The GVMA was one of 5 people/groups who sent a letter to the State Board of Veterinary Medicine about proposed rule changes that could negatively impact veterinarians.. On Wednesday, December 2nd, GVMA President Dr. Justin Toth spoke about these concerns at the virtual State Board meeting.
All of the rules that the GVMA had issues with—Unprofessional Conduct, Surgical Standards, Examination Area, and Patient Care—were all tabled and sent back to the Rules Committee for further consideration (see attached). All in all—a very good result for GVMA members!
Proposed Rules
Rule 700-8-.01 Unprofessional Conduct
◦ .5.c.2.x: Medication prescribed or recommended, including dose, strength, frequency, and reason for its use in treatment of the diagnosed condition.
▪ GVMA comment: We have concerns regarding the requirement to list the reason for use of a medication in the medical record. For example, if a veterinarian prescribes Apoquel to an atopic dog, would they be required to explain in the medical record the rationale for prescribing this medication and, if so, what level of detail is required? The requirement to list specifics in the record would be time consuming and burdensome to veterinarians.
◦ .5.c.2.xv: Radiographs to include details of radiographic technique and findings in accordance with federal and state regulations.
▪ GVMA comment: The assumption is that this would require listing radiograph machine settings in the medical records. We fail to see the usefulness of this information in a permanent medical record, which would not have a tangible positive impact on patient care and the practical application of this in a busy veterinary practice would be burdensome.
◦ Failure to Maintain Patient Records: A veterinarian shall prepare and maintain a record reflecting the care and treatment of animals treated or boarded
▪ GVMA comment: Does the requirement to maintain records for boarded animals apply only to medical boarding or to general boarding as well and is a valid VCPR required? What information is expected to be entered into patient records and how long do such boarding records need to be maintained? If medical records are required to be maintained for general boarding in a veterinary hospital, this will be burdensome and will increase the cost of care for clients.
BOARD DECISION 12/2: TABLED AND SENT BACK TO RULES COMMITTEE
Rule 700-12-.08 Surgical Standards
◦ .1.d: All surgery must be performed by a licensed veterinarian utilizing aseptic technique as appropriate for the procedure.
▪ GVMA comment: There are many “clean surgeries” where aseptic technique might not be possible or required such as castrations (cats and large animals), abscesses, lacerations, the field, etc. The deletion of the words “as appropriate for the procedure” prevents the veterinarian from using his or her professional judgment in individual cases.
◦ .1.g: For patients under general anesthesia for more than five minutes an endotracheal tube must be utilized.
• GVMA comment: What is definition of General Anesthesia? Is this defined in the Practice Act or in Board Rule?
• This rule is problematic for certain species which are not commonly intubated (horses, cows, goats, etc.) and is in some cases impossible
or harmful (certain exotics). In addition, injectable anesthesia (both IV and IM) is safe and has been used for decades when appropriate and the decision to intubate these patients should be left to the judgment of the veterinarian.
• The 2020 AAHA guidelines do not mention utilization of endotracheal tube for patients under anesthesia for more than five minutes.
• The current guidelines for spay-neuter as published in JAVMA acknowledge the challenge of intubation of cats in spay-neuter settings and leaves the decision to intubate up to the veterinarian.
.1.h: Monitoring equipment
▪ GVMA comment: Monitoring devices are not routine equipment in many large animal mobile clinics. In addition, their use in very small patients might not be possible. In most cases, having a dedicated anesthetist monitoring vital signs and anesthesia and recording this information can provide safe and effective care.
BOARD DECISION 12/2: TABLED AND SENT BACK TO RULES COMMITTEE
Rule 700-12-.09 Examination Area
◦ .1.e: The examination area must provide an adequate space to ensure client safety.
▪ GVMA comment: The requirement for “adequate space” is unclear and vague. Adequate space is dependent on multiple factors such as the size and disposition of the patient and number of persons present and is not something which can easily be defined and therefore mandated. In addition, this requirement could create unforeseen liability risk for veterinarians.
BOARD DECISION 12/2: TABLED AND SENT BACK TO RULES COMMITTEE
Rule 700-12-.11 Patient Care
◦ .1: For hospitalized or sick patients that are maintained in a veterinary facility, a licensed veterinarian must physically evaluate each patient daily.
▪ GVMA comment: This should be left to the discretion of the veterinarian depending on the condition of the patient as well as the skill of the persons designated by the veterinarians to provide care and treatment of the patient. This requirement would be at times unnecessary and would be burdensome.
◦ .1.b: For hospitalized and sick patients, the licensed veterinarian must have appropriate measures in place to ensure patient comfort to include but not limited
▪ GVMA comment: This rule is unclear and it appears there is a dropped line.
BOARD DECISION 12/2: TABLED AND SENT BACK TO RULES COMMITTEE
