#AccesstoCare
#EducationandTraining
#LawsandPublicPolicy
#Medicine,SurgeryandSterilization
#PeopleManagement(includingVolunteerIntegration)
#RemoteCustomerService*

------------------------------
Cindi Delany, DVM, KPA-CTP, FFCP
Director of Online Learning
Maddie's Million Pet Challenge
UC Davis Koret Shelter Medicine Program
------------------------------

Thank you Dr. Delany for the great news on telemedicine. I have been waiting for this and can't wait to attend the webinar. As a trainer working with private clients and rescues, I hope telemedicine will change the veterinary practice by providing better access to care. I witness many guardians who could not provide medical support for their pets or worst having to relinquish their pets to the shelters due to lack of access. There is also the issue of affordability, I hope this new approach will also lighten the financial responsibilities for many of the pet caregivers. I am excited to learn more about the telemedicine. 

#AccesstoCare
#EducationandTraining
#LawsandPublicPolicy
#Medicine,SurgeryandSterilization
#PeopleManagement(includingVolunteerIntegration)
#RemoteCustomerService*

------------------------------
Cindi Delany, DVM, KPA-CTP, FFCP
Director of Online Learning
Maddie's Million Pet Challenge
UC Davis Koret Shelter Medicine Program
------------------------------

#AccesstoCare
#EducationandTraining
#LawsandPublicPolicy
#Medicine,SurgeryandSterilization
#PeopleManagement(includingVolunteerIntegration)
#RemoteCustomerService*

------------------------------
Cindi Delany, DVM, KPA-CTP, FFCP
Director of Online Learning
Maddie's Million Pet Challenge
UC Davis Koret Shelter Medicine Program
------------------------------

Posting the webinars Q&A for attendees or those who weren't able to attend.

QUESTION: 

"Will this webcast be available for video replay on demand?"

ANSWER:

YES, please rewatch the webinar here - for more information and clarification on most of these topics - http://tinyurl.com/TMVXwatch

TOPIC:  Vaccines/Allowed Care for Shelter Impounded Animals

QUESTIONS:

"Can assistants do all of these tasks that are listed without a vet even seeing the pet, then?"

"What if you do not have an RVT or vet on staff but contract with an outside vet, can vaccines/meds be given to shelter animals?"

"Can you vaccinate upon intake an animal with ID before making contact with the owner?"

"So a stray coming in with a chip is owned?"

ANSWER:

Routine intake and other care (in the interest of animal/public health and safety) not restricted to a DVM or RVT for animals in a shelter (outside of the public vaccine clinic realm) can be provided by a Veterinary Assistant (VA) following California DVM created protocols under direct or indirect supervision for shelter animals.  

This applies both to animals with indications of ownership (who are considered owned during the stray or other legal holding period) as well as animals with no signs of ownership (who are considered "unowned" during the stray or other legal holding period unless or until an owner claims ownership of them).

Animals arriving at the shelter with a known owner or with indications of ownership (ID tag, other identifier, microchip, etc.) are considered owned during the stray or other legal holding period.

Care provided to owner animals at a vaccine clinic must follow the revised Vaccine Clinic guidelines covered in this webinar.  Please rewatch the webinar here - for specifics of what this covers - http://tinyurl.com/TMVXwatch

For more information on many of the concepts reviewed in the Telemedicine/Vaccine Clinic Legislative Updates Webinar - please review these previous webinars in our Shelter PALs series:

1. Legal Meets Best Practices

2. Decoding Compliance:  What You Need to Know About DEA, Controlled Drugs and Premises Permits in Your Shelter

3. Animal Intake Requirements and Holding Periods

4. Community Cat Programs

5. Veterinary Care in Shelters:  Who Can Legally Do What?

All of these webinars and more are available in our "Shelter PALs" package on Maddie's University - CLICK HERE to access.

TOPIC:   Vaccines Given to Public Owner Animals at a Vaccine Clinic

QUESTION:  "For owned pets (and for a charge), does the RVT thing stand to do services without a vet doing the exam, including rabies?"

ANSWER:  Yes, for owned animals receiving vaccinations and parasite control at a vaccine clinic for a charge, the new Vaccine Clinic legislation permits an RVT to establish the VCPR with the animal/client and provide the vaccinations/parasite control this legislation permits without a DVM exam occuring.

TOPIC:  Exception for Owned Animals - Free Services at Owner's Request

QUESTIONS:  

"If a person off the street walks into the shelter and asks for a DHPP vaccine, I can vaccinate it without an RVT or Vet present as long as I am doing it free of charge?"

"Can core vaccines given to the public at no charge with no vet or RVT on site."

"Is the statement about not charging for services just in California or beyond? What is the legal reference for that not constituting practicing medicine?"

"What about indigenous communities - is there a way to help them without a vet or RVT present?"

"If you hold a FREE vaccine clinic at your shelter where you hold your premise permit, would the DVM need to be present?"

"Can you provide more information about how services provided for free are not subject to a VCPR? This is different from what I learned in vet school (in California). What if a shelter is offering services to the public for free to prevent surrenders, but the provider is being paid for those services by the shelter- is that considered "free" or is it only if the DVM, RVT, etc does not accept any compensation?"

ANSWER:  In California, per the California Business and Professions Code - BPC Section 4827 - Services provided to an owner at their request free of charge do fall under the allowance for owners and their agents to provide medical care as a "bona fide owner of one's own animals."  This should apply to vaccines - core or other if provided at the owner's request at no charge.  This does not mean that free medical care can be provided to an impounded owned animal without first establishing a VCPR with the owner for non-emergency and non-population health (i.e. standard intake care) medical care.

In the last question above about services provided to the owner for free where a provider is compensated by the shelter but not by the animal owner, the above exception for services provided to an owner at no charge applies.  The relevant consideration is not if the person doing the service is getting paid, the only question is if the OWNER of the animal is getting the services for free.

CITATION:

California Code, Business and Professions Code - BPC § 4827

Current as of January 01, 2023 | Updated by FindLaw Staff

(a) Nothing in this chapter prohibits any person from:

(1) Practicing veterinary medicine as a bona fide owner of one's own animals. This exemption applies to the following:

(A) The owner's bona fide employees.

(B) Any person assisting the owner, provided that the practice is performed gratuitously.

https://codes.findlaw.com/ca/business-and-professions-code/bpc-sect-4827/

TOPIC:  Telemedicine VCPR Requirements

QUESTION:  In this first example (community cat with abscess) could the shelter team provide care without telemedicine? Since no VCPR is needed, why is a telemedicine consult needed- is that just bc of the nature of the issue (abscess) requires individual recommendations?

ANSWER:  If a California DVM has created a protocol for dealing with abscesses that protocol could be followed to begin initial care of the cat without using telemedicine.  In the absence of a clear CA DVM created protocol or where staff would like DVM guidance the cat could either be seen by a DVM if one was available in–person or telemedicine could be used to provide that guidance.  The main take-home of the scenario is that the cat is unowned if a "Community Cat" with no known owner or indications of ownership and so no VCPR (in-person or via telemedicine with an owner) is required to provide the needed care.

TOPIC:  VCPR - When Does it Apply

QUESTIONS:

"How does VCPR affect a vets ability to treat a shelter animal that is there as part of a criminal case? An animal confiscated after biting a person, where perhaps the owner doesn't provide consent to provide treatment but the animal is in our care/has to be in our care and needs treatment? Or may need to be sedated to remove a collar/harness/etc. so it can be safely housed?" - see below - intake and emergency care do not require VCPR, other care for owned animals does require it.

"If an animal is in the shelter during it's legal holding period/quarantine/dangerous dog hold etc, the owner is known to the shelter, do the shelter need to establish a VCPR?"- see below.

"Once animals are adopted many come back for meds for coughing. Usually the animal is brought to the hospital, examined by the vet and sent with meds. There is no direct communication between the vet and the owner. Does this mean that there is no vcpr?  Is it possible for the rvt to FaceTime or text with videos with owners for these post adoption animals for kennel cough?  It would save the owner from bringing the animal in and could just pick up meds when the vet is offsite" - yes, see below for VCPR options for owned animals (which includes recently adopted animals if ownership has been transferred).  A VCPR is required in this scenario and can be done in person or via telemedicine.

ANSWERS:

A VCPR (knowledge of the animal and communication with the owner) is required for owned animals requiring non-emergency and non-population health benefiting care.  Owned animals may be provided with typical shelter intake care (vaccinations, parasite control, etc.) as well as with emergency care.  See our prior webinars on intake and on who can do what in the shelters available at the link shown in the top of this post.

Non-emergency care for owned animals requires a VCPR.  A VCPR can now be established in person - animal, owner, DVM (or RVT but only for public vaccine clinic administration of vaccines and preventatives) or using telemedicine with the new AB 1399 legislation.

SF SPCA Shelter PALs has created a sample consent to care contract to use with owners of animals under the shelter's care to allow non-emergency, non-intake care when it is needed if contact can be made with an owner proactively even before such care is needed.

Download that document here - https://e73b1f685119e46196aa-18a481a4bc9b073c638b2c1df2d44b4e.ssl.cf2.rackcdn.com/maddiesfund_f6b66352dc8649c4617a479661c5d2ee.docx

TOPIC:  VACSP Requirement to Administer Controlled Drugs

QUESTIONS:

"I feel like the VACSP is a little ambiguous - are they allowed to do induction? Or to the discretion of the premise holder?"

"Does a certified euthanasia technician need a VACSP? (They would have gone through the class and testing, as outlined in the California Animal Laws Handbook)"

"For VACSP, can VA's give controlled drugs IM (so could be for induction, but not given IV)?"

ANSWER(S):

A VACSP is required for any non-DVM, non-RVT to administer controlled drugs in the shelter setting (other than Pentobarbital).

Pentobarbital may be given by an individual who is a Certified Euthanasia Technician (CET) but that is the ONLY controlled drug that certification allows the individual to give in the state of CA at this time.  

For a CET to administer any other controlled drug they must also possess a VACSP.

Induction of anesthesia is an approved task only for DVMs, and RVTs under direct supervision by a CA veterinarian.

TOPIC:  Affiliation with a DVM

QUESTION:  

"If the veterinarian is in another country or elsewhere, how does the hosting org of the vaccine clinic/RVT source and order the vaccines and emergency drugs? Do these still need to be ordered through a DVM that is affiliated with a veterinary premise in the state, or can this be two different DVMs?"

ANSWER:

The DVM affiliated with your shelter for purposes of order supplies is not required to be present at the time supplies are ordered.  If your facility has a veterinary premises permit there are full guidelines on the requirements of your premises permit holder available through the VMB.  

TOPIC:  Guidelines and Protocols for Vaccine Clinics

QUESTIONS:

"With having to wear the name tags does that establish compliance for the stating who you are and what your title is during vx clinic? Or do you have to verbally state that." - see below

"Where can I find specific guidelines for free/no-cost clinics for those of us without a DVM, RVT, or VA?" - see below

"In cases of vaccine reactions, if the DVM has written a protocol for medications to be given in the event of a reaction, can the RVT/VA's follow this protocol and give those meds?" - see below

"Can a VA establish VCPR at a vaccine clinic for owned animals?"

"For vaccination clinics held at the shelter with a premise permit, does a vet or vet tech have to meet with each owner?" - Yes.  Under this legislation the RVT has been delegated the authority to establish the VCPR which is covered under what a VCPR is in the full webinar (a VCPR includes an assessment of the animal and communication with the owner.  See below for more info and another resource.

"Will you have some sort of overview cheat sheet for who can administer vaccines and when?" - see below and refer to the SB 669 legislation.  Who and when can be very facility dependent.  Any DVM, RVT or VA (which, remember, means anyone trained to perform the duty) can vaccinate unowned animals as part of public/population health care.  Owned animals shelter protocol vaccines can be given at any time by anyone.  At public vaccine clinics the only specification (other than the general guidelines) are that a DVM or now an RVT must establish a VCPR for owned animals. 

"Should we have a written agreement between the veterinarian and our RVT and/or organization?  Should there be compensation to the vet?" - The agreement is mandatory; the compensation is optional.  See below for information on meeting the new vaccine clinic requirements for the written agreement.  In  general, it is a best practice for non-volunteer DVMs to be compensated for whatever duties they perform for your shelter.

ANSWER:

The San Francisco SPCA has generously created a set of guidelines that provide comprehensive guidance and recommendations on both the logistical/legal components to follow the new vaccine clinic legislation as well as medical protocols to be followed by an RVT running a public vaccine clinic under this legislation.  This legislation only allows for an RVT (not a VA) to have the authority to establish a VCPR delegated to them by the DVM.

The SF SPCA's guidelines include suggested forms that comply with the requirement to notify the owners of animals attending the clinic that an RVT will be establishing a VCPR with them and their pet, on behalf of a veterinarian, for the purposes of vaccine administration and parasite control at the vaccine clinic.

The SF SPCA's guidelines document also includes CA DVM created protocols that an RVT may follow to provide emergency care pursuant to the administration of vaccines/parasite control as required under this legislation.

You can DOWNLOAD this document as an MSWord Doc - available for customization by your organization here - https://e73b1f685119e46196aa-18a481a4bc9b073c638b2c1df2d44b4e.ssl.cf2.rackcdn.com/maddiesfund_1ad4b46f86afd4889110da46284f895f.docx

TOPIC:  Specific Vaccine Question RHDV

QUESTION:

"Would this allow an RVT to run a vaccine clinic for the Rabbit Hemorrhagic Disease Virus (RHDV) Medgene vaccine, which is under emergency use/preliminary approval through the USDA, or would this need to be done by a vet until the RHDV Medgene vaccine is fully licensed?"

ANSWER:  

The new vaccine clinic legislation does not specify which vaccines can be given at a public vaccine clinic (i.e. there is no specific guidance or any specified "approved" or "not approved" vaccines that could be given at a public vaccine clinic following these regulations).  The legislation is specifically meant to allow an RVT to establish a VCPR (on behalf of a veterinarian) with a member of the public for the purposes of administering vaccines and parasite control.

TOPIC:  Location of the DVM during a PUBLIC vaccine clinic - premises permit holding location vs non-premises permit holding location.

QUESTIONS:

"What if we have a premise license, but no vet coverage, is there any way we can operate vaccine clinic without a vet present?" - NO - see below.

"What is the reason that a vet does not have to be onsite for a non-premise, but does for a premise site?" - the reason is because this is how the legislation was written and passed into law - see below.

"What if the vaccine clinic is off-site of the shelter with a premise permit?  Does the vet have to be at the off-site vax clinic or can she stay at the shelter?" - see below.

"If a mobile clinic van that has a premise permit is present at in a parking lot clinic does a vet have to be present even though its in a parking lot?" - see below, our interpretation is yes

"Was there an explanation when SB669 as to why if there is a premise permit the DVM must be on site but if no premise no DVM needed? Since we have 3 locations with premise permits our DVM can be available by phone but may not physically be at the location." - see below, this is due to how the legislation was written.

"Why for shelters with premise permits, must the vet be on-site?"

"Up until now, we have been required to hold a premise permit for our MOBILE van used for pop-up vaccine clinics. Does SB669 mean we will not have to hold a premise permit for our mobile unit?"

"When there is no premise permit, and there is a charge for services, do all of these regulations still apply?"

"If the shelter has a premise permit but we run the vaccine clinic in our parking lot, would this be considered off-site so that a veterinarian does not have to be present?"

"What if you are a premise holding shelter but have a shelter with two locations that are ~20 miles apart? Can the DVM be at one location, and the vaccine clinic be held at the second location with an RVT?"

"​Will this pertain to those who host (cover the cost) of pet wellness clinics out in the community?"

ANSWER:

Under the specifics of this legislation, as it is written and passed into law, at a premises permit holding location the DVM must be "physically present" at the facility.  The veterinarian can be *anywhere* on the premises, regardless of how big it is.

When a public vaccine clinic is not being held at a premises permit holding location the DVM is not required to be physically present, but must be available "quickly" by telephone or other means.

Our interpretation of this legislation as it is written would be that vaccine clinics held off-site - not at the actual premises permit holding facility - would not require a DVM to be physically present.

This extends to mobile premises permit holding locations (like a vaccine clinic on wheels) - if the mobile does not have a premises permit,no DVM would need to be on-site.  If the mobile is a premises permit holder the DVM would need to be on-site at the mobile location.

Excerpt from the bill of relevance to these questions:

SB 669 Citation:

CITATION:

(1) The registered veterinary technician administers preventive or prophylactic vaccines or medications for the control or eradication of apparent or anticipated internal or external parasites in a registered veterinary premises when the veterinarian is physically present at the registered veterinary premises.

(2) If working at a location other than a registered veterinary premises, the registered veterinary technician administers preventive or prophylactic vaccines or medications for the control or eradication of apparent or anticipated internal or external parasites when the veterinarian is in the general vicinity or available by telephone and is quickly and easily available. At this location, the registered veterinary technician shall have equipment and drugs necessary to provide immediate emergency care at a level commensurate with the provision of preventive or prophylactic vaccines or medications for the control or eradication of apparent or anticipated internal or external parasites.

See the full SB 669 legislation as it was passed here - https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240SB669

TOPIC:  Do foster parents require a VCPR

QUESTION:

"Does this apply for a shelter/rescue to make a diagnosis since there is no way to set up VCPR with fosters? Can an RVT or Skilled tech see exam/diagnosis/send rx meds"

ANSWER:

Animals in foster care are not "owned" by the foster parent (including people entering a "Foster to Adopt" agreement before ownership is transferred).  There is no requirement for a VCPR for any unowned animal in the shelter's care regardless of the location of the animal; it is the ownership status, not the location that matters.  Foster homes are considered extensions of the shelter and are simply an alternate location in the same way that an off-site adoption event location or a field truck is considered an extension of the shelter.

TOPIC:  SF SPCA Public Vaccine Clinic Guidelines Document

QUESTION:

"FeLV on page 10 says left thoracic limb, but in the protocols it says pelvic limb… are we still recommending pelvic or has it changed to thoracic?"

ANSWER:

This was a typo and has been corrected in the reprinted and re-uploaded version of this document.  The long standing feline fibrosarcoma responsive recommendations for vaccine administration in specific locations have not changed.  FeLV vaccine under that protocol should be administered distally on the left pelvic limb.  Thank you for catching this typo.

TOPIC:  Rabies Vaccinations

QUESTIONS:

"Can an animal care technician that holds a VACSP at the shelter with a premise permit provide a rabies vaccination without an RVT or Veterinarian onsite.This may be off topic, does this effect the rabies vaccines that can be bought at a local feed store and administered by a private citizen?" - a VACSP is only required for controlled drugs - no VACSP is required for Rabies vaccine administration.  See below.

"Will their rabies vaccine be recognized by a shelter for a rabies vaccination towards a license?" - yes - see below.

"Do you have to list specific names that can sign rabies cert or give vax by the vet."  - no, see below.

"On a rabies certificate can you have the vets signature pre-populated and then the VA sign above or be signed the pre-printed signature?" - see below

"For administering vaccines in a shelter setting, can RVTs then administer the Rabies vaccine with no DVM present?" - see below - anyone trained in rabies vaccine administration can perform this vaccination by indirect supervision (DVM not required to be on-site)

"If the veterinarian doesn't have a written or oral communication to give Rabies, does that mean a RVT or VA cannot administer?" - a CA DVM must create a protocol for rabies administration that creates the "indirect" supervision scenario.  This protocol would cover all animals that fall within its specifications.  This type of protocol as indirect supervision applies to all animals the protocol is relevant to as indirect supervision in this case is not specific to any one animal.  Under this setting ANYONE trained in rabies administration can do it with no DVM on-site.

"In a facility with a premise permit, is it the same that a non DVM can sign the rabies cert?" - Rabies vaccine administration does not vary for premises permit holding or non-premises permit holding.

"Does this indirect supervision of rabies certificates apply to GP and other situations, as well?"
- yes.

"Can you revisit if a vet tech can administer a rabies vaccine if the doctor signs the rabies certificate off site?" - Signing of the rabies certificate can be delegated and there is no specifics about where the vaccine occurs.  Anyone trained in rabies vaccine administration may perform the vaccination and sign the certificate on behalf of the DVM.  See below.

"Who signs the rabies certificate at a vaccine clinic that us not at a permitted site, and the veterinarian is not physically present at the clinic?" - see question/answer above and info below.

"Does the RVT also sign the rabies cert for off-site vaccine clinics?" - see below, no adjustments for an off-site clinic.

"So premise holder must have a DVM on site to give vax such as rabies?" - No, see below.  The rabies vaccination does not have any specific requirements based on location.  The vaccine clinic legislation applies to all vaccines/parasite control at a public vaccine clinic.  So, the public vaccine clinic held at a premises permit holding location must have a vet at the facility at the time of the clinic for rabies and any other vaccines.

"Can the public/animal owner give their dog a rabies vaccination?" - a DVM signed/authorized Rabies certificate is required to comply with state laws for proof of rabies vaccination.  If they can obtain the vaccine they can give it but without the DVM signed/authorized certificate it will not be a valid rabies vaccination for legal purposes.  And, if a bite occurs the animal will be considered unvaccinated.

"We do not have a vet, rvt, or va. We are a shelter only, but have va training from a vet. Our local vets are 2-3 weeks out to see any of our pets, or we can drive 2-3 hours to have the pet seen today.  Is there a way we can still vaccinate for rabies? Ill go back and watch the webinar on "who can do what". - see above and below.  Anyone trained to administer a vaccine (or other medical care duty they are assigned to do) is considered a VA.

ANSWER:

Rabies vaccinations may be given by an RVT or a VA under direct or indirect supervision of a DVM.  That means that any individual who has been trained in the administration of rabies vaccines (making them a VA because that title does not require any specific schooling or licensing, just requires that training in the medical care duties they are being assigned has occurred) can give a rabies vaccination whether or not a DVM or RVT is present following a CA DVM created protocol for rabies vaccine administration.  

The person who has been trained in giving a rabies vaccination and performs the vaccination may also act as a delegate for the DVM and sign the rabies certificate on behalf of the DVM.  As written there is no specific exclusion for a computer applied signature, and we interpret the statute to allow for that as long as there is definitely an authorization from the DVM prior to administration of the vaccine.  Most shelter software programs can have a rabies certificate created that pulls in a DVM's signature (as a jpeg or other image file) and the shelter can be authorized to use this.  If you have multiple DVMs you can also program multiple signatures and program them to be pulled in from the correct DVM based on a data field you enter the DVM name into.  This allows the software to pull in the correct signature based on the name of the DVM you put into that data field.

As an aside a rabies vaccination given by an owner without a DVM signed rabies certification does not meet the documentation requirements for "proof of rabies vaccination" required by law for dogs in California.

TOPIC:  Additional concepts, topics

QUESTION: "Can a DVM give free care via telemedicine without it coming back to their license if they never see the pet or develop a VCPR?"

Yes.

QUESTION:  For  telemedicine, I was under the impression that it has to be a simultaneous audio-visual communication- not just one or the other. Is this the case?

ANSWER:

In AB 1399 Telehealth is defined and can be synchronous/simultaneous "real-time" audio and video, 2 way audio only or other means to electronically transmit information.  Note the semi-colons in the citation below where the 3rd option for telemedicine/telehealth is "and electronic transmission of images, diagnostics, data, and medical information."

CITATION:

From AB 1399 - Section 2 - 4825.1 (g)

"Telehealth" means the mode of delivering veterinary medicine via electronic communication technologies to facilitate the diagnosis, consultation, care management, or treatment of an animal patient, and includes, but is not limited to, synchronous video and audio communication; synchronous, two-way audio communication; and electronic transmission of images, diagnostics, data, and medical information.

LINK to AB 1399

https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240AB1399

QUESTION:  "Is there a suggested website or App we can find a list of DVM's offering Telemedecine for those of us without local vets?"

ANSWER:  There are many services/platforms available at this time.  We recommend an internet search for options for CA DVMs offering telemedicine.  In general, for a shelter, establishing a relationship with a DVM for telemedicine, protocol creation and oversight would be strongly recommended to secure a DVM with knowledge of animal shelters and animal shelter specific medicine.

QUESTION:  "These additional tasks for RVT's are wonderful and seem incredibly beneficial to shelter organizations. What is your opinion on how these responsibilities would reflect in compensation?"

ANSWER:  We would recommend that shelters offer a competitive salary and benefits for all RVTs, VAs and other staff based on the position, the individual, and the duties they will be assigned.  Those highly leveraging RVTs to perform all allowed tasks should ensure their staff are appropriately compensated.

Any further questions or clarification needed please reply in this thread and we'll add to this information.

------------------------------
Cindi Delany, DVM, KPA-CTP, FFCP
Director of Online Learning
Maddie's Million Pet Challenge
UC Davis Koret Shelter Medicine Program

Original Message:
Sent: 01-10-2024 10:18 AM
From: Cindi Delany
Subject: A New Era in Medical Care - Telemedicine and Vaccine Clinics in California (that could be adopted in other states) - Legislative Updates for 2024 Webinar - 1/24/24 (will be recorded)

#AccesstoCare
#EducationandTraining
#LawsandPublicPolicy
#Medicine,SurgeryandSterilization
#PeopleManagement(includingVolunteerIntegration)
#RemoteCustomerService*

------------------------------
Cindi Delany, DVM, KPA-CTP, FFCP
Director of Online Learning
Maddie's Million Pet Challenge
UC Davis Koret Shelter Medicine Program
------------------------------

Hello and thank you for this informative webinar and Q and A!  I have a question about OTC vaccination that has been done at my shelter for owned animals.  Historically, an owner could walk in and request DHPP/bord vaccines which they were being charged a small fee for, and shelter staff were administering these.  This was done during shelter operational hours, not at a specified vaccine clinic.  Am I correct in saying that if the owner is being charged for these vaccines,  the person giving them must be an RVT acting on behalf of the DVM with the paperwork designating this signed, and the owner informed of this, just like a vaccine clinic?

------------------------------
Stefanie Thielemann
Managing Veterinarian
Stockton Animal Shelter
CA

Original Message:
Sent: 02-05-2024 05:15 PM
From: Cindi Delany
Subject: A New Era in Medical Care - Telemedicine and Vaccine Clinics in California (that could be adopted in other states) - Legislative Updates for 2024 Webinar - 1/24/24 (will be recorded)

Posting the webinars Q&A for attendees or those who weren't able to attend.

QUESTION: 

"Will this webcast be available for video replay on demand?"

ANSWER:

YES, please rewatch the webinar here - for more information and clarification on most of these topics - http://tinyurl.com/TMVXwatch

TOPIC:  Vaccines/Allowed Care for Shelter Impounded Animals

QUESTIONS:

"Can assistants do all of these tasks that are listed without a vet even seeing the pet, then?"

"What if you do not have an RVT or vet on staff but contract with an outside vet, can vaccines/meds be given to shelter animals?"

"Can you vaccinate upon intake an animal with ID before making contact with the owner?"

"So a stray coming in with a chip is owned?"

ANSWER:

Routine intake and other care (in the interest of animal/public health and safety) not restricted to a DVM or RVT for animals in a shelter (outside of the public vaccine clinic realm) can be provided by a Veterinary Assistant (VA) following California DVM created protocols under direct or indirect supervision for shelter animals.  

This applies both to animals with indications of ownership (who are considered owned during the stray or other legal holding period) as well as animals with no signs of ownership (who are considered "unowned" during the stray or other legal holding period unless or until an owner claims ownership of them).

Animals arriving at the shelter with a known owner or with indications of ownership (ID tag, other identifier, microchip, etc.) are considered owned during the stray or other legal holding period.

Care provided to owner animals at a vaccine clinic must follow the revised Vaccine Clinic guidelines covered in this webinar.  Please rewatch the webinar here - for specifics of what this covers - http://tinyurl.com/TMVXwatch

For more information on many of the concepts reviewed in the Telemedicine/Vaccine Clinic Legislative Updates Webinar - please review these previous webinars in our Shelter PALs series:

1. Legal Meets Best Practices

2. Decoding Compliance:  What You Need to Know About DEA, Controlled Drugs and Premises Permits in Your Shelter

3. Animal Intake Requirements and Holding Periods

4. Community Cat Programs

5. Veterinary Care in Shelters:  Who Can Legally Do What?

All of these webinars and more are available in our "Shelter PALs" package on Maddie's University - CLICK HERE to access.

TOPIC:   Vaccines Given to Public Owner Animals at a Vaccine Clinic

QUESTION:  "For owned pets (and for a charge), does the RVT thing stand to do services without a vet doing the exam, including rabies?"

ANSWER:  Yes, for owned animals receiving vaccinations and parasite control at a vaccine clinic for a charge, the new Vaccine Clinic legislation permits an RVT to establish the VCPR with the animal/client and provide the vaccinations/parasite control this legislation permits without a DVM exam occuring.

TOPIC:  Exception for Owned Animals - Free Services at Owner's Request

QUESTIONS:  

"If a person off the street walks into the shelter and asks for a DHPP vaccine, I can vaccinate it without an RVT or Vet present as long as I am doing it free of charge?"

"Can core vaccines given to the public at no charge with no vet or RVT on site."

"Is the statement about not charging for services just in California or beyond? What is the legal reference for that not constituting practicing medicine?"

"What about indigenous communities - is there a way to help them without a vet or RVT present?"

"If you hold a FREE vaccine clinic at your shelter where you hold your premise permit, would the DVM need to be present?"

"Can you provide more information about how services provided for free are not subject to a VCPR? This is different from what I learned in vet school (in California). What if a shelter is offering services to the public for free to prevent surrenders, but the provider is being paid for those services by the shelter- is that considered "free" or is it only if the DVM, RVT, etc does not accept any compensation?"

ANSWER:  In California, per the California Business and Professions Code - BPC Section 4827 - Services provided to an owner at their request free of charge do fall under the allowance for owners and their agents to provide medical care as a "bona fide owner of one's own animals."  This should apply to vaccines - core or other if provided at the owner's request at no charge.  This does not mean that free medical care can be provided to an impounded owned animal without first establishing a VCPR with the owner for non-emergency and non-population health (i.e. standard intake care) medical care.

In the last question above about services provided to the owner for free where a provider is compensated by the shelter but not by the animal owner, the above exception for services provided to an owner at no charge applies.  The relevant consideration is not if the person doing the service is getting paid, the only question is if the OWNER of the animal is getting the services for free.

CITATION:

California Code, Business and Professions Code - BPC § 4827

Current as of January 01, 2023 | Updated by FindLaw Staff

(a) Nothing in this chapter prohibits any person from:

(1) Practicing veterinary medicine as a bona fide owner of one's own animals. This exemption applies to the following:

(A) The owner's bona fide employees.

(B) Any person assisting the owner, provided that the practice is performed gratuitously.

https://codes.findlaw.com/ca/business-and-professions-code/bpc-sect-4827/

TOPIC:  Telemedicine VCPR Requirements

QUESTION:  In this first example (community cat with abscess) could the shelter team provide care without telemedicine? Since no VCPR is needed, why is a telemedicine consult needed- is that just bc of the nature of the issue (abscess) requires individual recommendations?

ANSWER:  If a California DVM has created a protocol for dealing with abscesses that protocol could be followed to begin initial care of the cat without using telemedicine.  In the absence of a clear CA DVM created protocol or where staff would like DVM guidance the cat could either be seen by a DVM if one was available in–person or telemedicine could be used to provide that guidance.  The main take-home of the scenario is that the cat is unowned if a "Community Cat" with no known owner or indications of ownership and so no VCPR (in-person or via telemedicine with an owner) is required to provide the needed care.

TOPIC:  VCPR - When Does it Apply

QUESTIONS:

"How does VCPR affect a vets ability to treat a shelter animal that is there as part of a criminal case? An animal confiscated after biting a person, where perhaps the owner doesn't provide consent to provide treatment but the animal is in our care/has to be in our care and needs treatment? Or may need to be sedated to remove a collar/harness/etc. so it can be safely housed?" - see below - intake and emergency care do not require VCPR, other care for owned animals does require it.

"If an animal is in the shelter during it's legal holding period/quarantine/dangerous dog hold etc, the owner is known to the shelter, do the shelter need to establish a VCPR?"- see below.

"Once animals are adopted many come back for meds for coughing. Usually the animal is brought to the hospital, examined by the vet and sent with meds. There is no direct communication between the vet and the owner. Does this mean that there is no vcpr?  Is it possible for the rvt to FaceTime or text with videos with owners for these post adoption animals for kennel cough?  It would save the owner from bringing the animal in and could just pick up meds when the vet is offsite" - yes, see below for VCPR options for owned animals (which includes recently adopted animals if ownership has been transferred).  A VCPR is required in this scenario and can be done in person or via telemedicine.

ANSWERS:

A VCPR (knowledge of the animal and communication with the owner) is required for owned animals requiring non-emergency and non-population health benefiting care.  Owned animals may be provided with typical shelter intake care (vaccinations, parasite control, etc.) as well as with emergency care.  See our prior webinars on intake and on who can do what in the shelters available at the link shown in the top of this post.

Non-emergency care for owned animals requires a VCPR.  A VCPR can now be established in person - animal, owner, DVM (or RVT but only for public vaccine clinic administration of vaccines and preventatives) or using telemedicine with the new AB 1399 legislation.

SF SPCA Shelter PALs has created a sample consent to care contract to use with owners of animals under the shelter's care to allow non-emergency, non-intake care when it is needed if contact can be made with an owner proactively even before such care is needed.

Download that document here - https://e73b1f685119e46196aa-18a481a4bc9b073c638b2c1df2d44b4e.ssl.cf2.rackcdn.com/maddiesfund_f6b66352dc8649c4617a479661c5d2ee.docx

TOPIC:  VACSP Requirement to Administer Controlled Drugs

QUESTIONS:

"I feel like the VACSP is a little ambiguous - are they allowed to do induction? Or to the discretion of the premise holder?"

"Does a certified euthanasia technician need a VACSP? (They would have gone through the class and testing, as outlined in the California Animal Laws Handbook)"

"For VACSP, can VA's give controlled drugs IM (so could be for induction, but not given IV)?"

ANSWER(S):

A VACSP is required for any non-DVM, non-RVT to administer controlled drugs in the shelter setting (other than Pentobarbital).

Pentobarbital may be given by an individual who is a Certified Euthanasia Technician (CET) but that is the ONLY controlled drug that certification allows the individual to give in the state of CA at this time.  

For a CET to administer any other controlled drug they must also possess a VACSP.

Induction of anesthesia is an approved task only for DVMs, and RVTs under direct supervision by a CA veterinarian.

TOPIC:  Affiliation with a DVM

QUESTION:  

"If the veterinarian is in another country or elsewhere, how does the hosting org of the vaccine clinic/RVT source and order the vaccines and emergency drugs? Do these still need to be ordered through a DVM that is affiliated with a veterinary premise in the state, or can this be two different DVMs?"

ANSWER:

The DVM affiliated with your shelter for purposes of order supplies is not required to be present at the time supplies are ordered.  If your facility has a veterinary premises permit there are full guidelines on the requirements of your premises permit holder available through the VMB.  

TOPIC:  Guidelines and Protocols for Vaccine Clinics

QUESTIONS:

"With having to wear the name tags does that establish compliance for the stating who you are and what your title is during vx clinic? Or do you have to verbally state that." - see below

"Where can I find specific guidelines for free/no-cost clinics for those of us without a DVM, RVT, or VA?" - see below

"In cases of vaccine reactions, if the DVM has written a protocol for medications to be given in the event of a reaction, can the RVT/VA's follow this protocol and give those meds?" - see below

"Can a VA establish VCPR at a vaccine clinic for owned animals?"

"For vaccination clinics held at the shelter with a premise permit, does a vet or vet tech have to meet with each owner?" - Yes.  Under this legislation the RVT has been delegated the authority to establish the VCPR which is covered under what a VCPR is in the full webinar (a VCPR includes an assessment of the animal and communication with the owner.  See below for more info and another resource.

"Will you have some sort of overview cheat sheet for who can administer vaccines and when?" - see below and refer to the SB 669 legislation.  Who and when can be very facility dependent.  Any DVM, RVT or VA (which, remember, means anyone trained to perform the duty) can vaccinate unowned animals as part of public/population health care.  Owned animals shelter protocol vaccines can be given at any time by anyone.  At public vaccine clinics the only specification (other than the general guidelines) are that a DVM or now an RVT must establish a VCPR for owned animals. 

"Should we have a written agreement between the veterinarian and our RVT and/or organization?  Should there be compensation to the vet?" - The agreement is mandatory; the compensation is optional.  See below for information on meeting the new vaccine clinic requirements for the written agreement.  In  general, it is a best practice for non-volunteer DVMs to be compensated for whatever duties they perform for your shelter.

ANSWER:

The San Francisco SPCA has generously created a set of guidelines that provide comprehensive guidance and recommendations on both the logistical/legal components to follow the new vaccine clinic legislation as well as medical protocols to be followed by an RVT running a public vaccine clinic under this legislation.  This legislation only allows for an RVT (not a VA) to have the authority to establish a VCPR delegated to them by the DVM.

The SF SPCA's guidelines include suggested forms that comply with the requirement to notify the owners of animals attending the clinic that an RVT will be establishing a VCPR with them and their pet, on behalf of a veterinarian, for the purposes of vaccine administration and parasite control at the vaccine clinic.

The SF SPCA's guidelines document also includes CA DVM created protocols that an RVT may follow to provide emergency care pursuant to the administration of vaccines/parasite control as required under this legislation.

You can DOWNLOAD this document as an MSWord Doc - available for customization by your organization here - https://e73b1f685119e46196aa-18a481a4bc9b073c638b2c1df2d44b4e.ssl.cf2.rackcdn.com/maddiesfund_1ad4b46f86afd4889110da46284f895f.docx

TOPIC:  Specific Vaccine Question RHDV

QUESTION:

"Would this allow an RVT to run a vaccine clinic for the Rabbit Hemorrhagic Disease Virus (RHDV) Medgene vaccine, which is under emergency use/preliminary approval through the USDA, or would this need to be done by a vet until the RHDV Medgene vaccine is fully licensed?"

ANSWER:  

The new vaccine clinic legislation does not specify which vaccines can be given at a public vaccine clinic (i.e. there is no specific guidance or any specified "approved" or "not approved" vaccines that could be given at a public vaccine clinic following these regulations).  The legislation is specifically meant to allow an RVT to establish a VCPR (on behalf of a veterinarian) with a member of the public for the purposes of administering vaccines and parasite control.

TOPIC:  Location of the DVM during a PUBLIC vaccine clinic - premises permit holding location vs non-premises permit holding location.

QUESTIONS:

"What if we have a premise license, but no vet coverage, is there any way we can operate vaccine clinic without a vet present?" - NO - see below.

"What is the reason that a vet does not have to be onsite for a non-premise, but does for a premise site?" - the reason is because this is how the legislation was written and passed into law - see below.

"What if the vaccine clinic is off-site of the shelter with a premise permit?  Does the vet have to be at the off-site vax clinic or can she stay at the shelter?" - see below.

"If a mobile clinic van that has a premise permit is present at in a parking lot clinic does a vet have to be present even though its in a parking lot?" - see below, our interpretation is yes

"Was there an explanation when SB669 as to why if there is a premise permit the DVM must be on site but if no premise no DVM needed? Since we have 3 locations with premise permits our DVM can be available by phone but may not physically be at the location." - see below, this is due to how the legislation was written.

"Why for shelters with premise permits, must the vet be on-site?"

"Up until now, we have been required to hold a premise permit for our MOBILE van used for pop-up vaccine clinics. Does SB669 mean we will not have to hold a premise permit for our mobile unit?"

"When there is no premise permit, and there is a charge for services, do all of these regulations still apply?"

"If the shelter has a premise permit but we run the vaccine clinic in our parking lot, would this be considered off-site so that a veterinarian does not have to be present?"

"What if you are a premise holding shelter but have a shelter with two locations that are ~20 miles apart? Can the DVM be at one location, and the vaccine clinic be held at the second location with an RVT?"

"​Will this pertain to those who host (cover the cost) of pet wellness clinics out in the community?"

ANSWER:

Under the specifics of this legislation, as it is written and passed into law, at a premises permit holding location the DVM must be "physically present" at the facility.  The veterinarian can be *anywhere* on the premises, regardless of how big it is.

When a public vaccine clinic is not being held at a premises permit holding location the DVM is not required to be physically present, but must be available "quickly" by telephone or other means.

Our interpretation of this legislation as it is written would be that vaccine clinics held off-site - not at the actual premises permit holding facility - would not require a DVM to be physically present.

This extends to mobile premises permit holding locations (like a vaccine clinic on wheels) - if the mobile does not have a premises permit,no DVM would need to be on-site.  If the mobile is a premises permit holder the DVM would need to be on-site at the mobile location.

Excerpt from the bill of relevance to these questions:

SB 669 Citation:

CITATION:

(1) The registered veterinary technician administers preventive or prophylactic vaccines or medications for the control or eradication of apparent or anticipated internal or external parasites in a registered veterinary premises when the veterinarian is physically present at the registered veterinary premises.

(2) If working at a location other than a registered veterinary premises, the registered veterinary technician administers preventive or prophylactic vaccines or medications for the control or eradication of apparent or anticipated internal or external parasites when the veterinarian is in the general vicinity or available by telephone and is quickly and easily available. At this location, the registered veterinary technician shall have equipment and drugs necessary to provide immediate emergency care at a level commensurate with the provision of preventive or prophylactic vaccines or medications for the control or eradication of apparent or anticipated internal or external parasites.

See the full SB 669 legislation as it was passed here - https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240SB669

TOPIC:  Do foster parents require a VCPR

QUESTION:

"Does this apply for a shelter/rescue to make a diagnosis since there is no way to set up VCPR with fosters? Can an RVT or Skilled tech see exam/diagnosis/send rx meds"

ANSWER:

Animals in foster care are not "owned" by the foster parent (including people entering a "Foster to Adopt" agreement before ownership is transferred).  There is no requirement for a VCPR for any unowned animal in the shelter's care regardless of the location of the animal; it is the ownership status, not the location that matters.  Foster homes are considered extensions of the shelter and are simply an alternate location in the same way that an off-site adoption event location or a field truck is considered an extension of the shelter.

TOPIC:  SF SPCA Public Vaccine Clinic Guidelines Document

QUESTION:

"FeLV on page 10 says left thoracic limb, but in the protocols it says pelvic limb… are we still recommending pelvic or has it changed to thoracic?"

ANSWER:

This was a typo and has been corrected in the reprinted and re-uploaded version of this document.  The long standing feline fibrosarcoma responsive recommendations for vaccine administration in specific locations have not changed.  FeLV vaccine under that protocol should be administered distally on the left pelvic limb.  Thank you for catching this typo.

TOPIC:  Rabies Vaccinations

QUESTIONS:

"Can an animal care technician that holds a VACSP at the shelter with a premise permit provide a rabies vaccination without an RVT or Veterinarian onsite.This may be off topic, does this effect the rabies vaccines that can be bought at a local feed store and administered by a private citizen?" - a VACSP is only required for controlled drugs - no VACSP is required for Rabies vaccine administration.  See below.

"Will their rabies vaccine be recognized by a shelter for a rabies vaccination towards a license?" - yes - see below.

"Do you have to list specific names that can sign rabies cert or give vax by the vet."  - no, see below.

"On a rabies certificate can you have the vets signature pre-populated and then the VA sign above or be signed the pre-printed signature?" - see below

"For administering vaccines in a shelter setting, can RVTs then administer the Rabies vaccine with no DVM present?" - see below - anyone trained in rabies vaccine administration can perform this vaccination by indirect supervision (DVM not required to be on-site)

"If the veterinarian doesn't have a written or oral communication to give Rabies, does that mean a RVT or VA cannot administer?" - a CA DVM must create a protocol for rabies administration that creates the "indirect" supervision scenario.  This protocol would cover all animals that fall within its specifications.  This type of protocol as indirect supervision applies to all animals the protocol is relevant to as indirect supervision in this case is not specific to any one animal.  Under this setting ANYONE trained in rabies administration can do it with no DVM on-site.

"In a facility with a premise permit, is it the same that a non DVM can sign the rabies cert?" - Rabies vaccine administration does not vary for premises permit holding or non-premises permit holding.

"Does this indirect supervision of rabies certificates apply to GP and other situations, as well?"
- yes.

"Can you revisit if a vet tech can administer a rabies vaccine if the doctor signs the rabies certificate off site?" - Signing of the rabies certificate can be delegated and there is no specifics about where the vaccine occurs.  Anyone trained in rabies vaccine administration may perform the vaccination and sign the certificate on behalf of the DVM.  See below.

"Who signs the rabies certificate at a vaccine clinic that us not at a permitted site, and the veterinarian is not physically present at the clinic?" - see question/answer above and info below.

"Does the RVT also sign the rabies cert for off-site vaccine clinics?" - see below, no adjustments for an off-site clinic.

"So premise holder must have a DVM on site to give vax such as rabies?" - No, see below.  The rabies vaccination does not have any specific requirements based on location.  The vaccine clinic legislation applies to all vaccines/parasite control at a public vaccine clinic.  So, the public vaccine clinic held at a premises permit holding location must have a vet at the facility at the time of the clinic for rabies and any other vaccines.

"Can the public/animal owner give their dog a rabies vaccination?" - a DVM signed/authorized Rabies certificate is required to comply with state laws for proof of rabies vaccination.  If they can obtain the vaccine they can give it but without the DVM signed/authorized certificate it will not be a valid rabies vaccination for legal purposes.  And, if a bite occurs the animal will be considered unvaccinated.

"We do not have a vet, rvt, or va. We are a shelter only, but have va training from a vet. Our local vets are 2-3 weeks out to see any of our pets, or we can drive 2-3 hours to have the pet seen today.  Is there a way we can still vaccinate for rabies? Ill go back and watch the webinar on "who can do what". - see above and below.  Anyone trained to administer a vaccine (or other medical care duty they are assigned to do) is considered a VA.

ANSWER:

Rabies vaccinations may be given by an RVT or a VA under direct or indirect supervision of a DVM.  That means that any individual who has been trained in the administration of rabies vaccines (making them a VA because that title does not require any specific schooling or licensing, just requires that training in the medical care duties they are being assigned has occurred) can give a rabies vaccination whether or not a DVM or RVT is present following a CA DVM created protocol for rabies vaccine administration.  

The person who has been trained in giving a rabies vaccination and performs the vaccination may also act as a delegate for the DVM and sign the rabies certificate on behalf of the DVM.  As written there is no specific exclusion for a computer applied signature, and we interpret the statute to allow for that as long as there is definitely an authorization from the DVM prior to administration of the vaccine.  Most shelter software programs can have a rabies certificate created that pulls in a DVM's signature (as a jpeg or other image file) and the shelter can be authorized to use this.  If you have multiple DVMs you can also program multiple signatures and program them to be pulled in from the correct DVM based on a data field you enter the DVM name into.  This allows the software to pull in the correct signature based on the name of the DVM you put into that data field.

As an aside a rabies vaccination given by an owner without a DVM signed rabies certification does not meet the documentation requirements for "proof of rabies vaccination" required by law for dogs in California.

TOPIC:  Additional concepts, topics

QUESTION: "Can a DVM give free care via telemedicine without it coming back to their license if they never see the pet or develop a VCPR?"

Yes.

QUESTION:  For  telemedicine, I was under the impression that it has to be a simultaneous audio-visual communication- not just one or the other. Is this the case?

ANSWER:

In AB 1399 Telehealth is defined and can be synchronous/simultaneous "real-time" audio and video, 2 way audio only or other means to electronically transmit information.  Note the semi-colons in the citation below where the 3rd option for telemedicine/telehealth is "and electronic transmission of images, diagnostics, data, and medical information."

CITATION:

From AB 1399 - Section 2 - 4825.1 (g)

"Telehealth" means the mode of delivering veterinary medicine via electronic communication technologies to facilitate the diagnosis, consultation, care management, or treatment of an animal patient, and includes, but is not limited to, synchronous video and audio communication; synchronous, two-way audio communication; and electronic transmission of images, diagnostics, data, and medical information.

LINK to AB 1399

https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240AB1399

QUESTION:  "Is there a suggested website or App we can find a list of DVM's offering Telemedecine for those of us without local vets?"

ANSWER:  There are many services/platforms available at this time.  We recommend an internet search for options for CA DVMs offering telemedicine.  In general, for a shelter, establishing a relationship with a DVM for telemedicine, protocol creation and oversight would be strongly recommended to secure a DVM with knowledge of animal shelters and animal shelter specific medicine.

QUESTION:  "These additional tasks for RVT's are wonderful and seem incredibly beneficial to shelter organizations. What is your opinion on how these responsibilities would reflect in compensation?"

ANSWER:  We would recommend that shelters offer a competitive salary and benefits for all RVTs, VAs and other staff based on the position, the individual, and the duties they will be assigned.  Those highly leveraging RVTs to perform all allowed tasks should ensure their staff are appropriately compensated.

Any further questions or clarification needed please reply in this thread and we'll add to this information.

------------------------------
Cindi Delany, DVM, KPA-CTP, FFCP
Director of Online Learning
Maddie's Million Pet Challenge
UC Davis Koret Shelter Medicine Program

Original Message:
Sent: 01-10-2024 10:18 AM
From: Cindi Delany
Subject: A New Era in Medical Care - Telemedicine and Vaccine Clinics in California (that could be adopted in other states) - Legislative Updates for 2024 Webinar - 1/24/24 (will be recorded)

#AccesstoCare
#EducationandTraining
#LawsandPublicPolicy
#Medicine,SurgeryandSterilization
#PeopleManagement(includingVolunteerIntegration)
#RemoteCustomerService*

------------------------------
Cindi Delany, DVM, KPA-CTP, FFCP
Director of Online Learning
Maddie's Million Pet Challenge
UC Davis Koret Shelter Medicine Program
------------------------------

#AccesstoCare
#EducationandTraining
#LawsandPublicPolicy
#Medicine,SurgeryandSterilization
#PeopleManagement(includingVolunteerIntegration)
#RemoteCustomerService*

------------------------------
Cindi Delany, DVM, KPA-CTP, FFCP
Director of Online Learning
Maddie's Million Pet Challenge
UC Davis Koret Shelter Medicine Program
------------------------------

Thank you for such an insightful presentation!  I was hoping to get some clarification on community cats. 
I work with community cats, mainly kittens under 8 weeks.  Did I understand correctly that since community cats have no owner, no VCPCR is needed, therefore as an RVT I am able to provide vaccines without the need of a VCPCR?

I often encounter kittens with URI - If I have a DVM willing to write protocols surrounding treatment (including dispensing of medication), I would be able to provide those services/medications without the need of a VCPCR since they are unowned and under age? Or would this be where I would need to establish a telemedicine VCPRC? 

Thank you! 

------------------------------
Debra Olmedo
ASPCA

Original Message:
Sent: 01-10-2024 10:18 AM
From: Cindi Delany
Subject: A New Era in Medical Care - Telemedicine and Vaccine Clinics in California (that could be adopted in other states) - Legislative Updates for 2024 Webinar - 1/24/24 (will be recorded)

#AccesstoCare
#EducationandTraining
#LawsandPublicPolicy
#Medicine,SurgeryandSterilization
#PeopleManagement(includingVolunteerIntegration)
#RemoteCustomerService*

------------------------------
Cindi Delany, DVM, KPA-CTP, FFCP
Director of Online Learning
Maddie's Million Pet Challenge
UC Davis Koret Shelter Medicine Program
------------------------------

@Debra Olmedo

Hi Debra,

By definition any community cat (i.e. cat with no indications of (indicia of) ownership) does not have an owner.  The VCPR requirement only applies to animals that have an owner.

So, any community cat can have services provided under orders from a DVM (including standing orders/protocols) without any owner involvement (since there is no owner).  Additional caveats of course for services only a DVM or RVT can provide (like surgery, etc.).

Any RVT or VA (an unlicensed Veterinary Assistant which really can be anyone in your shelter trained to perform a duty that is legally allowed to be done by non- DVM/RVTs) can provide vaccines without the need of a VCPR (again, based on the cat being a community cat and not having an owner).

For URI treatment if you have a protocol from a California Licensed DVM (if you are in CA) you can follow that protocol under direct or indirect supervision of that DVM.  This applies to any community cat regardless of age.

Definitely keep in mind - there is no need for or way to get a VCPR (Veterinary Client Patient Relationship) because there is no "client" = owner.  This is all due to the fact that the cats are "Community Cats" which means they are cats/kittens with no known legal owner (so under the general community's stewardship rather than being owned by an individual).

Let me know if this all makes sense and reach out to me at cddelany@ucdavis.edu if you want to clarify anything here.  This legal stuff definitely gets a bit tricky and often it's based on the definitions we are using.

P.S. Editing to add - telemedicine can also be used in this case and really always could have been, as the only change in telemedicine with the legislation is that a VCPR (which was required for telemedicine for owned animals) can now be established by telephone/video chat, etc. and that VCPR was never needed in the scenario you describe due to the community cats not having a legal owner. 

Cindi

------------------------------
Cindi Delany, DVM, KPA-CTP, FFCP
Director of Online Learning
Maddie's Million Pet Challenge
UC Davis Koret Shelter Medicine Program

Original Message:
Sent: 03-05-2024 09:26 AM
From: Debra Olmedo
Subject: A New Era in Medical Care - Telemedicine and Vaccine Clinics in California (that could be adopted in other states) - Legislative Updates for 2024 Webinar - 1/24/24 (will be recorded)

Thank you for such an insightful presentation!  I was hoping to get some clarification on community cats. 
I work with community cats, mainly kittens under 8 weeks.  Did I understand correctly that since community cats have no owner, no VCPCR is needed, therefore as an RVT I am able to provide vaccines without the need of a VCPCR?

I often encounter kittens with URI - If I have a DVM willing to write protocols surrounding treatment (including dispensing of medication), I would be able to provide those services/medications without the need of a VCPCR since they are unowned and under age? Or would this be where I would need to establish a telemedicine VCPRC? 

Thank you! 

------------------------------
Debra Olmedo
ASPCA

Original Message:
Sent: 01-10-2024 10:18 AM
From: Cindi Delany
Subject: A New Era in Medical Care - Telemedicine and Vaccine Clinics in California (that could be adopted in other states) - Legislative Updates for 2024 Webinar - 1/24/24 (will be recorded)

#AccesstoCare
#EducationandTraining
#LawsandPublicPolicy
#Medicine,SurgeryandSterilization
#PeopleManagement(includingVolunteerIntegration)
#RemoteCustomerService*

------------------------------
Cindi Delany, DVM, KPA-CTP, FFCP
Director of Online Learning
Maddie's Million Pet Challenge
UC Davis Koret Shelter Medicine Program
------------------------------