Frequently Asked Questions Regarding Veterinarian-Client-Patient Relationship (VCPR)
(California Code of Regulations (CCR), Title 16, Sections 2032.1, 2032.15, and 2032.25)
No; for a second veterinarian to prescribe treatment of a condition, the condition would have to be diagnosed under the original VCPR. If no condition is diagnosed, a new VCPR would have to be established by the second veterinarian to treat the new condition. (CCR, tit. 16, §§ 2032.1, subs. (b)(2), (3), 2032.15, subs. (a)(3), (4).)
However, if the original veterinarian prescribed medications at the time of the wellness exam, then the second veterinarian (or any veterinarian at the same premises) can continue to refill those prescriptions up to a year without a new exam or VCPR. (CCR, tit. 16, §§ 2032.1, subs. (c), 2023.25, subs. (b)(2).)
Yes, Doctor B can treat the animal patient for the condition diagnosed by Doctor A, and no new exam is required to change the treatment plan for that condition. (CCR, tit. 16, § 2032.15.)
However, if Doctor B diagnosis a second (new) condition, treatment of the new condition would require Doctor B to establish a new VCPR. (CCR, tit. 16, §§ 2032.1, subs. (a), (b)(2), (3), 2032.15, subs. (a)(4).)
Yes, Doctor B can prescribe a new medication to treat the same condition diagnosed by Doctor A. To do so, Doctor B must consult the animal patient’s medical record or Doctor A (primary veterinarian), communicate the change in treatment to the client, and document the new prescription in the animal patient’s medical records. (CCR, tit. 16, §§ 2032.15, subs. (a), (b), 2032.3, subs. (a)(12).)
4. Doctor A does relief work at “XYZ Emergency Hospital” and establishes a VCPR with the animal patient at that location; Doctor A then sees this same animal patient at Doctor A’s original home hospital of “ABC Hospital”. Can Doctor A prescribe from “ABC Hospital” for said animal patient without establishing another VCPR?
Yes, Doctor A can issue a prescription while working at “ABC Hospital” to treat the animal patient without establishing a new VCPR, as long as the treatment is for the same condition that Doctor A previously diagnosed. (CCR, tit. 16, § 2032.1, subs. (b)(2).) A VCPR is established by the veterinarian and client for treatment of the animal patient; accordingly, the VCPR follows the veterinarian, not the veterinary premises.
Note: Doctor A should ensure that the animal patient’s medical records at “ABC Hospital” includes records of the original examination and diagnosis performed at “XYZ Emergency Hospital”, as well as the prescription issued at “ABC Hospital”. (Business and Professions Code (BPC), § 4855; CCR, tit. 16, § 2032.3, subs. (a).) “XYZ Emergency Hospital” can share originals or copies of the animal patient’s medical records with “ABC Hospital”. (BPC § 4857, subd. (a)(5).)
If Doctor B also works at “ABC Hospital” and has not established a VCPR with said animal patient, but needs to refill a prescription in the absence of Doctor A, as long as the complete animal patient records, including records of Doctor A’s examination and diagnosis performed at “XYZ Emergency Hospital”, are located at “ABC Hospital” and Doctor B has reviewed those records, Doctor B can refill a prescription without a new VCPR. (CCR, tit. 16, § 2032.25, subs. (b)(2).)
Yes; a VCPR is required only if the veterinarian is administering, prescribing, dispensing or furnishing a drug, medicine, appliance, or treatment to the animal patient (except for wild or unowned animals). Part of establishing the VCPR is obtaining sufficient knowledge of the animal(s), which includes through laboratory testing, to initiate at least a general or preliminary diagnosis of the medical condition. (CCR, tit. 16, § 2032.1, subs. (a), (b)(2).).
If the client requests treatment for the animal patient after the laboratory test results are returned, a VCPR, which includes a physical exam, must be established. (CCR, tit. 16, § 2032.1, subs. (a), (b).)
Generally, a vaccination is a treatment administered for the prevention of disease in an animal and requires a VCPR (CCR, tit. 16, § 2032.1, subs. (a)).
However, there are statutory and regulatory exemptions from this general requirement, as follows.Animal with Unknown Owner
If the animal patient is a wild animal or the owner is unknown, a vaccination can be administered without first establishing a VCPR (CCR, tit. 16, § 2032.1, subs. (a)).Shelter Setting
As of January 1, 2022, shelter staff can administer preventative or prophylactic nonprescription vaccinations to animals deposited with or impounded by a shelter without a veterinarian first establishing a VCPR (BPC § 4827, subd. (a)(5)(A)). To do so, shelter staff must follow written California-licensed veterinarian protocols and receive proper training, as specified, in the administration of the nonprescription preventative or prophylactic vaccinations.Small Animal Vaccination Clinic
A veterinarian onsite at a small animal vaccination clinic and veterinary staff supervised by the veterinarian can administer vaccinations, such as: FVRCP (Feline Viral Rhinotracheitis, Feline Calicivirus, and Feline Panleukopenia), Feline Leukemia, DHLPP (Distemper, Hepatitis, Leptrospirosis, Parvovirus, Parainfluenza), Canine Coronavirus, or Bordetella, without first establishing a VCPR (CCR, tit. 16, § 2030.3). However, administration of a vaccination that is a dangerous drug (defined under BPC, § 4022), which would include rabies vaccination, requires a VCPR to be established prior to administering that vaccination (CCR, tit. 16, § 2030.3, subs. (l)).
7. A corporation owns two veterinary premises and stores all electronic medical records on one shared electronic system. Doctor A establishes a VCPR with a client at Premises A and prescribes medication for the animal patient. A month later, the client goes to Premises B to refill the prescription from Doctor A. Can Doctor B refill the prescription without performing an examination, since Doctor B has access to the animal patient’s electronic medical records?
In the absence of Doctor A, there are two exemptions from the VCPR requirement for Doctor B to prescribe, administer, or dispense medication: (1) On an emergency basis to maintain the health of the patient until the client and patient could return to Doctor A; or (2) Doctor B works at the same veterinary premises as Doctor A, and, among other things, in Doctor B’s professional judgment, failure to refill the prescription might interrupt the animal patient’s ongoing care and might have an adverse effect on the animal patient’s well-being. (See CCR, tit. 16, § 2032.25, subs. (b)(2) for full list of requirements.).
In the above scenario, if neither exemption applies to the situation, Doctor B cannot refill the prescription without establishing a VCPR.