need to have an in-depth knowledge of the premises, the local environment and disease challenges in the area.
10. What is ‘recently enough’ for the purposes of prescribing antibiotics, antifungals, antiparasitics and antivirals to production animals, farmed fish and game?
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.
11. If a remote vet prescribes something for an animal registered at my practice, do they have to let me know?
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.
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 firstname.lastname@example.org
We wish to reassure the profession that for animals on health plans or similar where, for example, 12 months of antiparastics are prescribed to be dispensed quarterly, so long as the initial prescription is compliant with the Veterinary Medicines Regulations 2013 (see below), then practices may continue to supply against those valid prescriptions after 1 September 2023.
When that 12-month prescription comes to an end, under the new guidance a physical examination should be carried out at the time the new prescription is issued.
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.
Prescriptions in clinical records
For prescriptions written 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 name and amount of product prescribed (including pack strength details, for example, 2-10kg)
b. The dosage and administration instructions
c. Any necessary warnings
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
It is acceptable to include the generic name to enable a different brand with the same active ingredient to be supplied, for example in the event of supply issues. However, it is recommended that the person supplying it double-checks this is OK with the vet before it is dispensed.
It is also acceptable to note an alternative that could be supplied in the event the first option is not available but, again, it is recommended that the person supplying it checks with the vet before it is dispensed.
It would not, however, be acceptable to prescribe a long list of possible products to dispense that the person supplying then chooses from depending on factors such as stock levels, cost or convenience, as this would not be the vet making the prescribing decision.
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@example.com.