Animal Welfare Professionals

Last Wednesday, 10/11/23, we took a deep dive into decoding DEA controlled drug regulations and premises permits (with a specific look at California-specific regs).

Both the recorded webinar and an on-demand course are available now on Maddie's University.

MMPC Learniverse – Decoding Compliance: What You Need to Know about Controlled Drugs and Premises Permits in Your Shelter - Legal Considerations with Shelter PALS

#AccesstoCare
#LawsandPublicPolicy
#OrganizationalManagement

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA
------------------------------

WEBINAR Q&A - Question #1

QUESTION: 

Is the Premises Permit specific to CA?

ANSWER:

All or most states have their own veterinary medicine boards that would issue premises permits or the equivalent.

Check with your local veterinary medical board as well as lawyers familiar with the process if you are not in the state of California, to determine what type of premises permit or other requirement must be met to practice veterinary medicine in a shelter in your state.

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA
------------------------------

Original Message:
Sent: 10-16-2023 03:51 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

Last Wednesday, 10/11/23, we took a deep dive into decoding DEA controlled drug regulations and premises permits (with a specific look at California-specific regs).

Both the recorded webinar and an on-demand course are available now on Maddie's University.

MMPC Learniverse – Decoding Compliance: What You Need to Know about Controlled Drugs and Premises Permits in Your Shelter - Legal Considerations with Shelter PALS

During the webinar we had LOTS of great questions and we promised to grab the questions and share answers and references here on Maddie's Pet Forum.

I'll start adding those questions and answers to this thread.

Please add any additional questions you have to this discussion and we get input from our webinars speakers.

Thanks to everyone who attended and to everyone who takes a look at the on-demand version of the webinar and additional content linked above.

Cindi Delany, DVM

Maddie's Million Pet Challenge

Director of Online Learning

at UC Davis Koret Shelter Medicine Program

#AccesstoCare
#LawsandPublicPolicy
#OrganizationalManagement

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA
------------------------------

WEBINAR Q&A - Question #2 - DEA Licenses/Registration

QUESTION: 

Can Veterinarians hold multiple DEA licenses for different sites?

ANSWER:

Yes, DVMs may hold multiple DEA licenses for different locations and under the DEA's Veterinary Mobility Act of 2014 may also transport controlled drugs to a non-central practice location (such as a house call or livestock facility) in the course of the practice of veterinary medicine.

RESOURCE:  https://en.wikipedia.org/wiki/Veterinary_Medicine_Mobility_Act_of_2014

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

Original Message:
Sent: 10-16-2023 03:57 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

WEBINAR Q&A - Question #1

QUESTION: 

Is the Premises Permit specific to CA?

ANSWER:

All or most states have their own veterinary medicine boards that would issue premises permits or the equivalent.

Check with your local veterinary medical board as well as lawyers familiar with the process if you are not in the state of California, to determine what type of premises permit or other requirement must be met to practice veterinary medicine in a shelter in your state.

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA

Original Message:
Sent: 10-16-2023 03:51 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

Last Wednesday, 10/11/23, we took a deep dive into decoding DEA controlled drug regulations and premises permits (with a specific look at California-specific regs).

Both the recorded webinar and an on-demand course are available now on Maddie's University.

MMPC Learniverse – Decoding Compliance: What You Need to Know about Controlled Drugs and Premises Permits in Your Shelter - Legal Considerations with Shelter PALS

During the webinar we had LOTS of great questions and we promised to grab the questions and share answers and references here on Maddie's Pet Forum.

I'll start adding those questions and answers to this thread.

Please add any additional questions you have to this discussion and we get input from our webinars speakers.

Thanks to everyone who attended and to everyone who takes a look at the on-demand version of the webinar and additional content linked above.

Cindi Delany, DVM

Maddie's Million Pet Challenge

Director of Online Learning

at UC Davis Koret Shelter Medicine Program

#AccesstoCare
#LawsandPublicPolicy
#OrganizationalManagement

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA
------------------------------

WEBINAR Q&A - Question #3 - DEA Licenses/Registration

QUESTION:  - re DEA Registrant vs non-Registrant DVMs

If we have relief dvm working when registrant is not present, can they dispense controlled drugs (ie send home buprenex) post op etc

 I think you said a DVM not holding the DEA license cannot prescribe control drugs and I'm unclear how prescribing is defined in the shelter context. I usually think of prescribing in private practice as ordering meds that will go home with pet. does prescribing in shelter that include ordering a control drug for administration for an animal that remains in the shelter (i.e simbadol q 24 hr x 3 days post-op) when DVM will may not be on site for those days (but RVT or assistant with controlled drug license will be on site and administering)

ANSWER:

In the webinar we discussed this point:

A non-DEA registrant DEA can dispense and administer meds Rx'ed by the DEA registrant DVM.  They may not "prescribe" controlled drugs themselves if they don't have their own DEA registration.

In order to clarify what DVMs in a shelter can do who do not have their own DEA registration at the shelter's location (part-time DVMs, other DVMs besides the DEA registration holder, relief DVMs, etc.)  we did some research into the specifics of what is considered "prescribing" by the DEA in this context and also got input from the CVMA (CA Vet Med Association's) Director of Regulatory Affairs.

From the DEA's Website - Practitioner's Manual:

Registration Exemption of Agents and Employees   Individual practitioners who are agents or employees of another practitioner (other than a mid-level practitioner defined under 21 CFR 1300.01), who are registered to dispense controlled substances, may administer or dispense controlled substances under the registration of the employer or principal practitioner in lieu of being registered themselves, and only if authorized or permitted to do so by the jurisdiction where the practice is located.  However, this exemption does not extend to prescribing controlled substances.  21 CFR 1301.22 (b).

RESOURCE:  https://www.deadiversion.usdoj.gov/GDP/(DEA-DC-071)(EO-DEA226)_Practitioner's_Manual_(final).pdf

We were able to further clarify that in this context the DEA is referring to "prescribing" as writing a prescription for controlled drugs for an animal's owner or agent for outside the shelter use for that specific animal.

From the CVMA:

In veterinary practices, any drug (including a controlled substance) is administered when it is used "in house" from the hospital stock for procedures and treatments performed on a patient.  Drugs are dispensed when a veterinarian sends a client home with a supply to use from the hospital stock.

Medications or devices are prescribed when a veterinarian gives a  written authorization to a client to be filled at a third party pharmacy, or when a veterinarian provides oral instructions directly to a third party pharmacy on a patient's behalf. It is unlawful to write a prescription to obtain stock.  Prescriptions are orders for individual patients only.  Controlled drug prescriptions must be completed according to specific regulations.  To view them, visit: http://www.cvma.net/ doc.asp?id=2387&pid=20091. 

While it is acceptable for only one veterinarian in a practice to have a DEA number, the CVMA recommends that each veterinarian have his or her own DEA registration number because in California, clients have a legal right to request a written prescription in lieu of dispensed medication (Business and Professions Code Section 4170(a)(6).  Current law states that only the veterinarian who has established a Veterinarian-Client-Patient relationship can prescribe for that patient.  

RESOURCE:  https://cvma-inline.net/wp-content/uploads/2015/06/DEARegistration.pdf

BOTTOM LINE:

DEA regulations permit one veterinarian to administer and dispense controlled substances that were ordered through another veterinarian's DEA registration number, but they do not permit that same veterinarian to write prescriptions using the DEA registrant's prescription pad. So, as long as you are sticking to administration and dispensation only, it is fine for the relief veterinarian/ other veterinarian to function in this capacity.  So, controlled drugs can be dispensed and administered within the shelter without the attending DVM having their own DEA registration for that location.

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

Original Message:
Sent: 10-16-2023 04:00 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

WEBINAR Q&A - Question #2 - DEA Licenses/Registration

QUESTION: 

Can Veterinarians hold multiple DEA licenses for different sites?

ANSWER:

Yes, DVMs may hold multiple DEA licenses for different locations and under the DEA's Veterinary Mobility Act of 2014 may also transport controlled drugs to a non-central practice location (such as a house call or livestock facility) in the course of the practice of veterinary medicine.

RESOURCE:  https://en.wikipedia.org/wiki/Veterinary_Medicine_Mobility_Act_of_2014

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

Original Message:
Sent: 10-16-2023 03:57 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

WEBINAR Q&A - Question #1

QUESTION: 

Is the Premises Permit specific to CA?

ANSWER:

All or most states have their own veterinary medicine boards that would issue premises permits or the equivalent.

Check with your local veterinary medical board as well as lawyers familiar with the process if you are not in the state of California, to determine what type of premises permit or other requirement must be met to practice veterinary medicine in a shelter in your state.

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA

Original Message:
Sent: 10-16-2023 03:51 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

Last Wednesday, 10/11/23, we took a deep dive into decoding DEA controlled drug regulations and premises permits (with a specific look at California-specific regs).

Both the recorded webinar and an on-demand course are available now on Maddie's University.

MMPC Learniverse – Decoding Compliance: What You Need to Know about Controlled Drugs and Premises Permits in Your Shelter - Legal Considerations with Shelter PALS

During the webinar we had LOTS of great questions and we promised to grab the questions and share answers and references here on Maddie's Pet Forum.

I'll start adding those questions and answers to this thread.

Please add any additional questions you have to this discussion and we get input from our webinars speakers.

Thanks to everyone who attended and to everyone who takes a look at the on-demand version of the webinar and additional content linked above.

Cindi Delany, DVM

Maddie's Million Pet Challenge

Director of Online Learning

at UC Davis Koret Shelter Medicine Program

#AccesstoCare
#LawsandPublicPolicy
#OrganizationalManagement

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA
------------------------------

WEBINAR Q&A - Question #4 - DEA Controlled Drug Storage

In the webinar we discussed DEA guidance on storing Schedule 2 drugs separate from Schedules 3-5 and keeping controlled drugs in a double-locked cabinet attached to a wall or the floor.

QUESTIONS:

Is the DEA license holder allowed to carry two keys?

Do we effectively need 4 lock boxes in order to keep schedule 2 separate from everything else, and working or open bottles separate from closed bottles?

Do you need to keep drugs locked up in a two lock system? in a safe, behind locked doors?

ANSWERS:

KEYS:

It is recommended that no individual carry both of the keys for the double-locked controlled drug storage safe. Many shelters have their controlled drug keys stored in combination lock boxes near the controlled drug storage area.

DOUBLE LOCKED:

The recommendation is a separate double-locked box for Schedule 2, and another for Schedules 3-5.  Open and closed containers generally can be stored together, just need to be logged on those 2 logs - unopened log for bottles/boxes not yet in use, opened log for bottles/boxes in use.   The guidance is for a double-locked safe that is attached to the floor or wall.

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

Original Message:
Sent: 10-16-2023 04:11 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

WEBINAR Q&A - Question #3 - DEA Licenses/Registration

QUESTION:  - re DEA Registrant vs non-Registrant DVMs

If we have relief dvm working when registrant is not present, can they dispense controlled drugs (ie send home buprenex) post op etc

 I think you said a DVM not holding the DEA license cannot prescribe control drugs and I'm unclear how prescribing is defined in the shelter context. I usually think of prescribing in private practice as ordering meds that will go home with pet. does prescribing in shelter that include ordering a control drug for administration for an animal that remains in the shelter (i.e simbadol q 24 hr x 3 days post-op) when DVM will may not be on site for those days (but RVT or assistant with controlled drug license will be on site and administering)

ANSWER:

In the webinar we discussed this point:

A non-DEA registrant DEA can dispense and administer meds Rx'ed by the DEA registrant DVM.  They may not "prescribe" controlled drugs themselves if they don't have their own DEA registration.

In order to clarify what DVMs in a shelter can do who do not have their own DEA registration at the shelter's location (part-time DVMs, other DVMs besides the DEA registration holder, relief DVMs, etc.)  we did some research into the specifics of what is considered "prescribing" by the DEA in this context and also got input from the CVMA (CA Vet Med Association's) Director of Regulatory Affairs.

From the DEA's Website - Practitioner's Manual:

Registration Exemption of Agents and Employees   Individual practitioners who are agents or employees of another practitioner (other than a mid-level practitioner defined under 21 CFR 1300.01), who are registered to dispense controlled substances, may administer or dispense controlled substances under the registration of the employer or principal practitioner in lieu of being registered themselves, and only if authorized or permitted to do so by the jurisdiction where the practice is located.  However, this exemption does not extend to prescribing controlled substances.  21 CFR 1301.22 (b).

RESOURCE:  https://www.deadiversion.usdoj.gov/GDP/(DEA-DC-071)(EO-DEA226)_Practitioner's_Manual_(final).pdf

We were able to further clarify that in this context the DEA is referring to "prescribing" as writing a prescription for controlled drugs for an animal's owner or agent for outside the shelter use for that specific animal.

From the CVMA:

In veterinary practices, any drug (including a controlled substance) is administered when it is used "in house" from the hospital stock for procedures and treatments performed on a patient.  Drugs are dispensed when a veterinarian sends a client home with a supply to use from the hospital stock.

Medications or devices are prescribed when a veterinarian gives a  written authorization to a client to be filled at a third party pharmacy, or when a veterinarian provides oral instructions directly to a third party pharmacy on a patient's behalf. It is unlawful to write a prescription to obtain stock.  Prescriptions are orders for individual patients only.  Controlled drug prescriptions must be completed according to specific regulations.  To view them, visit: http://www.cvma.net/ doc.asp?id=2387&pid=20091. 

While it is acceptable for only one veterinarian in a practice to have a DEA number, the CVMA recommends that each veterinarian have his or her own DEA registration number because in California, clients have a legal right to request a written prescription in lieu of dispensed medication (Business and Professions Code Section 4170(a)(6).  Current law states that only the veterinarian who has established a Veterinarian-Client-Patient relationship can prescribe for that patient.  

RESOURCE:  https://cvma-inline.net/wp-content/uploads/2015/06/DEARegistration.pdf

BOTTOM LINE:

DEA regulations permit one veterinarian to administer and dispense controlled substances that were ordered through another veterinarian's DEA registration number, but they do not permit that same veterinarian to write prescriptions using the DEA registrant's prescription pad. So, as long as you are sticking to administration and dispensation only, it is fine for the relief veterinarian/ other veterinarian to function in this capacity.  So, controlled drugs can be dispensed and administered within the shelter without the attending DVM having their own DEA registration for that location.

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

Original Message:
Sent: 10-16-2023 04:00 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

WEBINAR Q&A - Question #2 - DEA Licenses/Registration

QUESTION: 

Can Veterinarians hold multiple DEA licenses for different sites?

ANSWER:

Yes, DVMs may hold multiple DEA licenses for different locations and under the DEA's Veterinary Mobility Act of 2014 may also transport controlled drugs to a non-central practice location (such as a house call or livestock facility) in the course of the practice of veterinary medicine.

RESOURCE:  https://en.wikipedia.org/wiki/Veterinary_Medicine_Mobility_Act_of_2014

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

Original Message:
Sent: 10-16-2023 03:57 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

WEBINAR Q&A - Question #1

QUESTION: 

Is the Premises Permit specific to CA?

ANSWER:

All or most states have their own veterinary medicine boards that would issue premises permits or the equivalent.

Check with your local veterinary medical board as well as lawyers familiar with the process if you are not in the state of California, to determine what type of premises permit or other requirement must be met to practice veterinary medicine in a shelter in your state.

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA

Original Message:
Sent: 10-16-2023 03:51 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

Last Wednesday, 10/11/23, we took a deep dive into decoding DEA controlled drug regulations and premises permits (with a specific look at California-specific regs).

Both the recorded webinar and an on-demand course are available now on Maddie's University.

MMPC Learniverse – Decoding Compliance: What You Need to Know about Controlled Drugs and Premises Permits in Your Shelter - Legal Considerations with Shelter PALS

During the webinar we had LOTS of great questions and we promised to grab the questions and share answers and references here on Maddie's Pet Forum.

I'll start adding those questions and answers to this thread.

Please add any additional questions you have to this discussion and we get input from our webinars speakers.

Thanks to everyone who attended and to everyone who takes a look at the on-demand version of the webinar and additional content linked above.

Cindi Delany, DVM

Maddie's Million Pet Challenge

Director of Online Learning

at UC Davis Koret Shelter Medicine Program

#AccesstoCare
#LawsandPublicPolicy
#OrganizationalManagement

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA
------------------------------

WEBINAR Q&A - Question #5 - CONTROLLED DRUG AND BOTTLE DISPOSAL

In the webinar we discussed that shelters should not accept donations of controlled drugs.

QUESTION:

What do we do with the donated controlled drugs if we unfortunately end up with them? IE - if someone throws them in the donation bin?

ANSWER:

Once the drugs are in the hands of a DEA registrant they would then need to use a reverse distributor for disposal vs an end user drug take back program.

QUESTION:

Does anyone know of any agencies other than Far West for reverse disposal?

ANSWER:

See this resource for more information:  https://www.federalregister.gov/documents/2014/09/09/2014-20926/disposal-of-controlled-substances

QUESTION:

Can you clarify how we are supposed to throw away empty bottles of controlled drugs? Can it not go in the regular trash?

ANSWER:

It is recommended that empty bottles be disposed of in a sharps container collected by an authorized sharps container pick-up company.

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

Original Message:
Sent: 10-16-2023 03:51 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

Last Wednesday, 10/11/23, we took a deep dive into decoding DEA controlled drug regulations and premises permits (with a specific look at California-specific regs).

Both the recorded webinar and an on-demand course are available now on Maddie's University.

MMPC Learniverse – Decoding Compliance: What You Need to Know about Controlled Drugs and Premises Permits in Your Shelter - Legal Considerations with Shelter PALS

During the webinar we had LOTS of great questions and we promised to grab the questions and share answers and references here on Maddie's Pet Forum.

I'll start adding those questions and answers to this thread.

Please add any additional questions you have to this discussion and we get input from our webinars speakers.

Thanks to everyone who attended and to everyone who takes a look at the on-demand version of the webinar and additional content linked above.

Cindi Delany, DVM

Maddie's Million Pet Challenge

Director of Online Learning

at UC Davis Koret Shelter Medicine Program

#AccesstoCare
#LawsandPublicPolicy
#OrganizationalManagement

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA
------------------------------

WEBINAR Q&A - Question #6 - Controlled Drug Transfers

QUESTION: 

Can a controlled drug be transferred from one shelter to another (and paid back) if needed?

Can a veterinarian transfer controlled substances to another veterinarian?

ANSWER:

Yes, controlled drugs can be transferred from 1 DEA registrant to another.  There is a specific form for this to make this transaction legitimate.  This would apply between shelters, between private practices, and also from one to the other, as long as there is a DEA registrant at both.

The requirements for this type of transfer include:

• Both are properly registered with the DEA.
• Transfers for CIII-V controlled drugs may be made via an invoice and should appear in the drug logs of both practitioners as to where the drugs went and where they came from. 
• The invoice should include the names, contact information and DEA registration numbers of the shipper and receiver, the name, strength, quantity, form and schedule of the controlled substance being transferred and the date of the transfer, along with the date and quantity transferred.
• Transfers for CII controlled drugs must in addition to invoice, be accompanied by a DEA 222 Form issued by the receiving practitioner. 
• Transfers should be limited to no more than 10% of the practitioner's normal volume of the normal drug inventory. 

REFERENCE:  https://www.vmb.ca.gov/enforcement/controlled_subs.shtml#:~:text=Transfers%20for%20CII%20controlled%20drugs,of%20the%20normal%20drug%20inventory.

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

Original Message:
Sent: 10-16-2023 03:51 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

Last Wednesday, 10/11/23, we took a deep dive into decoding DEA controlled drug regulations and premises permits (with a specific look at California-specific regs).

Both the recorded webinar and an on-demand course are available now on Maddie's University.

MMPC Learniverse – Decoding Compliance: What You Need to Know about Controlled Drugs and Premises Permits in Your Shelter - Legal Considerations with Shelter PALS

During the webinar we had LOTS of great questions and we promised to grab the questions and share answers and references here on Maddie's Pet Forum.

I'll start adding those questions and answers to this thread.

Please add any additional questions you have to this discussion and we get input from our webinars speakers.

Thanks to everyone who attended and to everyone who takes a look at the on-demand version of the webinar and additional content linked above.

Cindi Delany, DVM

Maddie's Million Pet Challenge

Director of Online Learning

at UC Davis Koret Shelter Medicine Program

#AccesstoCare
#LawsandPublicPolicy
#OrganizationalManagement

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA
------------------------------

WEBINAR Q&A - Question #7 - Rabies Vaccination and Signature Requirements in California

QUESTION: 

The Vet does not have to sign the Rabies Cert?  Can you point to the code for that?

If SB 669 passes, does this includes Rabies?

If a signature isn't required how does that affect International Health Certificates?

Can shelter staff in all states now be able to administer rabies vacc, or just in California?

Can shelter staff administer rabies vaccine if the veterinarian is not on site?

ANSWER:

Who can give Rabies vaccination in CA shelters:

This information is specific to CA - please just with your regular VMB if in another state:

Any trained shelter staff member (who become "unregistered assistants" with the training provided for the duties they are assigned) may give Rabies vaccination under direct or indirect supervision of a DVM in the state of CA.  This means trained staff can administer Rabies vaccination in the shelter setting without a DVM or RVT on-site.   Other states may need to research for specifics of this.

A California licensed veterinarian can administer the rabies vaccine or can delegate the administration of the rabies vaccine, to either a Registered Veterinary Technician (RVT) or unregistered assistant. A RVT and/or unregistered assistant can administer the rabies vaccination under either direct or indirect supervision of the California licensed veterinarian. The veterinarian may delegate supervision of the rabies vaccination administration to a California RVT, but, in that instance, when administering the rabies vaccination, the unregistered assistant must be working under direct supervision of the California RVT. The levels of supervision are governed by the requirements of the California Code of Regulations, sections 2034 through 2036.5. For additional information regarding rabies requirements, please contact Department of Health Services, Veterinary Public Health Unit.

RESOURCE:  https://www.vmb.ca.gov/consumers/faqs.shtml

Who must sign Rabies certificate in CA?

DVM may sign or he/she may authorize another signature in their place.  This means an RVT, VA or other designee could sign on behalf of the DMV if authorized by the DVM.

Such certificates shall bear the signature of the veterinarian administering the vaccine or a signature authorized by him, and in addition such certificate shall be stamped, printed, or typed with his name, address and telephone number for legibility, with the exception that at dog vaccination clinics conducted pursuant to section 121690(f) of the Health and Safety Code, vaccination certificates approved by the local health officer may be used provided that the specific clinic is identified upon the vaccination certificate and records are maintained containing the information specified under items (E) and (F) above.

RESOURCE:  https://govt.westlaw.com/calregs/Document/IA68A56635A2011EC8227000D3A7C4BC3?originationContext=document&transitionType=StatuteNavigator&needToInjectTerms=False&viewType=FullText&ppcid=30220c3e4b564b59943ac30ac74a9583&t_T1=17&t_S1=CA%20ADC%20s&contextData=%28sc.Default%29

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

Original Message:
Sent: 10-16-2023 03:51 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

Last Wednesday, 10/11/23, we took a deep dive into decoding DEA controlled drug regulations and premises permits (with a specific look at California-specific regs).

Both the recorded webinar and an on-demand course are available now on Maddie's University.

MMPC Learniverse – Decoding Compliance: What You Need to Know about Controlled Drugs and Premises Permits in Your Shelter - Legal Considerations with Shelter PALS

During the webinar we had LOTS of great questions and we promised to grab the questions and share answers and references here on Maddie's Pet Forum.

I'll start adding those questions and answers to this thread.

Please add any additional questions you have to this discussion and we get input from our webinars speakers.

Thanks to everyone who attended and to everyone who takes a look at the on-demand version of the webinar and additional content linked above.

Cindi Delany, DVM

Maddie's Million Pet Challenge

Director of Online Learning

at UC Davis Koret Shelter Medicine Program

#AccesstoCare
#LawsandPublicPolicy
#OrganizationalManagement

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA
------------------------------

WEBINAR Q&A - Question #8 - RE:  Compounding of Anesthetic Mixtures

QUESTION: 

It is illegal to mix the drugs for multiple doses, correct?

Is it clearly legal now to mix "kitty magic" in a bottle - I thought that was considered compounding still. 

Is it illegal to mix drugs for multi use doses?  I understood we could only combine for single dose use

If you mix controlled drugs (i.e. Telazol-Butorphanol-Dexmedetomidine), what are the specific requirements for logging/recording these drugs?

ANSWER - LEGALITY OF COMPOUNDING IN CA:

Veterinarians may compound drugs as described in the following resources.  As long as the compound is needed to achieve a result not otherwise easily available, it is allowed, pursuant to regulations under the Veterinary Medicine Practice Act at the cited pages.

RESOURCE:  https://www.vmb.ca.gov/laws_regs/vmb_act.pdf - pages 123-126

RESOURCE:  https://www.vmb.ca.gov/laws_regs/drug_compounding_isor.pdf

https://cvma-inline.net/wp-content/uploads/2020/02/Compounding-FAQ.pdf

ANSWER - Logging of Combination Controlled Drugs:

Each individual controlled drug should have the volume used logged out of that specific drug's open bottle log (and logged to the new combination bottle) and a separate log for the new combination can be created to log out amounts used for individual patients.  

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

Original Message:
Sent: 10-16-2023 03:51 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

Last Wednesday, 10/11/23, we took a deep dive into decoding DEA controlled drug regulations and premises permits (with a specific look at California-specific regs).

Both the recorded webinar and an on-demand course are available now on Maddie's University.

MMPC Learniverse – Decoding Compliance: What You Need to Know about Controlled Drugs and Premises Permits in Your Shelter - Legal Considerations with Shelter PALS

During the webinar we had LOTS of great questions and we promised to grab the questions and share answers and references here on Maddie's Pet Forum.

I'll start adding those questions and answers to this thread.

Please add any additional questions you have to this discussion and we get input from our webinars speakers.

Thanks to everyone who attended and to everyone who takes a look at the on-demand version of the webinar and additional content linked above.

Cindi Delany, DVM

Maddie's Million Pet Challenge

Director of Online Learning

at UC Davis Koret Shelter Medicine Program

#AccesstoCare
#LawsandPublicPolicy
#OrganizationalManagement

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA
------------------------------

WEBINAR Q&A - Question #9 

QUESTION: 

How California-specific is the information in this webinar?

ANSWER:

In the webinar, we covered general/national DEA regulations and also discussed some California Veterinary Medical Board-specific info on California-specific Premises Permits and requirements like the CET and VACSP requirements (also both California-specific) in regard to administering and obtaining controlled drugs in California. The California-specific information we covered might apply to some degree to other states but you'll definitely want to follow up with your own VMB and/or lawyers for any areas that do vary.

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

Original Message:
Sent: 10-16-2023 03:51 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

Last Wednesday, 10/11/23, we took a deep dive into decoding DEA controlled drug regulations and premises permits (with a specific look at California-specific regs).

Both the recorded webinar and an on-demand course are available now on Maddie's University.

MMPC Learniverse – Decoding Compliance: What You Need to Know about Controlled Drugs and Premises Permits in Your Shelter - Legal Considerations with Shelter PALS

During the webinar we had LOTS of great questions and we promised to grab the questions and share answers and references here on Maddie's Pet Forum.

I'll start adding those questions and answers to this thread.

Please add any additional questions you have to this discussion and we get input from our webinars speakers.

Thanks to everyone who attended and to everyone who takes a look at the on-demand version of the webinar and additional content linked above.

Cindi Delany, DVM

Maddie's Million Pet Challenge

Director of Online Learning

at UC Davis Koret Shelter Medicine Program

#AccesstoCare
#LawsandPublicPolicy
#OrganizationalManagement

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA
------------------------------

WEBINAR Q&A - Question #10

QUESTION: 

How do the DEA and California VMB regulations regarding Controlled Drugs affect field officers?

ANSWER:

Field officers are able to use controlled drugs for tranquilizing animals in the field as described in California Penal Code section 597.1(a)(2)(A)-(E) and 16 Cal. Code Regs. section 2039.5.

Field officers who have completed CET (Certified Euthanasia Technician) training are permitted to euthanize in the field in accordance with that training.

REF:  https://codes.findlaw.com/ca/penal-code/pen-sect-597-1/

(2) Notwithstanding any other law, if an animal control officer or humane officer, when necessary to protect the health and safety of a wild, stray, or abandoned animal or the health and safety of others, seeks to administer a tranquilizer that contains a controlled substance, as defined in Division 10 (commencing with Section 11000) of the Health and Safety Code, to gain control of that animal, the officer may possess and administer that tranquilizer with direct or indirect supervision as determined by a licensed veterinarian, provided that the officer has met each of the following requirements:

(A) Has received training in the administration of tranquilizers from a licensed veterinarian. The training shall be approved by the California Veterinary Medical Board.

(B) Has successfully completed the firearms component of a course relating to the exercise of police powers, as set forth in Section 832.

(C) Is authorized by the officer's agency or organization to possess and administer the tranquilizer in accordance with a policy established by the agency or organization and approved by the veterinarian who obtained the controlled substance.

(D) Has successfully completed the euthanasia training set forth in Section 2039 of Title 16 of the California Code of Regulations.

(E) Has completed a state and federal fingerprinting background check and does not have any drug- or alcohol-related convictions.

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

Original Message:
Sent: 10-16-2023 03:51 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

Last Wednesday, 10/11/23, we took a deep dive into decoding DEA controlled drug regulations and premises permits (with a specific look at California-specific regs).

Both the recorded webinar and an on-demand course are available now on Maddie's University.

MMPC Learniverse – Decoding Compliance: What You Need to Know about Controlled Drugs and Premises Permits in Your Shelter - Legal Considerations with Shelter PALS

During the webinar we had LOTS of great questions and we promised to grab the questions and share answers and references here on Maddie's Pet Forum.

I'll start adding those questions and answers to this thread.

Please add any additional questions you have to this discussion and we get input from our webinars speakers.

Thanks to everyone who attended and to everyone who takes a look at the on-demand version of the webinar and additional content linked above.

Cindi Delany, DVM

Maddie's Million Pet Challenge

Director of Online Learning

at UC Davis Koret Shelter Medicine Program

#AccesstoCare
#LawsandPublicPolicy
#OrganizationalManagement

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA
------------------------------

WEBINAR Q&A - Question #11

QUESTION: 

If animal control officers carry in-field euthanasia solution, their managing DVM/RVT would need to have the mobile component to their DEA, is this correct?

ANSWER:

The use of controlled drugs in the filed in this context would be covered by the information above and by the Veterinary Mobility Act.  So, no separate mobile premises permit should be required.

It is recommended that controlled drugs in the field be secured in a double-locked box attached to the vehicle.

RESOURCE:  https://en.wikipedia.org/wiki/Veterinary_Medicine_Mobility_Act_of_2014

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

Original Message:
Sent: 10-16-2023 03:51 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

Last Wednesday, 10/11/23, we took a deep dive into decoding DEA controlled drug regulations and premises permits (with a specific look at California-specific regs).

Both the recorded webinar and an on-demand course are available now on Maddie's University.

MMPC Learniverse – Decoding Compliance: What You Need to Know about Controlled Drugs and Premises Permits in Your Shelter - Legal Considerations with Shelter PALS

During the webinar we had LOTS of great questions and we promised to grab the questions and share answers and references here on Maddie's Pet Forum.

I'll start adding those questions and answers to this thread.

Please add any additional questions you have to this discussion and we get input from our webinars speakers.

Thanks to everyone who attended and to everyone who takes a look at the on-demand version of the webinar and additional content linked above.

Cindi Delany, DVM

Maddie's Million Pet Challenge

Director of Online Learning

at UC Davis Koret Shelter Medicine Program

#AccesstoCare
#LawsandPublicPolicy
#OrganizationalManagement

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA
------------------------------

WEBINAR Q&A - Question #12

QUESTION: 

Certified Euthanasia Technicians (CETs) and Veterinary Assistant Controlled Substances Permit (VACSP).

What can CETs and VACSPs do and not do in California?

ANSWER:

CET's are individuals who have completed an 8 hour euthanasia training program.  They are allowed to dispense and administer the drug, Sodium Pentobarbital ONLY, in performing euthanasia.

VACSPs are individuals in California who have a current VACSP Permit.  They are allowed to dispense and administer controlled drugs in the shelter setting following the prescription of a DEA registrant DVM.

A single individual can (and in most cases should) hold both a CET and VACSP to be allowed to perform both euthanasia with sodium pentobarbital and administration of controlled drugs for any prescribed purpose in the shelter setting.

Specific Questions on this topic and short answers below:

Q:  Do CETs require a DVM on-site to euthanize or can they do it themselves alone? I'm in NY, so CA regulations may not be the same.

A:  In CA individuals who are a CET may euthanize without a DVM present on-site following their shelter's protocols for this procedure.  For animals within the holding period there are certain exceptions to euthanasia in general (irremediably suffering, unweaned and without maternal support, documented by authorities as dangerous/vicious)l, unrelated to who is doing the euthanasia.

If you are not in California we recommend you check your own states laws for further information.

Q1:  However if they have their permit the CET would be able to give the sedation / anesthesia under the supervision of the veterinarian, yes?

Q2:  Can a CET administer controlled drugs for euthanasia sedation without a VACSP?

Q3:  Can a CET administer controlled drugs if a DVM prescribes it and is on-site?

Q4:  Regarding CETs administering sodium pentobarbital. They can open a lock box with one open bottle to draw up the drug and administer with approval from their vet?

Q5:  Do CET also need VACSP?

Q6:  Following up in the field would we not be beholden to the rule that anything beyond euthanasia solution would require an RVT or VCSP.  So CET would not be sufficient for Telazol?

SUMMARY ANSWER:

In CA, in shelters with a premises permit, CETs who are not VACSP holders (and not RVTs or field officers) are only authorized to administer pentobarbital.  In order to administer other controlled drugs in the shelter setting non RVT, non DVM shelter staff would need to have a VACSP and those other drugs would need to be prescribed by a DEA registrant DVM.

See question #10 about field officer use of controlled drugs in the field under specific conditions.

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

Original Message:
Sent: 10-16-2023 03:51 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

Last Wednesday, 10/11/23, we took a deep dive into decoding DEA controlled drug regulations and premises permits (with a specific look at California-specific regs).

Both the recorded webinar and an on-demand course are available now on Maddie's University.

MMPC Learniverse – Decoding Compliance: What You Need to Know about Controlled Drugs and Premises Permits in Your Shelter - Legal Considerations with Shelter PALS

During the webinar we had LOTS of great questions and we promised to grab the questions and share answers and references here on Maddie's Pet Forum.

I'll start adding those questions and answers to this thread.

Please add any additional questions you have to this discussion and we get input from our webinars speakers.

Thanks to everyone who attended and to everyone who takes a look at the on-demand version of the webinar and additional content linked above.

Cindi Delany, DVM

Maddie's Million Pet Challenge

Director of Online Learning

at UC Davis Koret Shelter Medicine Program

#AccesstoCare
#LawsandPublicPolicy
#OrganizationalManagement

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA
------------------------------

Hi - sorry to circle back to this again, but wanted to ask what Bruce meant at the 29-minute mark of the webinar "...and that sedative is not authorized to be given by the CET, or - let me take that back - if they can give it, but it has to be prescribed by a veterinarian..." - so, if a veterinarian (specifically the DEA-licensed DVM) prescribes the sedative for euthanasia, say having a standing order of a certain mg/kg of Telazol IM PRN for (any) euthanasia, would this enable the CET to give the sedative? Or if the DEA-vet prescribes the sedative specifically for that patient, but is not in the room (how "indirect" is indirect supervision?) Or are CETs not allowed to handle any controlled substance other than sodium pentobarbital, ever, period? (I thought there was some link made between clients being able to administer DEA-DVM-prescribed controlled substances at home and shelter employees being able to do something similar in the shelter since the DEA-DVM prescribed it and is at least "indirectly" supervising, though I might have made that up since technically they aren't the owner)

------------------------------
Joanne Lin
staff veterinarian
Peninsula Humane Society & SPCA
CA
------------------------------

Original Message:
Sent: 10-16-2023 04:54 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

WEBINAR Q&A - Question #12

QUESTION: 

Certified Euthanasia Technicians (CETs) and Veterinary Assistant Controlled Substances Permit (VACSP).

What can CETs and VACSPs do and not do in California?

ANSWER:

CET's are individuals who have completed an 8 hour euthanasia training program.  They are allowed to dispense and administer the drug, Sodium Pentobarbital ONLY, in performing euthanasia.

VACSPs are individuals in California who have a current VACSP Permit.  They are allowed to dispense and administer controlled drugs in the shelter setting following the prescription of a DEA registrant DVM.

A single individual can (and in most cases should) hold both a CET and VACSP to be allowed to perform both euthanasia with sodium pentobarbital and administration of controlled drugs for any prescribed purpose in the shelter setting.

Specific Questions on this topic and short answers below:

Q:  Do CETs require a DVM on-site to euthanize or can they do it themselves alone? I'm in NY, so CA regulations may not be the same.

A:  In CA individuals who are a CET may euthanize without a DVM present on-site following their shelter's protocols for this procedure.  For animals within the holding period there are certain exceptions to euthanasia in general (irremediably suffering, unweaned and without maternal support, documented by authorities as dangerous/vicious)l, unrelated to who is doing the euthanasia.

If you are not in California we recommend you check your own states laws for further information.

Q1:  However if they have their permit the CET would be able to give the sedation / anesthesia under the supervision of the veterinarian, yes?

Q2:  Can a CET administer controlled drugs for euthanasia sedation without a VACSP?

Q3:  Can a CET administer controlled drugs if a DVM prescribes it and is on-site?

Q4:  Regarding CETs administering sodium pentobarbital. They can open a lock box with one open bottle to draw up the drug and administer with approval from their vet?

Q5:  Do CET also need VACSP?

Q6:  Following up in the field would we not be beholden to the rule that anything beyond euthanasia solution would require an RVT or VCSP.  So CET would not be sufficient for Telazol?

SUMMARY ANSWER:

In CA, in shelters with a premises permit, CETs who are not VACSP holders (and not RVTs or field officers) are only authorized to administer pentobarbital.  In order to administer other controlled drugs in the shelter setting non RVT, non DVM shelter staff would need to have a VACSP and those other drugs would need to be prescribed by a DEA registrant DVM.

See question #10 about field officer use of controlled drugs in the field under specific conditions.

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

Original Message:
Sent: 10-16-2023 03:51 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

Last Wednesday, 10/11/23, we took a deep dive into decoding DEA controlled drug regulations and premises permits (with a specific look at California-specific regs).

Both the recorded webinar and an on-demand course are available now on Maddie's University.

MMPC Learniverse – Decoding Compliance: What You Need to Know about Controlled Drugs and Premises Permits in Your Shelter - Legal Considerations with Shelter PALS

During the webinar we had LOTS of great questions and we promised to grab the questions and share answers and references here on Maddie's Pet Forum.

I'll start adding those questions and answers to this thread.

Please add any additional questions you have to this discussion and we get input from our webinars speakers.

Thanks to everyone who attended and to everyone who takes a look at the on-demand version of the webinar and additional content linked above.

Cindi Delany, DVM

Maddie's Million Pet Challenge

Director of Online Learning

at UC Davis Koret Shelter Medicine Program

#AccesstoCare
#LawsandPublicPolicy
#OrganizationalManagement

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA
------------------------------

Hi Joanne,

This is confusing stuff.  Basically, the training and certification a CET receives ONLY allows them to administer pentobarbital for the purposes of euthanasia in California shelters.  That is the ONLY controlled drug just having a CET allows them to administer. 

Note that in states where oral Pentobarbital is not prohibited (which given references to human physician assisted suicide it does not appear to be  prohibited in CA)  it can be given as a pre-euthanasia sedative orally (but it does have a bitter taste and should be followed by IV injection once appropriate sedation is seen).  See page 30 of this reference:  https://humanepro.org/sites/default/files/documents/euthanasia-reference-manual.pdf

In order for any non-DVM or non-RVT to administer any other controlled drug (other than Pentobarbital) in a CA shelter that is operating with a VMB Premises Permit the California Veterinary Medicine Board now requires those individuals to hold a VACSP.  The VACSP requirement is a relatively newer thing (went into effect in 2016).   

So, at this time for a CET to be able to administer any other controlled drug (other than Pentobarbital) in the shelter setting they would ALSO need to have a VACSP.   Take a look at this FAQ page on the CA VMB website for some more info.  https://vmb.ca.gov/applicants/vacsp_faq.shtml

From that FAQ also VACSP's can administer controlled drugs under "indirect" supervision of a DVM.  

"Provisions of the VACSP permit do allow a permit holder to obtain or administer controlled substances under the indirect supervision of a licensed Veterinarian."

The best recommendation would be to ensure that enough of your staff hold a VACSP that you are able to administer controlled drugs in your shelter for all needs - animals on controlled drugs for pain/anxiety/seizures/etc. and for pre-euthanasia purposes.

For CA VMB definitions/guidance on direct vs indirect supervision check this page where this is stated:  https://www.vmb.ca.gov/applicants/vet_office_staff.shtml

"Tip: Direct supervision means the DVM is present and is quickly available where the animal healthcare task is being performed. Indirect supervision means the DVM is not present, but has given instructions for the animal's care."

I hope this is helpful.  One of the reasons a lot of this information is a little difficult to weed through is because most CA VMB guidance is aimed at veterinary clinics, not specifically addressing the shelter setting.   That means we need to spend some time reviewing the guidance and regulations out there and do our best to interpret for the shelter setting where there is any lack of specific direction and clarity for our situations in shelters.

As an aside, in CA shelters we do consider the use of written protocols - created by a CA licensed DVM - to be an acceptable practice.

I hope this is helpful.  If I hear any additional or different information I'll update my response.

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: 10-24-2023 10:03 PM
From: Joanne Lin
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

Hi - sorry to circle back to this again, but wanted to ask what Bruce meant at the 29-minute mark of the webinar "...and that sedative is not authorized to be given by the CET, or - let me take that back - if they can give it, but it has to be prescribed by a veterinarian..." - so, if a veterinarian (specifically the DEA-licensed DVM) prescribes the sedative for euthanasia, say having a standing order of a certain mg/kg of Telazol IM PRN for (any) euthanasia, would this enable the CET to give the sedative? Or if the DEA-vet prescribes the sedative specifically for that patient, but is not in the room (how "indirect" is indirect supervision?) Or are CETs not allowed to handle any controlled substance other than sodium pentobarbital, ever, period? (I thought there was some link made between clients being able to administer DEA-DVM-prescribed controlled substances at home and shelter employees being able to do something similar in the shelter since the DEA-DVM prescribed it and is at least "indirectly" supervising, though I might have made that up since technically they aren't the owner)

------------------------------
Joanne Lin
staff veterinarian
Peninsula Humane Society & SPCA
CA

Original Message:
Sent: 10-16-2023 04:54 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

WEBINAR Q&A - Question #12

QUESTION: 

Certified Euthanasia Technicians (CETs) and Veterinary Assistant Controlled Substances Permit (VACSP).

What can CETs and VACSPs do and not do in California?

ANSWER:

CET's are individuals who have completed an 8 hour euthanasia training program.  They are allowed to dispense and administer the drug, Sodium Pentobarbital ONLY, in performing euthanasia.

VACSPs are individuals in California who have a current VACSP Permit.  They are allowed to dispense and administer controlled drugs in the shelter setting following the prescription of a DEA registrant DVM.

A single individual can (and in most cases should) hold both a CET and VACSP to be allowed to perform both euthanasia with sodium pentobarbital and administration of controlled drugs for any prescribed purpose in the shelter setting.

Specific Questions on this topic and short answers below:

Q:  Do CETs require a DVM on-site to euthanize or can they do it themselves alone? I'm in NY, so CA regulations may not be the same.

A:  In CA individuals who are a CET may euthanize without a DVM present on-site following their shelter's protocols for this procedure.  For animals within the holding period there are certain exceptions to euthanasia in general (irremediably suffering, unweaned and without maternal support, documented by authorities as dangerous/vicious)l, unrelated to who is doing the euthanasia.

If you are not in California we recommend you check your own states laws for further information.

Q1:  However if they have their permit the CET would be able to give the sedation / anesthesia under the supervision of the veterinarian, yes?

Q2:  Can a CET administer controlled drugs for euthanasia sedation without a VACSP?

Q3:  Can a CET administer controlled drugs if a DVM prescribes it and is on-site?

Q4:  Regarding CETs administering sodium pentobarbital. They can open a lock box with one open bottle to draw up the drug and administer with approval from their vet?

Q5:  Do CET also need VACSP?

Q6:  Following up in the field would we not be beholden to the rule that anything beyond euthanasia solution would require an RVT or VCSP.  So CET would not be sufficient for Telazol?

SUMMARY ANSWER:

In CA, in shelters with a premises permit, CETs who are not VACSP holders (and not RVTs or field officers) are only authorized to administer pentobarbital.  In order to administer other controlled drugs in the shelter setting non RVT, non DVM shelter staff would need to have a VACSP and those other drugs would need to be prescribed by a DEA registrant DVM.

See question #10 about field officer use of controlled drugs in the field under specific conditions.

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

Original Message:
Sent: 10-16-2023 03:51 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

Last Wednesday, 10/11/23, we took a deep dive into decoding DEA controlled drug regulations and premises permits (with a specific look at California-specific regs).

Both the recorded webinar and an on-demand course are available now on Maddie's University.

MMPC Learniverse – Decoding Compliance: What You Need to Know about Controlled Drugs and Premises Permits in Your Shelter - Legal Considerations with Shelter PALS

During the webinar we had LOTS of great questions and we promised to grab the questions and share answers and references here on Maddie's Pet Forum.

I'll start adding those questions and answers to this thread.

Please add any additional questions you have to this discussion and we get input from our webinars speakers.

Thanks to everyone who attended and to everyone who takes a look at the on-demand version of the webinar and additional content linked above.

Cindi Delany, DVM

Maddie's Million Pet Challenge

Director of Online Learning

at UC Davis Koret Shelter Medicine Program

#AccesstoCare
#LawsandPublicPolicy
#OrganizationalManagement

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA
------------------------------

WEBINAR Q&A - Question #13

QUESTION: 

About the VACSP in CA -

Q1:  VACSP, was that obtaining/administering under direct or indirect dvm supervision?

A1:  VACSP may obtain from controlled drugs storage and administer prescribed controlled drugs under direct or indirect DVM supervision.

Q2 - all about VACSP and Name Badges

There's a requirement where we need to display the name and VCSP # on the individual's badge when they are in public spaces. This information needs to be 18 font. How are other shelters handling this?

What are the name badge requirements for staff with a vet assist control permit?

I thought there was a law about the permit number to be placed on their name tag, is this not correct?

ANSWER:

It is not required to have each VACSP have their permit number on a name badge IF you display their VACSP (the permit itself) in the hospital.  See specifics below:

RESOURCE:  https://vmb.ca.gov/applicants/vacsp_faq.shtml

https://casetext.com/regulation/california-code-of-regulations/title-16-professional-and-vocational-regulations/division-20-veterinary-medical-board/article-10-continuing-education-veterinary-technician/section-20873-display-of-veterinary-assistant-controlled-substances-permit-vacsp

Display of Veterinary Assistant Controlled Substances Permit (VACSP). (a) Every California permit holder shall wear a name tag in at least 18 point type. The name tag shall include the name that the permit holder has filed with the board and the term "VACSP Number,'' followed by the VACSP number issued to the permit holder by the board. (b) Permit holders need not wear a name tag if their VACSP is prominently displayed in an area of the animal hospital setting that is easily accessible to all members of the public at all times the premise is open. VACSPs shall not be altered in any manner nor shall any information contained on the VACSP be obscured or obliterated.

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

Original Message:
Sent: 10-16-2023 03:51 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

Last Wednesday, 10/11/23, we took a deep dive into decoding DEA controlled drug regulations and premises permits (with a specific look at California-specific regs).

Both the recorded webinar and an on-demand course are available now on Maddie's University.

MMPC Learniverse – Decoding Compliance: What You Need to Know about Controlled Drugs and Premises Permits in Your Shelter - Legal Considerations with Shelter PALS

During the webinar we had LOTS of great questions and we promised to grab the questions and share answers and references here on Maddie's Pet Forum.

I'll start adding those questions and answers to this thread.

Please add any additional questions you have to this discussion and we get input from our webinars speakers.

Thanks to everyone who attended and to everyone who takes a look at the on-demand version of the webinar and additional content linked above.

Cindi Delany, DVM

Maddie's Million Pet Challenge

Director of Online Learning

at UC Davis Koret Shelter Medicine Program

#AccesstoCare
#LawsandPublicPolicy
#OrganizationalManagement

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA
------------------------------

WEBINAR Q&A - Question #14 - California Shelters - Premises Permit Questions

Q1:  Can more than one vet hold a premise permit at a single location?

A1:  Each location in which veterinary medicine is practiced only requires a single premises permit.  

Q2: In the mobile vet situation, can the shelter hold/store non-controlled, prescription medication for when the vet comes and prescribes.  Or, must the vet hold those meds until prescribed?

A2:  Non-controlled drugs can be stored in any location.  DEA registration does not cover this area.  Premises permits cover the practice of veterinary medicine itself and has some specifics about drug storage but in general prescription medications (and non-prescription medications) including those in general supply for in-house use may be stored at the location where they will be used.

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

Original Message:
Sent: 10-16-2023 03:51 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

Last Wednesday, 10/11/23, we took a deep dive into decoding DEA controlled drug regulations and premises permits (with a specific look at California-specific regs).

Both the recorded webinar and an on-demand course are available now on Maddie's University.

MMPC Learniverse – Decoding Compliance: What You Need to Know about Controlled Drugs and Premises Permits in Your Shelter - Legal Considerations with Shelter PALS

During the webinar we had LOTS of great questions and we promised to grab the questions and share answers and references here on Maddie's Pet Forum.

I'll start adding those questions and answers to this thread.

Please add any additional questions you have to this discussion and we get input from our webinars speakers.

Thanks to everyone who attended and to everyone who takes a look at the on-demand version of the webinar and additional content linked above.

Cindi Delany, DVM

Maddie's Million Pet Challenge

Director of Online Learning

at UC Davis Koret Shelter Medicine Program

#AccesstoCare
#LawsandPublicPolicy
#OrganizationalManagement

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA
------------------------------

WEBINAR Q&A - Question #15 - Providing medical care to owner animals in shelters in CA

QUESTION: 

What happens to animals in the shelter that need medical attention but the owner has been arrested and no family to contact?

ANSWER:

In CA shelters population management health care and emergency medical care can be provided to an owned animal without making contact with the owner.  For other types of care the owner should be contacted to establish a VCPR.  

In cases of owner arrest, hospitalization or other removal of the owner from the home attempts to contact them should be made to establish a VCPR and secure approval for any non-population health and non-emergency care.

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

Original Message:
Sent: 10-16-2023 03:51 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

Last Wednesday, 10/11/23, we took a deep dive into decoding DEA controlled drug regulations and premises permits (with a specific look at California-specific regs).

Both the recorded webinar and an on-demand course are available now on Maddie's University.

MMPC Learniverse – Decoding Compliance: What You Need to Know about Controlled Drugs and Premises Permits in Your Shelter - Legal Considerations with Shelter PALS

During the webinar we had LOTS of great questions and we promised to grab the questions and share answers and references here on Maddie's Pet Forum.

I'll start adding those questions and answers to this thread.

Please add any additional questions you have to this discussion and we get input from our webinars speakers.

Thanks to everyone who attended and to everyone who takes a look at the on-demand version of the webinar and additional content linked above.

Cindi Delany, DVM

Maddie's Million Pet Challenge

Director of Online Learning

at UC Davis Koret Shelter Medicine Program

#AccesstoCare
#LawsandPublicPolicy
#OrganizationalManagement

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA
------------------------------

WEBINAR Q&A - Question #16 - California shelters WITHOUT a Premises Permit for the practice of veterinary medicine

QUESTIONS/ANSWERS: 

Q1:  How does this apply for Animal Control facilities with no Vet on staff?

A1:  See the section of this content that refers to "Non-Premises Permit" Shelters as to what can and can't be done in that setting.

Q2:  If a mobile vet with a (mobile) premise permit comes to the shelter and prescribes medications (not controlled), for staff to administer to their owned shelter pets, is it okay that the shelter does not have a premise permit?

A2:  Yes, a shelter without a premises permit may administer medications (including controlled drugs)  prescribed by a DVM (including a mobile vet).  In addition, the VACSP requirement related to controlled drugs pertains to shelters that do have a premises permit.  In addition, regulations do allow for owners of animals to administer prescribed medications - including prescribed controlled drugs.

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

Original Message:
Sent: 10-16-2023 03:51 PM
From: Cindi Delany
Subject: DEA Controlled Drug and Premises Permit Regulations - DECODED! - On-demand course available now!

Last Wednesday, 10/11/23, we took a deep dive into decoding DEA controlled drug regulations and premises permits (with a specific look at California-specific regs).

Both the recorded webinar and an on-demand course are available now on Maddie's University.

MMPC Learniverse – Decoding Compliance: What You Need to Know about Controlled Drugs and Premises Permits in Your Shelter - Legal Considerations with Shelter PALS

During the webinar we had LOTS of great questions and we promised to grab the questions and share answers and references here on Maddie's Pet Forum.

I'll start adding those questions and answers to this thread.

Please add any additional questions you have to this discussion and we get input from our webinars speakers.

Thanks to everyone who attended and to everyone who takes a look at the on-demand version of the webinar and additional content linked above.

Cindi Delany, DVM

Maddie's Million Pet Challenge

Director of Online Learning

at UC Davis Koret Shelter Medicine Program

#AccesstoCare
#LawsandPublicPolicy
#OrganizationalManagement

------------------------------
Cindi Delany
UC Davis Koret Shelter Medicine Program
Davis CA
------------------------------