Practice Advisory Service

Yes. In certain situations, a veterinarian may choose to discontinue a VCPR, despite attempts to address concerns or problems. In the interests of optimal animal care and treatment, discontinuing the VCPR may be the most productive option for both a client and a veterinarian to address on-going and unresolved issues.

Reasons why a veterinarian may discontinue a VCPR can include: 

• a client is continually not adhering to recommended treatment plans, resulting in potential risks to the welfare of the animal; 
• a difference in philosophy as to the approach taken for diagnosing and treating animals; 
• verbal abuse and/or threatening behaviour of a client towards the veterinarian and/or hospital staff; 
• a client making unreasonable demands for unnecessary medications and services, or for illegal or unethical actions (e.g. asking the veterinarian to alter a medical record); 
• a client continually deferring payment of fees owed for services rendered

When a veterinarian discontinues the VCPR, the client is to be provided with notice of when the VCPR will be discontinued and how a new veterinarian or the client can obtain the animal’s medical records. Once the VCPR has been discontinued, the veterinarian has no further professional obligations toward the animal and client.

Under the Cannabis Act and Regulations, veterinarians are permitted to prescribe and dispense Health Canada approved medications with cannabis or CBD (cannabidiol); however, there are currently no approved medications with cannabis or CBD to treat animals in Canada.

A veterinarian may recommend and sell veterinary health products with hemp that are approved through Health Canada’s Notification Program. A veterinarian may advise their client on the use of legally available recreational cannabis for their pet if they are knowledgeable about the legal framework and have the appropriate education and training on its use in animals. They will determine if it is appropriate for the pet. 

It is important for pet owners to be aware that there are many cannabis-derived products being marketed for animals that are unregulated by Health Canada. If you wonder if a cannabis product may be a treatment that would help your pet, it is important to talk to your veterinarian.

In Ontario, veterinary facilities are not like human pharmacies that only dispense medications. There are some narrowly defined exemptions in Regulation 1093 that allow for a veterinarian to dispense to another veterinarian’s patient based on that veterinarian’s prescription.  Even when these exemption criteria are met, a veterinarian is not obligated to fill a prescription written by another veterinarian. Convenience to the client is not one of the listed criteria.
Professional Practice Standard - Dispensing a Drug

The College does not set a fee structure for veterinary medicine. Veterinary facilities are run as small businesses and are not government funded in any way.  Each individual veterinary facility in Ontario will determine the fees charged for services provided as part of their business model and in keeping with the Federal Competition Act whereby veterinarians must not conspire to fix fees. 

While the College does not set fees, the regulatory framework does consider it professional misconduct if a veterinarian charges fees that are excessive in relation to what is normally charged. See Regulation 1093 which states:

17. (1) For the purposes of the Act, professional misconduct includes the following:

11. Charging a fee that is excessive in relation to the amount normally charged for the services performed or the product dispensed or adding a charge that is excessive when recovering any disbursement incurred in the course of providing services.

Questions regarding fees can be discussed with your veterinarian directly.  For the College to investigate concerns about excessive fees being charged, a complaint can be submitted to the College by contacting the Investigations and Hearings program.

While the College does not recommend or refer the public to specific veterinarians, we are the regulator for the practice of veterinary medicine in Ontario and keep a Public Register, or list, of all licensed veterinarians in the province. Through searching the Public Register, you can find information about veterinarians including their name, practice address, licence status, contact information, languages spoken, and species served. As well, their qualifications and areas of specialty are noted. The Public Register also includes information about any conditions on a licensed veterinarian's registration. Information about findings of professional misconduct is also specified.

This list can be easily found on our website. Click on Find a Veterinarian and follow these steps:

1. There will be 3 options displayed: veterinarian, veterinary practices, professional corporations. You will want to select “veterinarian”
2. Under “Status”, select ‘Active’ from the drop-down menu
3. Looking for a veterinarian in a specific location? Click on “By address” to type in a street name, city or postal code
4. Looking for more search options? Click on “Show More Options”
5. Looking by species? Click on “Patient Species” and choose species from the drop-down menu
6. Looking for a specialist? Under “Board Certified Specialist” select from the drop-down menu
7. Looking for languages spoken? Under “Language” select languages spoken from the drop-down menu.

If you need assistance or have questions, contact the College at inquiries@cvo.org.

The College does not set clinical guidelines for veterinarians or provide clinical advice. The College’s practice advisory service is available to anyone seeking information related to the regulations, policy and expectations associated with the practice of veterinary medicine and assists the public with their understanding of the professional obligations of veterinarians licensed in Ontario. 

It is important to keep in mind that the practice advisory service does not offer legal advice, or a legal opinion, and the Practice Advisors do not provide veterinary medical advice or a medical opinion. 

For the College to investigate a concern about a veterinarian, a complaint can be submitted to the Investigations and Hearings program at the College. 

Yes, a veterinarian is required to provide a copy of the requested components of the medical record to a client upon request. This includes a request for a copy of the complete medical record. The physical copy of the medical record is the property of the veterinary clinic, but the information contained in the record belongs to the client and the client has the right to access the content of their animal’s medical record.

A veterinarian is allowed to recover reasonable costs for producing copies of medical records (for example costs of materials, staff time, courier/postage fees etc.). The charge must not obstruct the efficient and timely release of information. Clients should be informed of this fee and made aware that payment is not a pre-requisite for providing the copy of the record in a timely manner.

Ontario Regulation 1093 requires that a veterinarian must have a veterinarian-client-patient relationship and have recent and sufficient knowledge of the animal to recommend and provide treatment, including medications.  For each animal, a veterinarian determines if they have recent and sufficient knowledge and may need to take a history from the client and perform a physical examination. The veterinarian uses their professional judgment to determine the information they require to prescribe or dispense a medication and their recommendations should be based on their assessment of the individual patient and their risk factors, including when the last physical examination occurred.

As part of the informed client consent process, a veterinarian will review their recommendations, any appropriate alternate treatment options and the risks, benefits and potential side effects of each with a client.  The decision to dispense a medication is up to the veterinarian. The client provides their consent to accept the veterinarian’s recommendations or not. However, a veterinarian is not obligated to proceed with a treatment a client requests if they believe it is not appropriate for the animal.  

It is a business decision on the part of the veterinary practice what fees to charge for services provided. Each individual veterinary facility in Ontario will determine the fees charged for services provided as part of their business model.

Yes, once a veterinarian has determined that a drug is warranted for a patient, a client can choose to have the medication dispensed from the veterinary facility or request that a written prescription be provided to be filled at a pharmacy of the client’s choice.   

If a client requests a written prescription, a veterinarian is obligated to provide it as per Regulation 1093 section 26. Veterinarians may charge a fee for providing the written prescription. Once a client is provided with a prescription then it is left to them to decide where they will have the prescription filled. For veterinary drugs, not all pharmacies will have them in stock for dispensing. 

Products obtained outside of Canada are not subject to the same regulated approval process as drugs approved by Health Canada. You should research the online supplier before making your purchase to decide whether you wish to assume that risk. The College regulates the practice of veterinary medicine in Ontario, including the issuance of prescriptions and the dispensing of drugs by licensed veterinarians, but the regulation of pharmacies – in Ontario or elsewhere – is not within the jurisdiction of the College. The integrity of the drug is the responsibility of the dispensing pharmacy, and they are required to follow the pharmacy regulations in their jurisdiction.  

See Health Canada's webpage on Buying Drugs over the Internet. While its content refers to purchasing drugs for human use over the Internet, some of the information may be useful for you. 

With the formation of a veterinarian-client-patient relationship (VCPR) a veterinarian assumes a variety of professional responsibilities including providing reasonably prompt services for their clients and patients outside of regular practice hours if the services are medically necessary for animals that they have recently treated or treat regularly.

As it is not reasonable to expect veterinarians to be available to all of their clients all of the time, the College’s After-Hours Care policy outlines options for the delivery of after-hours care services. These services may be provided through “on-call” services provided by the veterinarian or another local veterinarian or by referral to a facility that provides 24/7 services, an emergency clinic, or to a telemedicine service. Practices may use one or a combination of these options.

A veterinarian is required to have a veterinarian-client-patient relationship (VCPR) with a client before selling them a non-drug veterinary product.  A non-drug veterinary product is a substance that is intended for use in the maintenance or promotion of the health of an animal(s) (e.g. pesticides, parasiticides, notified veterinary health products, etc.) that does not fall under the definition of a drug nor retail items available for sale in the public domain.

Unlike the requirements for prescribing and dispensing a drug, the requirement for recent or sufficient knowledge is not always necessary when selling a non-drug veterinary product. Instead, veterinarians are expected to engage with their clients to determine the appropriateness and suitability of a non-drug veterinary product for an animal(s) prior to sale.

Yes, veterinarians can advertise prices, regardless of what the price is (this can include free). When advertising prices, it needs to be clear what is included in the price cited. It should also indicate if any taxes will be additional or if they are included. As with all advertising, fees cannot be misleading or deceptive by the inclusion or omission of information. 

Discounts can be advertised.  For example, if a veterinary clinic is promoting dental health month, dental cleanings can be advertised as being X% discounted. Seniors, military, multiple pets, new client discounts can all be advertised as well if that is part of the veterinary facility’s fee structure. 

Veterinary practices can use coupons to advertise promotions and prices of the services they offer. Coupons can be promoted in any public advertising medium.   However, a clinic cannot use the services of a third- party company to sell discounted veterinary services on their behalf via a coupon program. 

Third party company promotions can be advertised to clients. For example, if a clinic stocks a particular company’s foods, the clinic can let clients know about any discounts, coupon rebates or promotions such as “buy one get one free” that the company may be offering. 

To use a term, title or designation which indicates specialization in veterinary medicine or represents to the public that a veterinarian is a specialist or is specially qualified in a branch of veterinary medicine, a veterinarian must hold a specialty certification from an organization recognized by the College. If a veterinarian does not hold speciality certification, then it is acceptable to advertise that a veterinarian has "an interest" in for example, dentistry.

Yes, rewards programs can be used. For example, veterinary facilities can participate in third party rewards programs so that clients can use their points cards. 

Veterinary facilities can also offer their own rewards programs for clients. For example, if a certain number of bags of food are purchased, they will get a free bag. Or perhaps if clients spend a certain amount of money, they will reach a free service or a discount on a future invoice. 

Incentive programs, however, are not allowed. Clients should not be offered compensation, rewards, or incentives to refer others to a veterinarian’s practice. If a client, of their own accord, speaks highly of the veterinary facility to family and friends and this results in a new client, a veterinarian can thank them. A thank you can be verbal, or a card/letter/email can be sent. A veterinarian is allowed to show their appreciation for the referral by giving a gift card, or a discount on services or products, if they wish to. This differs from incentive programs as the client made the referral because they wanted to; not because they felt pressured to or that they would be rewarded for doing so. 

Veterinarians are not allowed to endorse or promote another business, service, or product. 

Examples of endorsement would include: 

• handing out another company’s card/pamphlet to market or advertise on the company’s behalf. However, in the context of a veterinarian-client-patient relationship (VCPR), using information provided by a third-party company for the purpose of client education (for example, when discussing recommendations for patient care, or providing information about the products the clinic stocks) would be permitted. 
• being a spokesperson in a marketing campaign for a company’s product or service. A veterinarian cannot permit their status as a licensed veterinarian to be used in any communication offering a product or service to the public except for the products, veterinary services or ancillary services that they offer in their professional capacity (at their veterinary facility).  
• advertising the products they stock at their facility in such a way as to be an endorsement. For example, advertising that “our clinic stocks item A because it is the best” is not appropriate as this would be seen as an endorsement. Advertising that “our clinic stocks item A” is fine. 

A testimonial, in the context of advertising, is “a statement from a client, former client, or other person that is solicited (directly or indirectly) by a veterinarian and used in an advertisement for the purpose of demonstrating esteem, admiration, gratitude, or praise for services provided by or experiences with the practice”. 

Veterinarians are permitted to use testimonials in their advertising and may ask a client for a testimonial. Other examples of testimonials include asking a client to rate or provide a review on a third-party website and asking a client to “like” the practice’s Facebook page.  

Veterinarians are held to professional standards regarding the manner and approach in asking for testimonials. For example, a client should not feel pressured to provide a testimonial, rating, or review. Veterinarians are expected to ensure that all forms of advertising they have control over (such as clinic websites, and their own social media) remain in line with Ontario Regulation 1093 Section 36. 

A clinic rating by a third-party company can be advertised if the third-party company is referenced as to the source of the rating. 

When a veterinarian uses Facebook or other social media platforms, they would apply the advertising regulations, maintain their professionalism, and protect confidentiality.  For more information on social media see Guidance on the use of Social Media.  

Before posting pictures or case stories of patients, a veterinarian must get the client’s consent. If a veterinarian is obtaining client consent to share an animal’s case story, be sure the client understands and agrees to what information will be shared. Written or verbal consent from clients is appropriate. If a veterinarian chooses to get verbal consent, it should be documented that consent was obtained. 

Veterinarians can advertise the professional and ancillary services they provide. When advertising, veterinarians are expected to do so in a professional manner and in keeping with Ontario Regulation 1093 Section 36 and the Professional Practice Standard: Advertising.

Veterinarians should ensure that the information included in their advertisements complies with the following rules: 

1. The information must be factual, accurate and verifiable. 
2. The information must not, be false, misleading or deceptive by the inclusion or omission of information, 
3. contain any comparative or superlative statements, or 
4. contain any endorsement or promotion of drugs or third-party service providers. 
5. The information must not reasonably be regarded by other veterinarians as likely to demean the integrity or dignity of the profession or to bring the profession into disrepute.  
6. Veterinarians can advertise in any public medium. This includes: 
7. print/radio/television 
8. internet/social media 
9. signs/bulletin boards 
10. booth (for example at a pet expo) 
11. community welcome package/realtor package 
12. merchandise (for example reusable shopping bags; sports team jerseys) 

Refer to the Guidance on the Use of Social Media document to assist with appropriate use of social media. A veterinarian should exercise caution when posting information online that relates to a client/patient. A suggestion is to move the conversation off-line by asking the individual to contact the practice directly. The College has no regulatory authority over third-party websites. To remove a negative review, a veterinarian can contact the third-party review site, or seek legal advice depending on the circumstances.

It is important that veterinarians recognize that these products are not indicated for animal use; they are not classified as drugs and do not make health claims. The scientific evidence to support the use of cannabis in animals, including safety and efficacy, is growing but remains limited. THC in cannabis has known toxic effects in pets and symptoms of toxicity can be severe. Veterinarians are accountable for any professional advice they provide to a client about their pet.

There are many cannabis products available that are not legal that clients may be accessing for human or animal use. 

Veterinarians should not advise on the use of any illegal substance, including cannabis sold on the black market or unapproved cannabinoid products. 

The only approved cannabis products for animals available in Canada at this time are veterinary health products made from hemp. These products: 

• Are exempt from the Cannabis Act as they contain < 10 ppm THC; 

• Are regulated by the Industrial Hemp Regulations (IHR); 

• Have no concentrated cannabinoids, including CBD; 

• Do not make health claims; 

• Are sold at retail; and 

• Are distinguished from unapproved cannabis products labelled for animal use by a Notification Number assigned by Health Canada. 

Legally purchased recreational cannabis from authorized provincial retail sales outlets can be distinguished from black market cannabis by its packaging. Legal products: 

• Are not sold as drugs and as such must not be accompanied with human or veterinary health claims; 

• Are packaged and labelled according to strict rules set by Health Canada; 

• Have packaging with a Canada Revenue Agency (CRA) excise stamp; and 

• Undergo quality control testing to ensure, among other things, that concentrations of CBD and THC that are indicated on the label are accurate, and that the products are free of specified contaminants (e.g. certain pesticides). 

References
Cannabis product package and label mock-up
Cannabis Excise Stamp (CRA)
Cannabis Excise Stamp (CRA) 2
Veterinary Health Product sample label

If a veterinarian chooses to advise on a legal recreational cannabis product for their client’s pet, they: 

• Must practice within the scope of their clinical competency; 

• Must weigh the evidence on cannabis against other available treatment options; 

• Must consider the known or suspected risks associated with its use in animals; 

• Must obtain informed client consent; 

• Must monitor patients and be available in the event of an adverse reaction or failure of treatment; and 

• Must be aware of the potential for abuse, diversion and misuse of cannabis. 

Under the Cannabis Act, veterinarians are permitted to prescribe and dispense Health Canada approved drugs with cannabinoids, whether human or veterinary label; however, there are currently no veterinary drugs available on the market. Current human prescription products containing cannabinoids (e.g. Sativex) are often not appropriate for veterinary use. Veterinarians may recommend and sell veterinary health products with hemp that are approved through Health Canada’s Notification Program. Veterinarians may advise clients on the use of legally available recreational cannabis for their pets based on sound professional judgment. 

Logs can be maintained in a paper based or electronic format (the clinic does not need to maintain both). Regardless of format, all requirements are to be recorded. With electronic logs (as with all electronic medical records), there must be the ability to print the logs if required. 

Medical records are kept for a minimum of five years after the date of the last entry made.  Radiographs are considered to be part of a patient’s medical records and therefore, need to kept until the patient record can be removed from the clinic’s files (not based on the date the radiograph). Logs that contain information about a patient also need to be kept for as long as the patient’s records are active.

Veterinarians are allowed to charge a reasonable fee to recover the cost of making a copy of a patient’s medical record. Materials, staff time, and courier/postage fees are examples of these costs. How that fee is dealt with will be up to the parties involved.

In a situation where the client or veterinarian has refused to pay for a complete copy of a record, a veterinarian is still obligated to provide relevant medical record information to a colleague. This information can be given verbally or as a written summary. The best interest of the patient and their continuity of care necessitate the timely and accurate transfer of medical information between colleagues. Patient information or a copy of the patient record should be transferred within two business days (or sooner) when a request for the information is made.

Yes, veterinarians are required to provide either a copy or a summary of the medical record to a client upon request. The physical copy of the medical record is the property of the veterinary clinic but the information contained in the record belongs to the client and the client has the right to access the content of their animal’s medical record.  A veterinarian is allowed to recover reasonable costs for producing copies of medical records.

Yes, the medical record information belongs to the owner and the previous owner’s consent must be obtained before that information can be provided to the new owner. 

In accordance with Ontario Regulation 1093, where an animal is unclaimed by the client, transfer of an animal to an animal shelter or a third-party owner can only occur if at least ten days have passed since the completion of the treatment, convalescence, or ancillary service. The client must agree in writing to the transfer; or if the veterinarian cannot reach the client, the following steps must be followed before transferring the animal: 

• attempt to contact the client on at least five occasions and by at least two different methods; 

• make at least one attempt to contact the patient’s emergency contact person; 

• and make a written record of the contact attempts and methods. 

In the meantime, the veterinarian must provide necessary care and housing to the animal. If the client cannot be reached after the ten-day period and the previous steps have been completed, then the veterinarian can proceed with the transfer of the animal. 

Managing Unclaimed Animals in Your Practice Poster

In certain situations, a veterinarian-client-patient relationship (VCPR) may need to be terminated, despite attempts to address concerns.  In the interests of optimal animal care, termination of the VCPR may be the most productive option for both the client and the veterinarian. The client must be provided with proper notice of the termination and allowed a reasonable opportunity to arrange for care with another veterinarian.

The steps to follow to officially terminate a VCPR and no longer be professionally obligated to provide care to a client/patient(s) can be found in the Guide to Establishing, Maintaining and Discontinuing a Veterinarian-Client-Patient Relationship (VCPR).

Informed client consent is valid only when given by a person who has the legal authority to give consent. Establishing and understanding legal ownership of the animal(s) is one component of the initial conversation with a potential client. In situations with multiple owners, each owner should be recorded (name, address, and contact information).

All owners can give consent for veterinary services unless otherwise documented in the record. An authorized agent is a person authorized by the owner(s) to act on their behalf and whose decisions bind the owner as though they were themselves making the decisions. Authorized agents of the owner(s) should also be clearly documented, including their contact details. A veterinarian should also document what kinds of decisions the agent has been authorized by the owner to make, such as medical and financial decisions. Simply adding a name under “spouse” “other” or even “emergency contact” may cause confusion.

It is also prudent to clarify whether an individual is an emergency contact for a specified time period, and whether an emergency contact is also an authorized agent. A Sample Form Client Patient Identification Companion Animal can be found on in sample documents.

An exception to the requirement that a veterinarian-client-patient relationship (VCPR) must be established before a veterinarian can provide veterinary services includes where a veterinarian acting reasonably, determines that there is an emergency situation and that an animal or animals require(s) immediate veterinary services. The veterinarian can provide emergency care until the client is contacted at which time they will discuss further veterinary services and obtain consent to proceed. 

The Provincial Animal Welfare Services (PAWS) Act includes the authority of a veterinarian to euthanize an animal without having to seek consent in specific circumstances. The criteria to assess this authority includes: 

• The animal is suffering; 
• The animal’s owner or custodian cannot be found promptly, or the veterinarian reasonably believes that 
• The animal does not have an owner or custodian, or 
• The animal has been abandoned by the owner or custodian, and 
• Euthanasia is the most humane course of action (defined as where immediate veterinary treatment cannot prolong the animal’s life or prolonging the animal’s life would result in undue suffering for the animal). 

PAWS Act

To remove an owner from a patient’s file, consent must be obtained from the individual whose name is being removed from the file. Alternatively, legal direction, such as a court order, may be provided to allow you to remove an owner from the file. The change to the medical record must then be made in such a way that original content is maintained. 
 

Where a veterinarian believes that ownership of an animal is unclear or where there is a dispute over ownership, the veterinarian should only proceed if it is an emergency to prevent suffering and/or significant harm to the animal. In situations where the health and well-being of the animal is not at risk, a veterinarian can postpone treatment until ownership is confirmed. 

When ownership is in question, a veterinarian must use their professional judgment to determine an appropriate process for identification in the circumstances.