7. Can I still prescribe several months’ worth of antiparasitics to be dispensed at intervals?

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 4.17 (a), (b) and (c) 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 4.10 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.

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). 

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.

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.

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.