R 338.4920 Safeguards for drugs used in practice of veterinary medicine: Rule 20. (1) If drugs are dispensed in the manufacturer’s original container, the original instructions shall be included. (2) If drugs are dispensed in other than the manufacturer’s original container, both of the following provisions shall apply:
Written or electronic prescriptions should contain the following details:
The actual container must bear the veterinarian's name, address, name of the drug (active ingredient), identification of the animal(s) to be treated, adequate directions for proper use, and cautions/precautions including milk and meat withdrawal times. This information may be on the label applied by the manufacturer, or on a label attached to the product by the veterinarian.
There are three main ways a client may fill any prescription written for use in their animal: from the issuing veterinarian if they keep it in stock; the veterinarian can write (or call in) a prescription to a local pharmacy that stocks the medication; the veterinarian can provide a prescription so the client can get the medication from an online pharmacy. In Michigan it is recommended that veterinary prescription drugs are to be used or prescribed only within the context of a veterinarian-client-patient relationship (VCPR). Although it sounds like you have a standing relationship with the doctor, if the VCPR isn’t in place we would strongly recommend you do not fill the prescription. If there were to be an issue after the animal ingests the drug your license may be at risk if the VCPR isn’t in place. If the doctor in question doesn’t work with another pharmacy, etc. it might be better to transfer the drug in question to the clinic itself and then allow them to dispense as appropriate. You had stated this was not a controlled substance, but the recommendation is based on the best way to protect your actions in general.
A client asked me to write a prescription rather than have me dispense the drug out of my clinic. What are my rights and responsibilities?
To comply with Public Health Code 333.16221(A) a veterinarian is obligated to honor a client’s request for a prescription versus dispensing, providing the drug is deemed medically necessary and in the animal's best interest by the veterinarian. Veterinarians are not obligated to prescribe when requested to do so by a third party, i.e. a pharmacist. The request must be made by the client. It is ethical for veterinarians to refuse a prescription if clients do not follow instructions, i.e. yearly heartworm test, lab work to evaluate drug effects, etc. Veterinarians should be willing and able to explain to a client when a prescription is appropriate based on AVMA Principles of Veterinary Medical Ethics.
The American Veterinary Medical Association (AVMA) does not have a position on this subject. According to the Michigan Board of Pharmacy, there are no regulations preventing a veterinarian from charging a fee for writing a prescription. In general, veterinarians must charge adequately for their professional services to cover the costs of maintaining a veterinary clinic, paying staff, and offering quality medical care to a client’s animal. Some veterinarians have chosen to charge a prescription issuance fee in those cases when the veterinarian does not directly dispense the medication to the client. Some have considered implementing a policy to charge a specified fee, whether a drug is dispensed or prescribed. Others have reviewed fees and the need for any adjustments within the context of all services rendered. And still others charge for their professional services using units of time (e.g. when reviewing prescription drug authorizations or conducting telephone consultations with clients).
If you are asked to approve a prescription, you should do so only if the prescription is medically appropriate for the patient and you have a valid veterinarian-patient-client relationship. The decision as to whether a prescription drug should be used for a patient is made by you – the veterinarian – not a pharmacy.
After consulting with the Michigan Board of Veterinary Medicine, we received the following recommendation: "Veterinarians should not fill prescriptions for human treatment. It is probably a fairly common practice as the drugs are the same but it is still dispensing to treat humans and that is practicing human medicine without a license."
No, the client has the option of filling a prescription at any authorized pharmacy. In this example, the veterinarian’s practice of veterinary medicine, which would include writing a prescription, would be confined to his or her state.
Veterinarians may want to advise clients who choose to fill prescriptions through the Internet to select a VIPPS pharmacy - one that is certified by the National Association of Boards of Pharmacy and has its seal of approval. The national pharmacy association developed the Verified Internet Pharmacy Practice Sites (VIPPS) program in 1999 in response to public concern over the safety of Internet pharmacy practices. VIPPS pharmacy sites are designated by a hyperlink seal. To be VIPPS certified, a pharmacy must comply with the licensing and inspection requirements of the state in which it is located and in each state where it dispenses pharmaceuticals. These pharmacies must also demonstrate compliance with criteria that include patient rights to privacy, authentication and security of prescription orders, adherence to a recognized quality assurance policy, and provision of meaningful consultation between patients and pharmacists.
Report it! The American Veterinary Medical Association (AVMA) has created a Pharmacy Complaint Form to simplify the reporting process for practitioners. The form identifies the organizations to which the form should be sent. Regulatory agencies cannot act unless they have factual complaints to pursue. Forms can be found on the AVMA website. If you are unable to locate this form on the web contact MVMA at 517/347-4710 and we will send you a copy of the complaint form.