Under Care Review: final consultation launched

Following a recent decision by RCVS Council, we have this week [18 July 2022] launched the final stage of our wide-ranging review of the definition of ‘under care’ and the provision of 24/7 emergency cover, and are now consulting veterinary surgeons, veterinary nurses, students and the wider veterinary team on our proposed new guidance.

At their meeting on 6 July, Council members gave the go-ahead for the consultation, and also voted to approve in principle that a separate consultation with the animal-owning public should take place, the terms of which would be reviewed by the College’s Standards Committee prior to its launch.

Background

Launched in 2019, but then delayed by the pandemic, our Under Care Review originated from the 2016 Vet Futures initiative (a joint project by the RCVS and British Veterinary Association).

It then became a key strategic ambition for us to review the regulatory framework for veterinary businesses to ensure a level playing field, enable a range of business models to coexist, ensure professionalism in commercial settings, and explore the implications for regulation of new technologies, eg telemedicine. This led to consideration of 'telemedicine' in its narrowest sense, ie in relation to remote prescribing of prescription-only veterinary medicines (POM-Vs).

The terms 'clinical assessment' and 'under care' are not defined by the VMRs, so we sought legal advice to ensure that the basis of the proposed guidance would be correct and reliable.

The Veterinary Medicines Regulations (VMRs) require veterinary surgeons to carry out a clinical assessment and to have an animal under their care before prescribing POM-Vs. The terms 'clinical assessment' and 'under care' are not defined by the VMRs, so we sought legal advice to ensure that the basis of the proposed guidance would be correct and reliable. That legal advice underpins the recommendations made.

A further key theme that emerged during discussions was that remote prescribing and out-of-hours care were closely linked. The reason being that if a medicine was prescribed without a physical examination, consideration needed to be given to where owners would go to seek help for their animals in the event of an adverse reaction or deterioration.

Under Care Review: three stages

The Under Care Review, conducted by our Standards Committee and approved by Council, has sought to answer these questions in three different stages:

1. Evidence-gathering: sought views and experiences from a wide range of veterinary professionals across multiple sectors via a series of focus groups
2. Analysis and feedback: used the analysis of information gained from Stage 1, along with additional stakeholder submissions, data from our Covid surveys, independent research studies and formal legal advice to formulate an online qualitative survey to gain the views and feedback of UK-based veterinary professionals.
3. Public consultation: proposed changes to the Code of Professional Conduct and its supporting guidance on the concept of 'under care' and 24/7 emergency cover arising from the survey in Stage 2 are now the subject of consultation with the professions and the animal-owning public.

Safeguards

Commenting on the launch of the consultation, Dr Melissa Donald MRCVS, RCVS President and former Chair of the Standards Committee, commented: "As difficult as the Covid-19 pandemic made all our working lives, the numerous lockdowns gave us the opportunity to explore what ‘under care’ meant in principle and helped us to learn how new guidance could best work in practice and across all species.

The proposed guidance seeks to protect animal health and welfare and maintain public trust by ensuring that decision-making remains firmly in the hands of individual veterinary surgeons.

Melissa Donald

"The past two years have shown us that the veterinary professions are highly capable of adopting new ways of working. It also revealed that we can adapt our established ways of practice to better respond to shifts in public expectations and advancements in technology.

"However, it is our collective responsibility to ensure that any changes continue to allow us to provide safe and effective care for our patients, and meet the appropriate expectations of our clients.

"Whilst we recognise and reflect on the need for change, the proposed guidance seeks to protect animal health and welfare and maintain public trust by ensuring that decision-making remains firmly in the hands of individual veterinary surgeons, as to what they, in their professional judgement, consider appropriate in a specific situation.

"This consultation, then, while not a referendum on whether RCVS guidance on 'under care' and 24-hour emergency first-aid and pain relief should change – that decision having been made by Standards Committee and approved by Council based on the evidence gathered, including the views of the profession and objective evidence, and legal advice – is a crucial opportunity for veterinary colleagues to tell us whether we have got the draft guidance right, whether the proposed safeguards are sufficient, and whether there is anything we might have missed or should amend."

Council decision

At their recent meeting, Council members were reassured that suggestions and concerns raised during the consultation process, particularly around antimicrobial resistance and additional safeguards to protect animal health and welfare, would be taken into account when finalising the proposed guidance.

We’re now in a position where we are ready to hear what the professions and the public think about the proposed guidance, and whether the safeguards we are suggesting are adequate and appropriate.

Kate Richards

They then reaffirmed their broad support for the reasons behind the consultation and voted to approve the consultation questions, structure and timeline.

The consultation will run for eight weeks, rather than the usual six, to account for the holiday period, closing at 5pm on Monday, 12 September 2022.

Dr Kate Richards MRCVS, who chaired the Council meeting as the then RCVS President, said: “I want to thank my Council colleagues for taking part in a robust discussion on this topic, it was important that opposing views were expressed and debated.

"While acknowledging that Covid made day-to-day work challenging for the veterinary professions, it also presented opportunities for us to understand and explore how we can modernise veterinary practice.

"With Council’s approval, we are now in a position to hear what the professions and the public think about the proposed guidance, and whether the safeguards we are suggesting are adequate and appropriate.”

The consultation

The new consultation seeks views from all veterinary professionals, vet and vet nurse students, practice managers and all those who work in the veterinary practice team.

It asks respondents to what extent they agree with each element of the proposed guidance on 'under care', their views on the requirements for a 24/7 follow-up service following a remote prescription and other safeguards, and their feedback on the proposed definition of limited-service providers.

All veterinary surgeons and veterinary nurses were invited by email on 18 July 2022 to take part in the consultation, and we will also be writing to all key veterinary stakeholders to seek their input.

The public consultation, which will take place in parallel via an external agency but over a shorter timeframe, will likely include questions asking for information about animal owner experiences with remote prescriptions, the perceived advantages and/or disadvantages of remote prescribing, and views on 24/7 care and how important a service this is to respondents.

Details of the consultation, including the background, current position, proposed ‘under care’ guidance, recommendations about 24/7 emergency cover, independent research reports, and legal advice, are available at www.rcvs.org.uk/undercare.

If you have any questions about the consultation, please email us at [email protected].