Can a veterinarian write a prescription that their client wishes to have filled outside Ontario?
The following information pertains to drugs that are available in Canada and have been approved by Health Canada:
Once the client is provided with a prescription, it is left to them to decide where they will have the prescription filled. The determination of the validity of a veterinary prescription is made by the dispenser. In some cases, some pharmacies will accept prescriptions from veterinarians not licensed in the jurisdiction in which the pharmacy is located, some will not. The integrity of the drug is the responsibility of the dispensing pharmacy, and they are required to follow the pharmacy regulations in their jurisdiction.
For oral or faxed prescriptions, a veterinarian can only deal directly with a pharmacist licensed in Ontario, another member of the College of Veterinarians of Ontario, or a licensed veterinarian practising outside of Ontario.
In addition, a veterinarian may wish to educate their client about the risks associated with purchasing drugs online, as outlined by Health Canada: https://www.canada.ca/en/health-canada/services/buying-drugs-over-internet.html. The College regulates the practice of veterinary medicine in Ontario, including the issuance of prescriptions and the dispensing of drugs, but the regulation of pharmacies – in Ontario or elsewhere – is not within the jurisdiction of the College or its licensed veterinarians.
When a veterinarian prescribes a drug for a client’s animal, can the client ask them to write a prescription instead of purchasing the medication from the veterinary practice?
Yes, a client may request that a medication their veterinarian has prescribed for their animal be dispensed at a pharmacy of their choice. A veterinarian must comply with the client’s decision and provide a written prescription. The veterinarian may choose to charge a prescribing fee.
When can a veterinarian dispense without having a veterinarian-client-patient relationship (VCPR)?
There are two broad categories outlined in the standards and associated regulations: Food/drink/cosmetics, and drugs. The specifics related to VCPR requirements within these categories are summarized below.
A VCPR is not required when a veterinarian dispenses any substance or preparation manufactured, offered for sale or sold as, or as part of, a food, drink or cosmetic (not defined as a drug). Currently, natural health products require a VCPR to be dispensed.
A veterinarian can sell therapeutic diets to someone who is not a client. Before therapeutic diets are sold to non-clients, the potential risks to this group of animals should be assessed. Therapeutic diets used in the treatment of specific disease conditions that are fed to an animal without that condition can potentially put that animal’s health at risk. For these situations, it would be best for a veterinary clinic to either call the regular clinic for verification and/or discuss further with the non-client before selling that product. For other therapeutic diets, (e.g. a maintenance-type diet), selling directly to a non-client without consulting with their regular veterinarian/veterinary clinic is low risk.
There are narrowly defined exemptions in Regulation 1093 that allow a veterinarian to dispense a non-controlled drug pursuant to a prescription from another veterinarian who is licensed in Ontario (the prescribing veterinarian) when the following conditions are met:
- it is not reasonably possible for the client to obtain the drug from the prescribing veterinarian or a pharmacy;
- it is necessary in the interests of the animal to administer or dispense the drug without the delay that would be associated with returning to the prescribing veterinarian;
- the dispensing veterinarian makes a reasonable effort to discuss the matter with the prescribing member;
- the dispensing veterinarian conducts a sufficient assessment of the animal’s circumstances, which may not require a physical examination in every case, to ascertain that it is unlikely that there has been a material change in the circumstances since the prescription was given;
- the quantity of the drug dispensed is no more than would reasonably enable the client to return to the prescribing veterinarian for future prescriptions or quantities of the drug; and
- the dispensing veterinarian makes a written record of the transaction.
Please note that convenience to the client is not one of the listed criteria. In general, veterinarians do not act as dispensing pharmacies for each other. A veterinarian is not obligated to dispense a drug outside of a VCPR even if these conditions are met. A veterinarian may decide to establish a VCPR with the individual in question, for the purpose of prescribing and dispensing the drug.
The College regulations only allow a member to dispense controlled substances to animals that are under their direct care. Clients do have the option of having the prescription filled by a pharmacist.
When drugs are returned to the clinic, can a veterinarian re-dispense these drugs to other patients or donate them to an animal shelter or rescue?
A veterinarian may not return to stock, administer, re-sell, or re-dispense a drug that was previously sold or dispensed. This includes drugs in any format (e.g. oral, injectable) and any type of packaging (e.g. blister pack, packet, loose tablets in vial). Redistributing unused drugs, even those in their original packaging, is not permitted because the chain of custody and the integrity of the drugs cannot be ensured. A veterinarian must meet the same standards of care in all circumstances and for all clients and animals. Returned drugs must be disposed of in a safe and secure manner.