Veterinarians are responsible for ensuring the safe use of prescription drugs for animals. Federal law requires that prescription animal drugs can only be prescribed or dispensed by a licensed veterinarian, not by veterinary technicians or other staff. This is because these prescription animal drugs may have harmful effects if used incorrectly or without proper guidance. FDA described the expected practices at vet offices in a blog post last week.
Prescription animal drugs are regulated by the Federal Food, Drug, and Cosmetic Act (FD&C Act), which says that only licensed veterinarians can prescribe these drugs. Just like human prescription drugs, animal drugs can also be toxic or have specific instructions for use that require a trained professional to administer them safely. Veterinarians can give these drugs directly to the animal’s owner with instructions on how to use them or they can administer the drugs in their clinic or on-site. This ensures that the drugs are used properly, with directions on the correct dosage, how often to give the drug, and any special instructions, like whether the drug should be given with food or on an empty stomach.
Veterinarians have the authority to allow other trained staff, such as veterinary technicians, to help with giving out or administering the drugs. However, the veterinarian must still be involved and oversee the process. The involvement of the veterinarian is important because they are responsible for making sure the drugs are given safely and correctly. The law ensures that no one except the veterinarian or their trained staff can handle prescription animal drugs without proper supervision.
In some cases, veterinarians may prescribe a drug to be used in a way that’s different from what is written on the drug’s label. This is called “extralabel use.” Extralabel use may happen when a veterinarian decides to use a drug in a different way, such as giving a different dose, treating a different condition than what it was approved for, or even using a drug meant for humans on an animal. This is similar to the off-label use of human prescription drugs. However, this can only be done if the veterinarian has a special relationship with both the animal and the owner, which is called a Veterinarian-Client-Patient Relationship (VCPR). This relationship means the vet knows the animal’s medical history and has personally examined it. Without this relationship, it is not legal for a vet to prescribe drugs in an extralabel manner.
The VCPR is a key part of veterinary care. It means the vet has seen the animal and is familiar with its health and care. This relationship is necessary before a veterinarian can prescribe prescription drugs or Veterinary Feed Directives (VFD), which are used to give animals medication in their food. While telemedicine, such as phone calls or video chats, can be helpful in maintaining this relationship, it cannot be used to establish the relationship in the first place. The veterinarian must physically examine the animal or visit the place where the animal is kept to create the VCPR.
Once a VCPR is established, telemedicine can be a valuable tool for follow-up care. For example, the veterinarian may use photos, videos, or virtual consultations to check on the animal’s progress after treatment. However, the veterinarian must still be available for in-person follow-up if needed, such as in cases where the treatment isn’t working or the animal has an adverse reaction to the medication.
Veterinarians play a vital role in making sure that prescription animal drugs are used safely. They are responsible for prescribing and supervising the use of these drugs, ensuring that only trained professionals handle them. Through a close relationship with the animal and its owner, veterinarians can make informed decisions about treatments, including the use of drugs in ways not listed on the label, as long as they meet FDA requirements.
