To provide relief during the coronavirus (COVID-19) pandemic, the U.S. Food and Drug Administration (FDA) announced on March 24, 2020, that it will not enforce certain veterinarian-client patient relationship (VCPR) restrictions in order to allow veterinarians to use telemedicine to provide services during the coronavirus pandemic.
FDA stated it will temporarily suspend enforcement of the animal examination and premises visit VCPR requirements that are relevant to FDA regulations governing Extralabel Drug Use in Animals (21 CFR part 530) and Veterinary Feed Directive Drugs (21 CFR 558.6). These restrictions require veterinarians to be readily available in the case of an adverse reaction to or failure of the regimen, which means veterinarians must physically examine animal patients and/or make medically appropriate and timely visits to the location where the animal patients are kept. Veterinarians previously could not serve animal patients completely virtually because veterinarians could not meet VCPR requirements solely through telemedicine.
With its change in enforcement of this VCPR restriction, FDA is allowing veterinarians to assess animal health needs completely remotely, to help limit human-to-human interaction and prevent the spread of COVID-19. The temporary suspension of enforcement of this specific VCPR restriction will allow veterinarians, without physically examining the patient, to prescribe drugs in an extralabel manner or authorize the use of Veterinary Feed Directive drugs, which are drugs that are used in animal feed and may be used only under the professional supervision of a licensed veterinarian.
Veterinarians can make use of the FDA’s temporary suspension of enforcement of this VCPR restriction and inform existing clients of the opportunity to have a veterinarian provide veterinary medical services to their animals without leaving their homes. The FDA’s decision to temporarily allow veterinary services to be conducted completely through telemedicine allows veterinarians to reach clients who are not able to visit in-person due to “stay-at-home orders” or other COVID-19 restrictions. Although FDA will temporarily not enforce certain federal VCPR restrictions, veterinarians should still consider individual state restrictions that could require an in-person visit. Veterinarians should also monitor FDA guidance on this topic, as the agency stated it would reassess this guidance periodically and provide revision or withdrawal of its guidance as necessary.