Report on Consultation

Consultation Period: August 20, 2021 to November 1, 2021

Submissions: 76 Submissions

What is the issue?

The College established a Professional Practice Standard on telemedicine in 2016 to acknowledge the increasing use of technology to facilitate and enhance veterinary care in Ontario. This standard supports veterinarians in using virtual modalities in practice and clarifies the expectations related to safety and quality.

The standard is reviewed regularly by Council to consider and accommodate the evolution of this fast-advancing area.

Since 2019, Council has been considering potential changes to its policy based on two relevant topics – jurisdictional oversight and veterinary prescribing.

Council first began reviewing its approach to jurisdictional oversight in December 2019. At that time, Council determined that it would wait until the Canadian Council of Veterinary Regulators (CCVR) completed its work on telemedicine and jurisdictional issues. In July 2020, the CCVR approved its National Policy Statement on Telemedicine. This document has served as a reference for Council’s review, and subsequent discussions at the Council table have centered around the feasibility and enforceability of the College’s current approach of requiring that every individual who offers veterinary services to an animal(s) or group of animals located in Ontario must be licensed with the College.

Council’s current discussion related to veterinary prescribing has largely been driven by the College’s decision in March 2020 to establish a temporary pandemic modification to permit the prescribing of all non-controlled drugs and substances to a new client/patient and/or for a new condition for an existing client within a VCPR but without requiring an in-person examination or premise visit to obtain recent and sufficient knowledge. This allowance has proven to be widely appreciated by both veterinarians and the public and has permitted the opportunity for Council to consider whether it should become a permanent amendment in cases where there is an immediate need for the welfare of the animal(s).

In June 2021, Council once again considered and debated proposed changes based on these two topics.  A revised Professional Practice Standard: Telemedicine and Professional Practice Standard: Prescribing a Drug were provided to Council to aid in its review.  Based on its review, Council determined that the proposed amended standards should be circulated for public consultation before returning to Council for further consideration.

Why is it Important

Advancements in technology, of all forms, provide opportunities for new approaches to the delivery of veterinary medicine. The importance of the utilization of technology in the practice of veterinary medicine was heightened during the Covid-19 pandemic.

As the broader world of veterinary telehealth continues to expand, the College recognizes the value of veterinarians utilizing developments in technology to improve access to the provisions of veterinary medicine, where appropriate, and supports innovations in the delivery of veterinary services.

The College remains, however, dedicated to ensuring that all forms of veterinary medicine offered in Ontario remain safe and accountable. This requires a risk-based approach that weighs the use of technology against any real or potential harm to the public and/or its animal(s).

Consultation Process

The draft Policy Statement was sent for public consultation for a 74-day period during which members of the College and members of the public were asked to provide their feedback.

What we heard

Major Themes

 Support for the Proposed Amendments

• The majority of responses received were in favour of the proposed amendments to both draft standards.

Additional Themes

1. Concern about out-of-province/unlicensed veterinarians offering veterinary services in Ontario

   • Concern was tied to ability to prescribe to Ontario animal(s) without available follow up

2.  Belief that all veterinarians offering services to Ontario animal(s) should be licensed in Ontario 

3. Telemedicine undermines an in-person examination and/or premise visit

4.  Veterinarians should be able to use their professional judgement 

5. The use of telemedicine alone may miss the detection of important signs or symptoms

6.  Proposed changes are not permissive enough 

Sample Comments

The following quotes, summarized from comments received, reflect suggestions received through the College consultation:

•  As a Fear Free Certified Hospital owner, telemedicine is an important tool which gives me the ability to prescribe non-controlled pre visit pharmaceuticals for their first in person visit.It also helps with time management, some rechecks are more efficient and effectively done virtually and we need all the help we can get with scheduling right now.
• I am a little concerned that a veterinarian who is not licensed in Ontario may prescribe medications in Ontario. Perhaps clarifications should be made as to whether this DVM can be licensed elsewhere in Canada vs in the US vs internationally. I don't think its appropriate for non-Canadian veterinarians to prescribe in Ontario. I am less hesitant with veterinarians in other provinces prescribing in Ontario as it is difficult for pet owners who recently moved provinces to find a DVM sometimes. 
• Telemedicine should be limited to EXISTING VPCR AND PRE-EXISTING PROBLEMS. Allowing a virtual diagnosis or presumptive diagnosis on a new condition without hands-on examination is doing a great disservice to the animals that we are suppose to help.
• By allowing telemedicine on new conditions and prescribing medications, you are sending the wrong message that physical examination is useless. With that said, there is a place for telemedicine, but only in very limited and specific conditions. For example, telemedicine without the ability to prescribe medication is absolutely fine as that would not violate to "Do no harm" first principle. For any prescription medication, be it controlled or not, it should be reserve for pre-existing patients and with pre-existing conditions, and such patients must have a current and valid VPCR.
•  I support the changes, I see benefit in providing telemedicine follow-up once an in person VPCR has been established for a medical condition. I have some concerns about telemedicine for new medical issues (e.g. can't perform ear cytology). However, I believe that the option to Rx short-term therapy until an in-person exam can be performed is important, esp when so many of the ER clinics only have the ability to provide immediate life-saving therapy.  This amendment also allows clients in remote areas to access ER veterinary medical care. May a telemedicine Rx be sent to a veterinary hospital closer to the client? I feel that it is important for veterinarians licensed outside of ON to provide telemedicine (e.g. veterinary nutritionist), when these appts can be performed in conjunction with a pet's ON veterinary team. 
• I feel strongly that a veterinarian performing telemedicine for a patient in Ontario should also be licensed in Ontario.
•  It is critical that the educational materials provided to veterinarians make it clear that their professional judgment is to be used in determining if prescribing based on a virtual examination without a physical examination is appropriate and the decision to so is because of the urgent need, and that they will be held accountable the same as if they had conducted a physical examination.  They must also understand their responsibility to attend in person, in the event of an adverse event, I offer this comment because there is significant potential for abuse of this prescribing authority, and the subsequent lack of best care of the patient.  The Animal Welfare implications are significant, we must protect the public. 
• This is a smart and timely update to the standard given the high demand for veterinary care and the ongoing and never-ending pandemic.
• I am having a hard time coming to terms with the CVO and lack of jurisdiction/authority over veterinarians licensed in other jurisdictions. If you physically wish to practice veterinary medicine in Ontario, you need to have your Ontario veterinary license. Why is it any different for virtual/telemedicine? In my opinion, anyone giving veterinary medical advice to animals in Ontario needs to be licensed to practice in Ontario. Period. I love that our telemedicine standard is being updated. It is great to get specific guidance from the college. 

How We Responded

College staff made several revisions to the draft amended standards based on the consultation feedback. The entirety of the consultation feedback was presented to Council in December 2021 to be used as part of its ongoing review.

Council Decision – December 2021

Council reviewed both the proposed amended draft Professional Practice Standard: Telemedicine and Professional Practice Standard: Prescribing a Drug at its December 2021 meeting. Following discussion, Council determined that it would keep its current approach of requiring that every individual who offers veterinary services to an animal(s) or group of animals located in Ontario must be licensed with the College. Council also determined that it would move forward with permanently permitting prescribing via telemedicine alone in certain circumstances. Council directed that the two proposed draft standards be published, with amendments, in early 2022.

Telemedicine