COVID-19 FREQUENTLY ASKED QUESTIONS

(Philip Ladner, American Veterinarians’ Insurance) The CDC advises that anyone who has been exposed to COVID-19 should be isolated from others. Many people will experience little to no symptoms but are still carriers that could spread the virus if they sneeze or cough on someone.

An employer can require an employee to stay at home. However, an employer cannot simply require an employee who is considered “high-risk” due to age or any other known pre-existing condition to stay at home unless it was know that they were diagnosed or been around someone who has been diagnosed with COVID.

Employers do have the right to measure the temperature of all staff and evaluate any symptoms they may be experiencing. However, this information is considered medically sensitive. Any screenings should be done in a private setting.

Additionally, it is also important to note a recent update that employers cannot require a healthcare provider’s note for employees who are sick with acute respiratory illness to validate their illness or return to work. This is to protect the already overwhelmed healthcare system from taking time to provide this documentation.

(Philip Ladner, American Veterinarians’ Insurance) It is imperative that all employers take steps to create a safe workplace environment. The steps fall into 4 categories:

1. Engineering Controls – physical changes such as increasing ventilation rates or installing high efficiency air filters
2. Administrative controls – Minimizing contact with other employees or clients, alternating shifts to reduce exposure, develop communication plans to keep staff updated
3. Safe Work Practices – providing resources that promote hygiene. Frequent hand washing, disinfectants, disposable towels, no touch trash cans.
4. PPE (Personal Protective Equipment) – Gloves, masks etc. Employees should be instructed on proper use of equipment.

Yes, large hospitals can have more than 10 persons working so long as they practice social distancing.

(Philip Ladner, American Veterinarians’ Insurance) Generally, employees do not have the right to refuse to come to work unless they believe they are in imminent danger. Therefore, it is important to have communication with your employees about concerns they may have in the workplace. Employers are required to provide a safe workplace environment (cleaning supplies, gloves, social distancing). The rule is written that if a “reasonable person” would agree there is a real danger or serious injury then the employee can refuse to come to work.

(Philip Ladner, American Veterinarians’ Insurance) Curbside service helps control contamination when done properly. Employees should never reach into cars.

1. Exposes them to any airborne containment in the car.
2. Increased liability if damage to vehicle during extraction, or the animal bites the assistant because the pet is protective/territorial.

It is advised to have owner remove pet from vehicle and hand off to staff.

(Philip Ladner, American Veterinarians’ Insurance) Currently no states have required such documentation but the GVMA is aware of several instances where someone has been pulled over. The GVMA has a template on their website of a letter for employers to use stating that they are employed by an essential business with contact information for the employer in case it is needed.

(Philip Ladner, American Veterinarians’ Insurance) Business interruption has to be tied to a direct physical loss. Policy language can vary. It can be argued that if the virus was to be found in a business because an employee had it and was working. For example, this could result in physical loss because the building could not be used for some time. I recommend you review your policy language in case you have a viable claim.

(Philip Ladner, American Veterinarians’ Insurance) Most major carriers are relaxing any “actively at work” requirements associated with eligibility so long as the intent of the employee is that they will return to work full time at some time in the future.

(Philip Ladner, American Veterinarians’ Insurance) Yes, you can always request an audit that could help lower your monthly cost now. Many carriers will allow for an audit outside of the renewal if there has been a change in payroll. This could help free up some much needed cash flow.

(Philip Ladner, American Veterinarians’ Insurance) Yes, an employee would qualify if they are experiencing COVID-19 related symptoms (fever) AND is seeking a medical diagnosis. All insurance carriers are required to provide access to telemedicine which is the quickest way to do this. If that doctor then advises that employee to then self-quarantine or to be tested the employee would continue to qualify.

You may want to document sick leave using the guidelines here: https://www.natlawreview.com/article/covid-19-federal-everything-employers-need-to-document-to-claim-tax-credits-ffcra

(Jim Cichanski, CEO of Flex HR Inc)

1. Self-quarantine advised by a healthcare advisor, or told to do so by a Federal, State or local government quarantine or isolation order;
2. Has symptoms and is seeking medical diagnosis;
3. Is experiencing any other substantially similar conditions specified by the U.S. Department of Health and Human Service.

(Jim Cichanski, CEO of Flex HR Inc) Yes, the employer will get repaid. It will be handled via a reduction in the practice submitting federal taxes on their payrolls. Quickly work with your payroll company and you should set up two “pay leave” deduction codes. One for the 2-week sick leave, and one for the 2/3rd pay. Therefore, whatever you paid off these codes can be easily recorded and entered to get your tax rebate.

(Jim Cichanski, CEO of Flex HR Inc) The Department of Labor has stated that all the rules of the Families First Coronavirus Recovery Act (FFCRA) will be prepared and published on April 2 and the rules should be out on April 1. What we are hearing so far is when you do your payroll, you will reduce the amount of bottom line federal taxes you were going submit by the amount of the expense. We are recommending that you talk to your payroll firm and ask them to set up two separate leave categories, one for the sick and one for the FMLA portion. This way it will be easy to track.

(Jim Cichanski, CEO of Flex HR Inc) Only one, and that is if the owner just won the lottery and prefers to eat up the won cash rather than spending a few minutes reporting how much you paid in this area to get your money repaid you. I would think it would be embarrassing for an owner if one did get sick and you don’t pay them and the employee asked for the Family First pay for sick and the owner would say, no I opted out of that option to get you paid.

(Don Riddick, Esq. – GVMA Legal Expert) Here are the statutory reasons for the FFCRA:

1. is subject to a Federal, State, or local quarantine or isolation order related to COVID-19;
2. has been advised by a health care provider to self-quarantine related to COVID-19;
3. is experiencing COVID-19 symptoms and is seeking a medical diagnosis;
4. is caring for an individual subject to an order described in (1) or self-quarantine as described in (2);
5. is caring for a child whose school or place of care is closed (or child care provider is unavailable) for reasons related to COVID-19; or
6. is experiencing any other substantially-similar condition specified by the Secretary of Health and Human Services, in consultation with the Secretaries of Labor and Treasury.

(Don Riddick, Esq. – GVMA Legal Expert) They would not qualify for the FFCRA.

(Don Riddick, Esq. – GVMA Legal Expert) Yes. The two are separate rights, so you could qualify for one, or the other, or both (when one benefit expires).

(Jim Cichanski, CEO of Flex HR Inc) It is a one year look back period at the origination of the loan. They will take the payroll cost for the last 12 months, average it and multiply by 2.5 to get the amount of the loan. So that would mean April 1, 2019 through March 31, 2020.

(Don Riddick, Esq., GVMA Legal Expert) Actually, the FFCRA is a modifier of FMLA and is not truly a different program. One of the differences with the FMLA—it modifies the amount of leave that can be taken just as the CARES Act increases the number of weeks of unemployment for states that participate in the program. One of the things that is different about FMLA is that you can’t require an employee to use other paid leave available before using normal FMLA leave. You can identify the choices—it’s a menu of choices you have now that you didn’t have before. The second part is under the FFCRA, you can’t ask for the type of evidence that you could ask for under FMLA request before. That’s important because you do have to ask and maintain records on the request that are sufficient to qualify for the tax benefits that you need—the IRS requires it. For every request for the FFRCA, you must have in writing—the employee’s name, the date that leave is requested, the qualifying reason and an oral or written reason including why the employee can’t work including telework. If it’s for a son/daughter staying at home due to a school closure, you must have the child’s name and age, the name of the school/child care provider, a representation that no other suitable person can care for them during the time of the leave requested. There are additional requirements under FFCRA because of the tax credit as opposed to regular FMLA.

(Jim Cichanski, CEO of Flex HR Inc) There is a disaster loan out there, but it MUST all be repaid. It is low interest (4%) and you may need it to get to the next loan, but I would think twice. And work with your bank or trusted advisor.

(Jim Cichanski, CEO of Flex HR Inc) This is a great loan option and I really do see it as an option in an Essential Business. This is a real plan and I see the Payroll Protection Program as the “Get out of Jail” card to help you bridge the practice’s losses. This loan is forgiven if you do all the right things and that should not be hard to do.

But please use a reputable loan firm. I would first start with the bank you do business with – almost all of them have these loans available. I would not even respond to one of those email loan schemes! The big banks do not have the full information so forms floating around may not be the final format to use. The IRS stated they will try to get information out to the loan partners by April 3.

(Jim Cichanski, CEO of Flex HR Inc) First, you must pay the current employees their normal wages prior to the start of COVID-19 at the average rate you paid them. So, if they were full time, then they need to get their full-time pay. Your average headcount will be one of the factors and how many hours they work would be another factor. It also will include 1099’s you have paid.

Well it is already April and you don’t have the funds yet so it may be mid-April to mid-June. Each Bank will have that information to include what documentation you will need to provide to the government.

(Jim Cichanski, CEO of Flex HR Inc) Starting on April 3, you can go to any bank that has federal loan processing. What we have heard is that you must keep and pay 90% of your workforce to get the loan forgiven. What we are hearing is it will cover wages, employment taxes, benefit cost and lease facility cost. There are some hints of other business expenses but that is not clear at this time.

(Jim Cichanski, CEO of Flex HR Inc) In most arrangements I have seen, there is a contract for a lease and you pay on that agreement, therefore I would believe that is OK if you can prove this has always been done and you didn’t do this arrangement just to get more money in your claim of expenses.

(Don Riddick, Esq. – GVMA Legal Expert) It depends on your corporate structure. Generally the corporate entity does, but if you are a wholly owned affiliate, you may also be able to apply for the loan. I’d talk with your parent company.

(Don Riddick, Esq. – GVMA Legal Expert) No—it is February 1, 2019 to January 31, 2020.

(Don Riddick, Esq., GVMA Legal Expert) The answer is no. The Frequently Asked Questions about PPP on the Treasury Department’s site is a great resource for what should and shouldn’t be included. The US Treasury issued new guidance on 4/6 so anything you saw before that is no longer valid. You can go to their website to see what qualifies as payroll expenses.

(Don Riddick, Esq. – GVMA Legal Expert) Firstly, all employers have an obligation to provide a safe workplace. “Your employer must provide a workplace free of known health and safety hazards.” OSHA and the Department of Labor issued guidance this week that employers should send employees home who have symptoms that could align with COVID-19.

In addition, any employee who is not following safety protocols can be sent home without violation of labor laws. Every employee can expect an employer to provide protective equipment appropriate for safety in the workplace. You also have a duty to keep invitees safe from unknown (to the invitee) and known hazards, so clients should be informed if they have been exposed while on your premises. Liability can arise from several different causes, failure to provide a safe environment, failure to disclose hazards to invitees, but generally, if you are following safety protocols directed by the CDC and OSHA, along with state health officials, you will be deemed to have met any minimum standards or obligations.

(Don Riddick, Esq. – GVMA Legal Expert) Yes, if you are doing farm calls or home visits, you must check that these homes or farms are not exposed by COVID-19 and if they are, you have to take appropriate safety precautions when going to help those clients. You still have an obligation under OSHA to disinfect just as before.

(Don Riddick, Esq. – GVMA Legal Expert)

Compensating staff who don’t want to work should follow the normal guidelines for your practice and labor laws, including vacation, time off, and leave. Several new laws, such as the Family First Act have been passed to allow for leave for care of infected family members, for childcare, and so flexibility is important.

However, staff who just don’t want to work with the public are not currently required, beyond unemployment benefits, your general duties as an employer, to be compensated. There are some loans and tax breaks which have been discussed to require this, but I am not aware of them passing as of this date. Some reasons under the Family First Act that are legitimate include:

1. is subject to a Federal, State, or local quarantine or isolation order related to COVID-19;
   has been advised by a health care provider to self-quarantine related to COVID-19;
2. is experiencing COVID-19 symptoms and is seeking a medical diagnosis;
3. is caring for an individual subject to an order described in (1) or self-quarantine as described in (2);
4. is caring for a child whose school or place of care is closed (or child care provider is unavailable) for reasons related to COVID-19; or
5. is experiencing any other substantially-similar condition specified by the Secretary of Health and Human Services, in consultation with the Secretaries of Labor and Treasury.

Under FFCRA—if they don’t want to work for the above reasons, you absolutely have to pay them. If they are caring for an individual that is subject to one of the things that I just mentioned or a child who is out of school or their place of care is closed, you may have to continue for some period of time—generally for 80 hours to pay for an additional 10 weeks at 2/3 of the pay rate for certain employees who have been employed for more than 30 days.

Now the IRS has said that the child care leave provision doesn’t apply in some cases—particularly for employers with less than 50 employees where providing that pay for leave requirements related just for school closings would jeopardize the viability of an employer’s business as an ongoing concern. The IRS has specific guidance on their site about FFRCA and if the employee says they can’t work for that reason, you must pay them so look for that guidance there. FMLA and existing leave requirements also still need to be followed.

If people just don’t want to work with the public right now, you can allow them to take PTO or an unpaid furlough. If you do that or provide paid leave for any of the above reasons or you let anyone go or reduce their hours from full time to part time—under an emergency order from the GA Department of Labor, you are required to report it in advance as soon as you know on a weekly basis for those reductions in hours or for someone who might potentially ask for unemployment. In a case where someone just doesn’t want to work for no protected reason, they may still be eligible for unemployment and if you don’t file on the GA Department of Labor website in advance, you may have to pay that unemployment payment yourself rather than through the state insurance for that.

(Don Riddick, Esq. – GVMA Legal Expert) They would not qualify for the FFCRA.

(Don Riddick, Esq. – GVMA Legal Expert) Yes. The two are separate rights, so you could qualify for one, or the other, or both (when one benefit expires).

(Don Riddick, Esq. – GVMA Legal Expert) Here are the statutory reasons for the FFCRA:

1. is subject to a Federal, State, or local quarantine or isolation order related to COVID-19;
2. has been advised by a health care provider to self-quarantine related to COVID-19;
3. is experiencing COVID-19 symptoms and is seeking a medical diagnosis;
4. is caring for an individual subject to an order described in (1) or self-quarantine as described in (2);
5. is caring for a child whose school or place of care is closed (or child care provider is unavailable) for reasons related to COVID-19; or
6. is experiencing any other substantially-similar condition specified by the Secretary of Health and Human Services, in consultation with the Secretaries of Labor and Treasury.

(Philip Ladner, American Veterinarians’ Insurance) The CDC advises that anyone who has been exposed to COVID-19 should be isolated from others. Many people will experience little to no symptoms but are still carriers that could spread the virus if they sneeze or cough on someone.

An employer can require an employee to stay at home. However, an employer cannot simply require an employee who is considered “high-risk” due to age or any other known pre-existing condition to stay at home unless it was know that they were diagnosed or been around someone who has been diagnosed with COVID.

Employers do have the right to measure the temperature of all staff and evaluate any symptoms they may be experiencing. However, this information is considered medically sensitive. Any screenings should be done in a private setting.

Additionally, it is also important to note a recent update that employers cannot require a healthcare provider’s note for employees who are sick with acute respiratory illness to validate their illness or return to work. This is to protect the already overwhelmed healthcare system from taking time to provide this documentation.

(Philip Ladner, American Veterinarians’ Insurance) It is imperative that all employers take steps to create a safe workplace environment. The steps fall into 4 categories:

1. Engineering Controls – physical changes such as increasing ventilation rates or installing high efficiency air filters
2. Administrative controls – Minimizing contact with other employees or clients, alternating shifts to reduce exposure, develop communication plans to keep staff updated
3. Safe Work Practices – providing resources that promote hygiene. Frequent hand washing, disinfectants, disposable towels, no touch trash cans.
4. PPE (Personal Protective Equipment) – Gloves, masks etc. Employees should be instructed on proper use of equipment.

Yes, large hospitals can have more than 10 persons working so long as they practice social distancing.

(Philip Ladner, American Veterinarians’ Insurance) Generally, employees do not have the right to refuse to come to work unless they believe they are in imminent danger. Therefore, it is important to have communication with your employees about concerns they may have in the workplace. Employers are required to provide a safe workplace environment (cleaning supplies, gloves, social distancing). The rule is written that if a “reasonable person” would agree there is a real danger or serious injury then the employee can refuse to come to work.

(Philip Ladner, American Veterinarians’ Insurance) Curbside service helps control contamination when done properly. Employees should never reach into cars.

1. Exposes them to any airborne containment in the car.
2. Increased liability if damage to vehicle during extraction, or the animal bites the assistant because the pet is protective/territorial.

It is advised to have owner remove pet from vehicle and hand off to staff.

(Philip Ladner, American Veterinarians’ Insurance) Currently no states have required such documentation but the GVMA is aware of several instances where someone has been pulled over. The GVMA has a template on their website of a letter for employers to use stating that they are employed by an essential business with contact information for the employer in case it is needed.

(Philip Ladner, American Veterinarians’ Insurance) Business interruption has to be tied to a direct physical loss. Policy language can vary. It can be argued that if the virus was to be found in a business because an employee had it and was working. For example, this could result in physical loss because the building could not be used for some time. I recommend you review your policy language in case you have a viable claim.

(Philip Ladner, American Veterinarians’ Insurance) Yes, you can always request an audit that could help lower your monthly cost now. Many carriers will allow for an audit outside of the renewal if there has been a change in payroll. This could help free up some much needed cash flow.

(Philip Ladner, American Veterinarians’ Insurance) Most major carriers are relaxing any “actively at work” requirements associated with eligibility so long as the intent of the employee is that they will return to work full time at some time in the future.

(Philip Ladner, American Veterinarians’ Insurance) Yes, an employee would qualify if they are experiencing COVID-19 related symptoms (fever) AND is seeking a medical diagnosis. All insurance carriers are required to provide access to telemedicine which is the quickest way to do this. If that doctor then advises that employee to then self-quarantine or to be tested the employee would continue to qualify.

You may want to document sick leave using the guidelines here: https://www.natlawreview.com/article/covid-19-federal-everything-employers-need-to-document-to-claim-tax-credits-ffcra

(Don Riddick, Esq., GVMA Legal Expert) This is actually answered on the FAQ from the Departmentt of Treasury that I was referring to earlier—it is actually advantageous for an employer to see if there is a way to have some hours for a given week be paid for telework and keep the employee on the payroll.

(Don Riddick, Esq., GVMA Legal Expert) If they are showing no symptoms, there is really nothing for you to do. There is no exclusion/reason under FFCRA or CARES ACT for self isolation if they are not showing symptoms. If they feel like they’ve been exposed, they should consult a physician and if they are advised by their doctor to stay in isolation for a period of time, they should do that. The way that FFCRA is currently structured, you have to either be seeking a medical diagnosis or you have to self quarantine on the advice of a health care provider. If you self quarantine just because you are either afraid you’ll be exposed or you already have been exposed but you are showing no symptoms and you haven’t gone to a doctor, the only benefits that are available to that employee are unemployment and that could be declined. I spoke to the Georgia Department of Labor about this and this is being done on a case by case basis. The employee would have to file on their own. The answer is that you ask them to come to work unless they feel like they can’t.

(Don Riddick, Esq., GVMA Legal Expert) Actually, the FFCRA is a modifier of FMLA and is not truly a different program. One of the differences with the FMLA—it modifies the amount of leave that can be taken just as the CARES Act increases the number of weeks of unemployment for states that participate in the program. One of the things that is different about FMLA is that you can’t require an employee to use other paid leave available before using normal FMLA leave. You can identify the choices—it’s a menu of choices you have now that you didn’t have before. The second part is under the FFCRA, you can’t ask for the type of evidence that you could ask for under FMLA request before. That’s important because you do have to ask and maintain records on the request that are sufficient to qualify for the tax benefits that you need—the IRS requires it. For every request for the FFRCA, you must have in writing—the employee’s name, the date that leave is requested, the qualifying reason and an oral or written reason including why the employee can’t work including telework. If it’s for a son/daughter staying at home due to a school closure, you must have the child’s name and age, the name of the school/child care provider, a representation that no other suitable person can care for them during the time of the leave requested. There are additional requirements under FFCRA because of the tax credit as opposed to regular FMLA.

(Dr. Julie Gabel, State Department of Public Health Veterinarian) At this time, testing for asymptomatic people is NOT GENERALLY RECOMMENDED and has only been done in rare circumstances. For example, some testing of asymptomatic people who were passengers on the Grand Princess cruise ship was conducted before returning to the US. Public Health does not recommend testing for asymptomatic individuals. We still have limited testing capacity through the Public Health Lab, commercial and hospital laboratories.

Public Health is restricting testing to patients who are hospitalized with respiratory illness, symptomatic healthcare workers, and ill persons who live or work in congregate settings such as long-term care facilities, jails, etc. Many commercial laboratories are now offering testing and Public Health has free-standing testing sites, but patients must be referred by their healthcare provider or must meet certain criteria for testing such as ill healthcare worker, or patient with a compatible illness. In situations where healthcare workers are exposed, CDC’s guidance includes the option of testing asymptomatic healthcare workers but due to limited testing materials this is not being done in most jurisdictions. We are following CDC’s recommendations to exclude exposed healthcare workers for 14 days or allowing exposed healthcare workers who are asymptomatic to return to work and wear a mask, if staffing is critically low. Finally, CDC states that asymptomatic people who have tested positive are not thought to be driving the outbreak. In a nutshell, it is highly unlikely you would ever have any interaction with someone who tests positive and is asymptomatic, for all the reasons I just covered.

(Dr. Julie Gabel, State Department of Public Health Veterinarian) Persons who are confirmed or suspect for COVID-19 are subject to a strict home isolation for a defined period of time. But in an abundance of caution, it would be prudent for office staff when people call in schedule appointments to remind clients that they should stay home if they sick. Additionally, practices can determine if they want to completely eliminate having clients come into the office and do a curbside/parking lot drop off like many other types are businesses are doing. They also need to remind their own employees that it is critical for them to stay home if they are sick.”

(Dr. Julie Gabel, State Department of Public Health Veterinarian) Risk groups for severe disease include people 65 and older, and people with the following underlying conditions: chronic lung disease or moderate to severe asthma, significant cardiovascular disease, and immunocompromising conditions. Also included are people of any age with severe obesity, defined as body mass index or BMI >40, or other underlying medical conditions, particularly if not well controlled, such as diabetes, renal failure, or liver disease. In terms of deciding if someone at high risk should work, it would be prudent for them to discuss their risk with their healthcare provider. If practices are put in place to limit exposure to the general public as we previously discussed and are included in the COVID Guidance for Veterinary Clinics, the risk for exposure will be minimized. Another consideration would be to assign tasks to those with risk factors that would eliminate their interaction with the general public altogether if possible. Also important is to remind employees to stay home when they are sick.

(Dr. Julie Gabel, State Department of Public Health Veterinarian) Certainly, making house calls is associated with a greater risk for exposure and practices should weigh the benefit vs. risk of offering this service during the COVID-19 pandemic. As we discussed, communication with the client ahead of time to ask if there are any ill individuals in the home is critical. House calls to homes where clients are sick should be avoided. If the clients are well, and the veterinary staff feels confident that the client is reliable, then house calls could be considered.

(Dr. Julie Gabel, State Department of Public Health Veterinarian) Since close contact with clinic staff is unavoidable during euthanasia, out of an abundance of caution clients could be asked to wash their hands and wear a mask during the procedure, but the risk to the staff if the client is not sick is low. In these limited situations, veterinarians should ultimately decide how they want to handle euthanasia. I would also direct you to the guidance document to review the information we include on cleaning and disinfection, which will be an important to perform regularly if clients will be coming into the office.

From the GA SOS, under Rule 480-28-.07 (6) (DISPENSING OF DRUGS, Storage): A practitioner shall cause to be removed from stock all outdated and deteriorated drugs, at regular intervals of not more than six months duration, and under no circumstances will any practitioner permit any drug to be dispensed which bears a date of expiration which has been reached, or which is in a deteriorated condition.

http://rules.sos.ga.gov/GAC/480-28

The shelter in place order issued on 4/03 expired on 5/13. Governor Kemp issued another executive order on 5/12 covering the reopening of businesses. The main item that relates to veterinarians is #17 on pg. 11 concerning the use of PIN pads, which now can be used if disinfected frequently. Click here to read the executive order. For the sake of health & safety concerns, there should be no rush to get back to “normal” and the GVMA recommends that you continue observing the safety protocols that you have instituted for your staff and your clients.

The Georgia State Board of Veterinary Medicine has implemented Emergency Rules that affect continuing education requirements. CLICK HERE TO SEE THE RULE CHANGE

The Georgia State Board of Veterinary Medicine has implemented Emergency Rules that affect VCPR requirements. CLICK HERE TO SEE THE RULE CHANGE

The Georgia State Board of Veterinary Medicine has implemented Emergency Rules that affect VCPR requirements. CLICK HERE TO SEE THE RULE CHANGE

(Don Riddick, Esq., GMVA Legal Expert and Co-Owner, Benning Animal Hospital, Columbus)
No. Neither the VCPR nor the minimum standard of care has been waived due to COVID 19, including for telemedicine. You must still have sufficient information to initiate a preliminary diagnosis, and must only provide veterinary medicine within the minimum standard of care, which means that even where possible and permitted, you must ensure that while practicing veterinary medicine through electronic mediums, you are performing the same quality care as you would on premise, that you gain informed consent from the client, you keep records, and you are familiar with the animal through a physical exam or routine visits to the place of their care (for food and large animals). No one wants to be behind a story where a vet gives a misdiagnosis or treatment with adverse effects that is caused by insufficient information to perform veterinary medicines within the minimum standard of care, including being familiar with the animal you are providing care to.

I thought the FDA allowed relaxing laws on the VCPR, why is it not happening in Georgia and how does what they did affect anything here?

On March 24, 2020 the FDA directed that “the FDA generally does not intend to enforce the animal examination and premises visit portion of the VCPR requirements relevant to the FDA regulations governing Extralabel Drug Use in Animals and Veterinary Feed Directive (VFD) drugs. This will allow veterinarians to prescribe drugs in an extralabel manner or authorize the use of VFD drugs without direct examination of or making visits to their patients, which will limit human-to-human interaction and potential spread of COVID-19 in the community.”

However, the FDA did not overrule state requirements, their goal was merely not to make their requirement stricter than those of the States–“Although the FDA intends to temporarily suspend certain federal VCPR requirements, veterinarians still need to consider state VCPR requirements that may exist in their practice area.”

The DEA has guidance effective March 31st, that in certain circumstances, a controlled substance can be used to Evaluate patient in one of the following ways: in person, or via telemedicine using a realtime, two-way, audio-visual communications device… unless it is for buprenorphine.
In addition, there is new waivers for prescription refills from the DEA – “With respect to schedule III through V controlled substances, which can be refilled under the CSA, some states have issued orders allowing pharmacies to dispense early refills of prescriptions. Subject to the provisions of 21 CFR 1306.06, requiring a pharmacy only to dispense controlled substances in the usual course of professional pharmacy practice, and if the prescription meets the requirements of 21 CFR 1306.04(a), this practice may be permitted if the early dispensing is allowed by state law and regulation. In all cases, it bears repeating that every prescription for a controlled substance must be issued for a legitimate medical purpose by an individual practitioner acting in the usual course of professional practice and that a pharmacist bears a corresponding responsibility for the proper dispensing of controlled substances. See 21 CFR 1306.04(a). All prescriptions must also comply with applicable state laws. ”

Each of these waivers is limited to state laws, which does permit prescribing according to the requirements for telemedicine listed above.

(Dr. Jill Lancaster, GVMA President) Policy #14 of the Georgia Board of Pharmacy provides for refills of certain medication for up to 30 days for persons in the areas covered by a State of Emergency declared by the Governor of the State of Georgia. There have been no changes to compounding.

(Dr. Lee Myers, USDA APHIS VIC) USDA APHIS has posted guidance on their One Health website:

https://www.aphis.usda.gov/aphis/ourfocus/animalhealth/SA_One_Health

(Dr. Lee Myers, USDA APHIS VIC) There are no known cases of active infection with SARS-CoV-2 in domestic animals including pets at this time. Because the situation is ever-evolving, public and animal health officials may decide to test certain animals out of an abundance of caution. The decision to test will be made collaboratively between local, state or federal public and animal health officials.

At this time, testing for companion animals will only be done if animal and public health officials agree testing should occur due to a link to a known human case of COVID-19. We will not be testing the general companion animal population.

Who will collect the samples from animals?

After the decision is made to test, the state animal health officials will designate a state appointed veterinarian, USDA accredited veterinarian, or Foreign Animal Disease Diagnostician (FADD) to collect the sample using appropriate personal protective equipment and sample collection methods.

State animal health laboratories can/will conduct animal testing, but any positive samples would need to be confirmed through additional testing by USDA’s National Veterinary Services Laboratory.

UPDATED 4/16:

(Dr. Robert Cobb, State Veterinarian & Dr. Lee Myers, USDA APHIS AVIC) The routine testing of animals for COVID-19 is not recommended at this time. Currently, there is no evidence to indicate that animals are a source of infection with COVID-19 in humans. Information on testing of animals can be found at CDC, USDA, GA DPH, UGA Athens Diagnostic Lab and GDA State Veterinarian office.

If an animal is suspected of being infected with COVID-19, upon request by the attending veterinarian, the decision to test will be made jointly by the State Animal Health Veterinarian’s office and the Public Health State Veterinarians office.

Official testing will be done by regulatory officials or approved accredited veterinarians, utilizing approved sample collection and transport procedures, at approved state animal health laboratories. The collection of inappropriate samples and non-approved testing will lead to confusion, waste of critical supplies and possibly unnecessary exposure and spread of disease. The State Veterinarian’s office can be contacted at 404-656-3671. All testing should follow USDA/CDC recommendations and all positive tests must be confirmed by the National Veterinary Services Laboratory (NVSL). COVID-19 in animals is reportable to OIE once confirmed by NVSL. Practicing healthy habits when around animals is recommended.

See useful links below:

• http://agr.georgia.gov/COVID-19.aspx
• https://dph.georgia.gov/novelcoronavirus
• https://www.cdc.gov/coronavirus/2019-ncov/daily-life-coping/animals.html?CDC_AA_refVal=https%3A%2F%2Fwww.cdc.gov%2Fcoronavirus%2F2019-ncov%2Fprepare%2Fanimals.html
• https://www.aphis.usda.gov/animal_health/one_health/downloads/faq-sapho-on-companion-animal-testing.pdf
• https://www.avma.org/resources-tools/animal-health-and-welfare/covid-19
• https://www.gvma.net/2020/03/23/covid-19-resources/
• https://www.aavld.org/assets/1_Oasis2020/HomePage/COVID-19Info/AAVLD%20Guidance%20for%20SARS%20TestingF.pdf

The shelter in place order issued on 4/03 expired on 5/13. Governor Kemp issued another executive order on 5/12 covering the reopening of businesses. The main item that relates to veterinarians is #17 on pg. 11 concerning the use of PIN pads, which now can be used if disinfected frequently. Click here to read the executive order.

For the sake of health & safety concerns, there should be no rush to get back to “normal” and the GVMA recommends that you continue observing the safety protocols that you have instituted for your staff and your clients.

(Don Riddick, Esq., GVMA Legal Expert) The answer is you are not required to have a physical signature on a consent form—it just needs to be in the medical record (so you could have an email or text as consent as well).

There is no longer a requirement to keep the 6’ distance.

The shelter in place order issued on 4/03 expired on 5/13. Governor Kemp issued another executive order on 5/12 covering the reopening of businesses. The main item that relates to veterinarians is #17 on pg. 11 concerning the use of PIN pads, which now can be used if disinfected frequently. Click here to read the executive order. For the sake of health & safety concerns, there should be no rush to get back to “normal” and the GVMA recommends that you continue observing the safety protocols that you have instituted for your staff and your clients.

(Dr. Robert Cobb, State Veterinarian) To date, there is no evidence that domestic animals including pets can spread SARSCoV-2.

(Dr. Robert Cobb, State Veterinarian) At this time, there is no reported evidence of pets or other domestic animals (livestock) becoming sick from COVID-19 or as a source of infection. There have been reports of dogs with weak positive tests from China; however, no serological conversion has been demonstrated. A private lab (IDEXX) has reported thousands of tests of dogs and cats performed for SARS-CoV-2 on animals. All have been negative.

However, please keep in mind that animals in close contact with humans that are sick, may become contaminated by droplets from coughing, etc. More research is needed to determine if this is a risk for infection. At this time, there is no evidence that animal skin or fur can spread the virus.

Just like social distancing with people, practicing healthy habits such as washing hands and cleaning up after handling animals are recommended to aid in preventing the spread of the virus. CDC, AVMA, USDA and Georgia Department of Public Health have some very good guidance. Better to err on the side of caution until more research can be accomplished.

(Dr. Robert Cobb, State Veterinarian) More research is needed. The virus is not hardy and is easily killed with disinfection. Similar to other coronaviruses, it is thought to live up to 9 days on inanimate objects. High temperatures and high humidity (sounds like Georgia) may decrease increase the virus’ survivability. It may be possible that a person can get COVID-19 by touching a surface or object that has the virus on it and then touching their own mouth, nose, or possibly their eyes, but this is not thought to be the main way the virus spreads. Respiratory droplets is the main pathway.

At this time there is no evidence to support that animal skin or fur can spread the virus.

For disinfection of inanimate objects (doorknobs, counters, etc.), emerging virus approved disinfection products should be used after cleaning. A list can be found at EPA. Appropriate PPE should be used, and healthy habits should be followed (wash hands and equipment afterward). Use dedicated equipment.

For washing of canines or other domestic animals, routine bathing should be adequate. Animals from an infected household should remain in the household if possible to minimize the risk of spreading the virus. If this is not possible and the animal comes in from an infected household, appropriate PPE should be worn during bathing and animals should be segregated – just as you would when around a person.

(Dr. Robert Cobb, State Veterinarian & Dr. Lee Myers, USDA APHIS AVIC) The routine testing of animals for COVID-19 is not recommended at this time. Currently, there is no evidence to indicate that animals are a source of infection with COVID-19 in humans. Information on testing of animals can be found at CDC, USDA, GA DPH, UGA Athens Diagnostic Lab and GDA State Veterinarian office.

If an animal is suspected of being infected with COVID-19, upon request by the attending veterinarian, the decision to test will be made jointly by the State Animal Health Veterinarian’s office and the Public Health State Veterinarians office.

Official testing will be done by regulatory officials or approved accredited veterinarians, utilizing approved sample collection and transport procedures, at approved state animal health laboratories. The collection of inappropriate samples and non-approved testing will lead to confusion, waste of critical supplies and possibly unnecessary exposure and spread of disease. The State Veterinarian’s office can be contacted at 404-656-3671. All testing should follow USDA/CDC recommendations and all positive tests must be confirmed by the National Veterinary Services Laboratory (NVSL). COVID-19 in animals is reportable to OIE once confirmed by NVSL. Practicing healthy habits when around animals is recommended.

See useful links below:

• SARS-CoV-2 Case Definition from USDA (4/29)
• http://agr.georgia.gov/COVID-19.aspx
• https://dph.georgia.gov/novelcoronavirus
• https://www.cdc.gov/coronavirus/2019-ncov/daily-life-coping/animals.html?CDC_AA_refVal=https%3A%2F%2Fwww.cdc.gov%2Fcoronavirus%2F2019-ncov%2Fprepare%2Fanimals.html
• https://www.aphis.usda.gov/animal_health/one_health/downloads/faq-sapho-on-companion-animal-testing.pdf
• https://www.avma.org/resources-tools/animal-health-and-welfare/covid-19
• https://www.gvma.net/2020/03/23/covid-19-resources/
• https://www.aavld.org/assets/1_Oasis2020/HomePage/COVID-19Info/AAVLD%20Guidance%20for%20SARS%20TestingF.pdf

(Mark Murrah, Georgia Department of Agriculture Manager, Companion Animal/Equine) Georgia shelters are not allowed to practice TNR unless they provide an outgoing record that gives the name, address, and contact information of the new owner. So essentially, TNR isn’t allowed by licensed Georgia Animal shelters. Also shelters should limit people coming in to bring in animals since they increase the risk of COVID-19 being transferred.

If an owner has tested positive for COVID-19, keep the animal at home if there is another caregiver do not bring to a shelter/animal control unless there is no one available to care for the animal.

Although we are aware that NACA and other groups may recommend that unaltered animals be released during the Covid-19 event at this time there is no exemption to the Georgia Sterilization Act that requires that the shelter make provisions for the sterilization of all dogs and cats acquired from such shelter by providing sterilization by a licensed veterinarian before relinquishing custody of the animal or entering into a written agreement with the adopter of the animal guaranteeing that sterilization will be performed within 30 days after acquisition. We have had requests from shelters that want to place more animals in foster. GDA has allowed virtual foster inspections to facilitate the addition of temporary fosters. It is worth mentioning that GDA cannot issue exemptions to a GDA rule or regulation. That said, we may be able to promulgate emergency rules in certain dire situations.

(Don Riddick, Esq., GVMA Legal Expert and co-owner of Benning Animal Hospital in Columbus) We assign Google voice phone numbers to key staff. We also use Zoom meetings for internal meetings to avoid the need for exposing their numbers.

(Don Riddick, Esq., GVMA Legal Expert and co-owner of Benning Animal Hospital in Columbus) We have a cloud based medical record system and I can give them access away from our office IP address. I know others use a VPN into their office so they can log on like they were in the office.

(Don Riddick, Esq., GVMA Legal Expert)

• Telehealth – This is broader than telemedicine and goes far beyond telemedicine. It is the overarching term that encompasses all uses of technology to deliver health information, education or care remotely. Telehealth can be divided into categories based on who is involved in the communication.
• Telemedicine – This involves the use of a tool to exchange medical information electronically from one site to another to improve a patient’s clinical health status. You use technology to perform telemedicine. In order to practice telemedicine, you need to have a VCPR—that you have sufficient knowledge of the animal to issue a preliminary diagnosis and you have seen the animal by physical exam within the last year (The Georgia State Board of Veterinary Medicine has implemented Emergency Rules that affect VCPR requirements. CLICK HERE TO SEE THE RULE CHANGE) or timely visits to the premises where the animal is kept (if it is a herd). Those are the basics of what you need.
  Examples include anything you would use to communicate with a client and visually observe the patient for examination/discussion:
  • Skype
  • Mobile app such as Face Time or Messenger
  • Text
  • Phone Call
• Teleadvice – This is where you provide general information that is not a diagnosis and is not specific to any animal. It is very general in nature. AVMA defines it as the provision of any health information, opinion, guidance or recommendation concerning prudent future actions that are not specific to a particular patient’s health, illness or injury. This is general advice that is not intended to diagnose, prognose, treat, correct, change, alleviate, or prevent animal disease, illness, pain, deformity, defect, injury, or other physical, dental, or mental conditions. Examples include recommendations made by veterinarians or non-veterinarians via phone, text or online that all pets should receive annual wellness exams as part of a comprehensive preventive care plan, or that animals living in mosquito-infested areas should receive year-long heartworm preventatives.
• Teleconsulting – This is where you remotely contact an expert or diagnostic lab or tool to provide information that you use in your practice of veterinary medicine. It is a subcategory of telehealth in which a general practice veterinarian uses telehealth tools to communicate with a veterinary specialist to gain insights and advice on the care of a patient.
• Teletriage – This is one where there is some confusion as to whether this is really telemedicine. It is where you take information to assess the condition of the patient to determine whether the animal should be seen. You are not saying what the problem is or diagnosing it—you are helping the client make a good and safe decision about the urgency of them being seen or cared for by a professional. This can be done without a VCPR and can be done for anyone in the state of Georgia. The AVMA definition is that it is a safe, appropriate, and timely assessment and management of patients via electronic consultation with their owners. In assessing patient condition electronically, the assessor determines urgency and the need for immediate referral to a veterinarian, based on the owner’s (or responsible party’s) report of history and clinical signs, sometimes supplemented by visual (e.g., photographs, video) information. A diagnosis is not rendered. The essence of teletriage is to make good and safe decisions regarding a patient’s disposition (immediate referral to a veterinarian or not), under conditions of uncertainty and urgency.

(Don Riddick, Esq., GVMA Legal Expert)

• Licensure—You must be a licensed veterinarian in the state of Georgia.
• State of Georgia Practice Act – You must have a valid VCPR—under the updated Practice Act, that means you must have informed consent as one of the components of establishing the VCPR. That does not mean that you must have a signed or electronic statement. It means that in the medical record, you will identify that you presented the options, the prognosis for the various treatments and they made a decision on how they wanted to move forward. That is informed consent. You do not necessarily have to have a consent form in the state of GA in order for a consent to be valid.
• Pharmacy regulations—Regardless of what the State Board of Veterinary Medicine in GA determines, for the use of any scheduled substance and the prescription of it, that is still subject to the federal rules and their VCPR which does not allow telemedicine. Similar with the FDA for feed directives and for food animal—has not alleviated their normal standard for the VCPR. Even if you are trying to prescribe for example a treatment for bee hive—under the FDA guidelines, you must have a valid VCPR. NOTE: The FDA has relaxed their stance on the VCPR during this pandemic—however, you must still observe the VCPR stipulations that are in your state’s Practice Act.
• Record retention—You have to keep records just as you would if a client came in for a visit. Keeping your records that is part of the VCPR as of 2018 and so all of the elements that you would normally keep for a medical record are the same ones you would need for telemedicine. Because you don’t have signed forms, taking a picture or an image of a text message is permissible. Recording them without their consent is not. So if you need to confirm something or you need something in writing from them, ask them to text it or email it or transcribe it yourself. If you get the consent to video ahead of time as part of the telemedicine application that you are using, that is fine.
• Patient confidentiality—you have an ethical duty to keep your client’s records confidential. Remember that they can always ask for a copy of their records and that the practice owns the record—not the client or an individual doctor. The client is always entitled to a copy of the record.

(Don Riddick, Esq., GVMA Legal Expert)

Yes. Teletriage can be offered outside of a VCPR because you aren’t giving a diagnosis or identifying treatment. You are only taking in the information and directing them to care that is appropriate. You aren’t actually making a diagnosis or practicing veterinary medicine that would require a VCPR. You can continue to do teleconsulting and teleadvice but what you can’t do is give a specific response on a specific condition of an animal without a VCPR. The VCPR doesn’t require that you physically see the client—it requires that you see the patient and that you gain the client’s consent. You have to have seen the animal in the last year—not the human.

The Georgia State Board of Veterinary Medicine has implemented Emergency Rules that affect VCPR requirements. CLICK HERE TO SEE THE RULE CHANGE

(Don Riddick, Esq., GVMA Legal Expert)

Your liability for doing telemedicine if you have a valid VCPR and are staying within the minimum standard of care, you do not have liability for animal cruelty. You do not have the pain and suffering damages available to you because for the practice of veterinary medicine, the law establishes the value of the animal at the time presented. However, if you are not practicing as a validly licensed veterinarian with a valid VCPR and you are not performing the legal practice of veterinary medicine, then those waivers of liability may not apply. Your liability is expanded if you don’t follow all of the requirements of the VCPR and of the Practice Act as interpreted by the State Board of Veterinary Medicine.

Making sure that you have sufficient information to initiate at least a preliminary diagnosis is critical with telemedicine and you should be willing and able to say that you don’t have enough information from what I am seeing on the screen or from what you have told me so we’re going to need to see the animal or you need to go to a veterinarian that can see the animal.

The second question about insurance—what I can tell you is that if you have an undisclosed risk, it may not be covered by the policy so if you are really concerned about telemedicine—particularly if you don’t have AVMA PLIT insurance, I would call your insurer to make sure that it’s covered. Some policies do and some policies are location specific. You must make sure you don’t have a premise specific insurance policy in which case this would not apply.

(Don Riddick, Esq., GVMA Legal Expert)

There are 2 types of consent–the first one is an informed consent for the treatment. This means you have to make reasonable efforts—verbal or in writing—of all of the diagnostic and treatment options/risk assessment and prognosis which are appropriate, probable in the case of your veterinary judgement following the standard of care. That is one form of consent.

There is another consent that you need to do related to telemedicine—explain to them the limitations of telemedicine when you start. So the AVMA has some guidance on this that I think is very good, which essentially says—we’re going to try telemedicine but if I don’t have enough information to practice the best quality care through telemedicine, we may have to choose another option. There are some things that I am not able to diagnose or to provide through telemedicine-if you’re willing to work within those constraints, then I can provide a telemedicine session with you. If they say yes—great. If they say “I don’t know, should I come in?”, you have to present them with the informed consent—the full option of here are the limitations of telemedicine and you have the option to come in if you prefer.

(Dr. Andrea Dunnings, Practice Owner, East Atlanta Animal Clinic, Atlanta) We use an app based platform. The client downloads the app for their phone. We use the Vet version of the app on our cell phones, and there is a dashboard that can be accessed through the internet. When we first started using the platform, our Practice Manager submitted test cases through the client version, and I responded through the dashboard. Once the vet version of the app became available, we did the same process using the cell phone. I think this step is important. It allows you to see what the process looks like for the client. This also allows the staff to become familiar with how to use the platform.

(Dr. Jacqueline Horner, Associate, Pharr Road Animal Hospital, Atlanta) There are many telemedicine options available, mostly apps or desktop services (GVMA has complied a list on their site). We use either our cell phone with the app downloaded or the hospital computer, preferably a laptop with a camera. Once we downloaded/purchased our app, we set up the admin account and then set up a “client account” with our own animal(s). In this way, we were able to role play and experiment with the app to get familiar with the software prior to using it real time with our clients.

(Dr. Andrea Dunnings, Practice Owner, East Atlanta Animal Clinic, Atlanta) There were only a few platforms available for veterinary practices when I first started to research telemedicine. I researched all of them and compared features. The one I chose had the following features:

• ease of use for the staff and the client,
• payment collection with automatic bank deposit,
• three client communication options, and
• text, phone and video.

Also, one really important factor for me was to have the ability to not charge the client. I thought it would be important to help maintain goodwill with clients. Because this was unchartered territory, I knew there would be cases that we would not want to address through telemedicine. So, if I had to tell a client they needed to bring a pet in being able to say we will not charge your card for the consult makes for a better client experience. Most of the applications at the time had their own disclaimers for liability that protects their company. This may have changed with some of the newest platforms. Our legal advisor created a consent form for us to use. Do your research and check with your liability carrier to see what coverage is available for your practice.

(Dr. Jacqueline Horner, Associate, Pharr Road Animal Hospital, Atlanta) In the case of Pharr Road, we attended a CE meeting about telemedicine and had the opportunity to meet with the creators of the app we currently use. They walked us through a demo of the product and allowed us a trial period, which was very helpful. The app was user friendly as well, which solidified the choice. This particular company did not require separate liability insurance coverage.

(Dr. Andrea Dunnings, Practice Owner, East Atlanta Animal Clinic, Atlanta) To define our service offering, we looked at it from an internal perspective and from the client (external) perspective. Before we officially launched the service, the doctors discussed basic types of cases we felt were appropriate to address through telemedicine. We looked at the types of phone call discussions we were having with clients as a potential source for telemedicine cases. Also, medical progress exams that were primarily follow ups with the clients to answer questions were pushed to telemedicine. For client convenience, we initially offered the service 7 days per week. We did not know what types of consultations we would get after hours. After several months we started to get a feel for what we felt comfortable addressing, and the types of issues clients were requesting consultations for. With both of these considerations in mind, we were able to decide on a basic list of appropriate consultations. Please keep in mind that service offerings will probably vary for each practice. Demographics, clinic hours, clinic location may all play a part in which services you include on your list

(Dr. Jacqueline Horner, Associate, Pharr Road Animal Hospital, Atlanta) We first started by having one doctor identify ideal cases with our best clients on the schedule, and then directly offered it to those clients for a reduced price until we got comfortable. From there, we had a doctor meeting to get all DVMs trained, walked them through the provided training videos, then familiarized them with the desktop and smartphone software. Once everyone’s doctor accounts were set up, we rolled it out fully for the outbreak. I’m happy to share our email client invitation template and the email sent out to our clients. This was offered as an in-between option for those clients who weren’t sure if their pet’s problem warranted a hospital visit OR if they were unable to safely bring the patient in due to client health concerns/risks.

(Dr. Andrea Dunnings, Practice Owner, East Atlanta Animal Clinic, Atlanta) This was a natural evolution for us out of necessity. We originally had it set up where one of the doctors was always available on a day off from work to handle telemedicine consultations. When the caseload started to pick up, it became necessary for one of us to handle a consult while at work. We found that doing this between appointments usually worked out fine. It was really no different from making calls between appointments. If the day was hectic, we would text the client with a call time and schedule the consult in the dashboard so it would trigger a reminder for the doctor. For example, if a consult comes in first thing in the morning the Practice Manager will contact the doctor and coordinate scheduling a time with the client.

(Dr. Jacqueline Horner, Associate, Pharr Road Animal Hospital, Atlanta) If the client would like to do a video or phone call, we schedule them in as appointments on our schedule. The doctors do this, as they are the ones communicating with the client via the telemedicine app. Many of our clients like to resolve things via the chat or text message format, which doesn’t require a booked time.

(Dr. Andrea Dunnings, Practice Owner, East Atlanta Animal Clinic, Atlanta) We have not had many issues with the doctor working from home. Sometimes the timing of a consultation has not always been convenient for the doctor. For example, if the doctor is at the grocery store when a consult comes in, she will text the client and say can I contact you in 30 minutes. Clients are amazingly flexible with this. If your practice is not set up for off -site access this may be something to consider if you have someone working from home. All of our doctors have access to our PMS system so it is easy for them to log into the system to look at records, put prescriptions in or communicate with the staff as it relates to a consultation. I personally think this is very important so your team can readily verify the existence of a valid VCPR. We have had a client try to use the platform for a feral cat. We have also had inactive clients submit consults that were declined as a result.

(Dr. Jacqueline Horner, Associate, Pharr Road Animal Hospital, Atlanta) As long as you have remote access to the patient record from home, there is no issue with telehealth at home. Make sure that your staff is comfortable with doing this. Work/Life balance can be an issue, so be sure to have a schedule for who will be handling telemed appointments that day and have a policy on what to do if a client specifically requests a doctor that is currently off the clock.

(Dr. Andrea Dunnings, Practice Owner, East Atlanta Animal Clinic, Atlanta) We do not really get into treating ears unless it is a drastic situation. We had one consult come in where the owner was out of state and he felt that the dog was having an ear infection. The dog did have a history of an ear infection a few months prior. We did not feel comfortable prescribing meds but did discuss with the owner how to clean the ears and what to look for in terms of progression. We were also able to give him the number to a local clinic where the classmate of a doctor worked. The client was very satisfied with our resolution. Skin consultations can be done if you have a proper history and previous records. Having the client use the zoom feature on their camera can really help with visualization. You can see redness, flakes, and pustules pretty easily. More importantly it is more about the communication with the client and asking appropriate questions. This is also a teaching moment for clients as you instruct them how to brush the hair backward. Or, statements like this area must be itchy see how he started to kick with his leg, etc…

(Dr. Jacqueline Horner, Associate, Pharr Road Animal Hospital, Atlanta) History of recurrent skin or ear infections is a pre-requisite for our patients to use telemedicine. If it’s a new issue, they must come in for a proper otic and dermatologic exam. Otherwise, I would choose medications that are safe for ruptured ear drums OR clearly warn the owner of the risks of administering otic medications without performing an exam of the tympanic membrane. Warn them of symptoms of ototoxicity. If they are concerned, they should bring the pet in for a traditional exam. For skin infections, if you are concerned about multi-drug resistance, seeing them for a visit may be a requirement in order to collect culture samples. Otherwise, I recommend treating with a broad spectrum cephalosporin for 1 week past normal skin (usually about 3 weeks), and rechecking the skin via telemedicine 2 weeks into therapy.

(Dr. Andrea Dunnings, Practice Owner, East Atlanta Animal Clinic, Atlanta) Most of the consults done in-house are in the doctor’s office or the Practice Manager’s office. The noise is usually limited. Very rarely do we have an issue. If anything, I think the client acknowledges that we are busy and have other patients. However, if you are going to use the platform for more of a concierge experience I do think all of those factors become more important. So having a nice picture or backdrop that you can place in a quiet nook should be easy enough to do. Don’t let a small thing like wall coverings keep you from doing video calls. They provide more of a personal touch and a lot of clients really prefer them over a phone call.

(Dr. Jacqueline Horner, Associate, Pharr Road Animal Hospital, Atlanta) Since clients and patients are no longer coming into exam rooms, we typically find a quiet, unoccupied exam room or our doctor office to hold these calls.

(Dr. Andrea Dunnings, Practice Owner, East Atlanta Animal Clinic, Atlanta) We have had quality of life consultations with some of our elderly clients for their senior pet. We also have eased our policy on addressing eye issues via telemedicine. We had one case where the owner had a newborn baby at home and justifiably did not want to bring the pet in. So we did a video call and were able to talk things through. Luckily it was not a severe problem. We were able to do a home delivery for her which we also normally do not do. We are asking ill clients not to bring their pet in. We want them to request a telemedicine consult instead. We have actually had a few clients who are actively in quarantine utilize the service as a result. In these cases, we were able to provide home delivery and come up with the best possible plan once everyone in the house was clear.

(Dr. Jacqueline Horner, Associate, Pharr Road Animal Hospital, Atlanta) We are doing our best to email all discharges digitally and schedule post-op exams via telemedicine. We are trying to triage as many non-essential cases as we can. Many things like allergy symptoms or non-painful conjunctivitis can be managed this way without having the pet come in.

(Dr. Andrea Dunnings, Practice Owner, East Atlanta Animal Clinic, Atlanta) We have four doctors including myself that are on the service. The Practice Manager and two RVTs are listed as nurses which allows them to triage cases and assign them to a doctor. We initially did demo cases with the entire staff so that everyone could ask questions and become familiar with the platform. Now when we add a new staff member we will do a test case where they pretend to be the client. Once we developed a general guideline for appropriate types of consultations, we discussed it in a staff meeting. We read through one of the resolved cases on the list so they could understand how it was resolved. We then walked through the next steps with the client in terms of medications dispensed and when to follow up. We also reviewed all of our promotional content and material with the staff.

(Dr. Jacqueline Horner, Associate, Pharr Road Animal Hospital, Atlanta) All DVMs are using the app and desktop software. A few of our level 3 vet techs are starting to learn how to triage and we instituted some training guidelines for our reception team to know which cases may be good ones for telemedicine. Oftentimes they are double checking with a doctor or RVT, and then emailing the client invitation template to get them set up with the app. Once the client submits a consultation request, a doctor evaluates the case and decides if ultimately the patient should come in or not. If the patient ends up needing to come in, we do NOT charge them twice.

(Dr. Andrea Dunnings, Practice Owner, East Atlanta Animal Clinic, Atlanta) We priced our initial consultation fee about $15 less than our regular exam fee. The follow up fee is the same as our in clinic medical progress exam. We considered what we were paying the doctor who was the primary service provider at the time. We wanted to make sure that the fee was attractive enough to generate enough volume to make it lucrative for her and the practice. Obviously, the more staff you involve the more you have to account for their time. When you are first getting started, there will be a learning curve so a consult may take you 20-25 minutes. On average, our consults take 10-15 minutes maximum. I would advise that you also consider how you are using the service and your overall goal with telemedicine. If you are providing after hours consults or triage, I think you can set your fees higher. I know of some clinics that have bundled a consult into their surgery fee and then do video chats as part of the post-op follow up. I know of another practice that includes the consult fee in all of their surgeries and then send video of the pet being prepped for surgery and resting during recovery. Since we no longer have clients entering the building we are currently in the process of bundling a consult into our New Client Exam. I am hopeful this will allow us to bond with the client more and increase the value to them.

(Dr. Jacqueline Horner, Associate, Pharr Road Animal Hospital, Atlanta) We have two flat rates: full consultation (new problem/concern, only $3 less than in-hospital exam) and recheck consultation (free for post-ops, $7 less for true rechecks like skin). We modeled them as closely to our in-hospital cost as we could. The software company takes $5 per consultation. Later, once things are more streamlined and this is more of a luxury rather than a need, we will likely increase the price.

View the SARS-CoV-2 Case Definition from USDA (4/29)

(Dr. Julie Gabel, State Department of Public Health Veterinarian) We are starting to widespread experience shortages in PPE in human medical facilities and hospital systems – some are re-using masks and other equipment. Human hospitals experiencing shortages can request PPE through the State Operations Center at GEMA but supplies are limited. Veterinary practices should consider taking an inventory of their PPE supplies and consider if or how they might need to ration their knowing that they may not have access to additional PPE in the coming weeks due to widespread shortages.

The Department of Public Health Administrative Order doesn’t specify that level of detail other than veterinary practice is deemed an essential business. Human healthcare facilities are postponing elective procedures but clearly a very different situation due to the fact that they are making preparations for a tremendous surge in patients due to COVID-19. I personally think immunizations are critical, particularly with regard to rabies as we don’t want companion animals at risk and also for the zoonotic potential of some of the other diseases.

(Dr. Robert Cobb, State Veterinarian) As mentioned in the guidance documents from Homeland Security and DPH, veterinarians are essential to maintain animal and public health. However, I believe this status does not give a free pass to do things that are non-essential. The Governor has issued several Executive Orders. They should be followed.

I feel that disease prevention is as important as disease treatment. In this time of COVID-19, I feel that routine annual check-ups and vaccinations can and should be postponed within a reasonable time. On the other hand, Initial vaccinations of puppies and kittens for zoonotic (Rabies) and life threating diseases are needed in a timely manner. An evaluation of the risk to the patient and staff should be determined in making the decision whether or not to postpone vaccine visits. I feel that veterinarians should do their part to minimize the spread of this virus. Practice owners should conserve and balance their supply of PPE.

In order to provide essential services for our animals, veterinarians are recommended to practice social distancing and limit exposure for themselves and their staff. Reducing risks by postponing non-essential services, routine annual check-ups, non-emergency surgeries and utilizing curbside service, segregation and isolation of clients and patients are recommended. Providing staff with necessary animal disease biosecurity training and proper PPE are essential.

As part of a statement that went out on 3/31 from GVMA President Jill Lancaster—GVMA recommendations on procedures are as follows:
Similar to measures to control parvovirus and other infectious diseases, it is even more important to understand how the profession could act as an unintentional vector spreading COVID-19 throughout the community due to lax protocols while dealing with the public. At this time, the GVMA is strongly recommending that ALL veterinary facilities implement new methods for interacting with clients:

• Discussion with client about procedure and receiving payment through mobile, computer, or phone prior to client coming into the practice;
• Client calls upon arrival and a staff member goes outside to pick up the animal;
• Telemedicine is used wherever possible (abiding by the rules in our practice act that establish VCPR);
• Curbside delivery of food, medications, etc. where client opens door or trunk of vehicle without any contact with staff.

To maintain continuity of veterinary activity in conjunction with keeping your staff and clientele safe, we strongly recommend the following:

• Postpone Services/Treatments for:
  • Spays
  • Neuter
  • Breeding services/artificial inseminations
  • Non-essential surgery
  • Dentals without severe oral disease
  • Monitoring of chronic illness when an animal is stable

• Essential services:
  • Surgical and emergency medical procedures
  • Rabies vaccines
  • Vaccinations on puppies and kittens
  • Parasitic control (especially those that are zoonotic or if an animal welfare issue)
  • Acute conditions
  • Condition that will affect the comfort and life expectancy of the animal
  • Management of populations at risk of infection (shelters, animal control, farms)

(Dr. Robert Cobb, State Veterinarian & Dr. Lee Myers, USDA APHIS AVIC)

Large animal veterinarians and staff are critical to maintaining our food supply. Practicing social distancing, proper utilization of PPE and limiting farm visits and interaction to essential duties is important to minimize exposure. Utilizing strict biosecurity measures and PPE will help prevent the spread of disease.

Food animal veterinarians play a key role in maintaining a safe, secure, and stable food supply. Access to clients and patients is a necessary part of this responsibility, so it is critical to actively incorporate preventative measures into facility visits. To help with that, AVMA has published considerations for food animal veterinarians during the COVID-19 pandemic. https://www.avma.org/resources-tools/animal-health-and-welfare/covid-19/considerations-food-animal-veterinarians-during-COVID-19-pandemic

The American Association of Bovine Practitioners (AABP) have developed several COVID-19 resources for its members and all veterinarians who work with cattle. https://aabp.org/members/resources/AABPcv19info.pdf

The Georgia State Board of Veterinary Medicine has implemented Emergency Rules that affect VCPR requirements. CLICK HERE TO SEE THE RULE CHANGE

——

(Don Riddick, Esq., GVMA Legal Expert and Co-Owner, Benning Animal Hospital, Columbus)

The minimum standard of care has not been waived due to COVID-19. You must still have sufficient information to initiate a preliminary diagnosis, and must only provide veterinary medicine within the minimum standard of care, which means that even where possible and permitted, you must ensure that while practicing veterinary medicine through electronic mediums, you are performing the same quality care as you would on premise, that you gain informed consent from the client, you keep records, and you are familiar with the animal through a physical exam or routine visits to the place of their care (for food and large animals). No one wants to be behind a story where a vet gives a misdiagnosis or treatment with adverse effects that is caused by insufficient information to perform veterinary medicines within the minimum standard of care, including being familiar with the animal you are providing care to.

I thought the FDA allowed relaxing laws on the VCPR, why is it not happening in Georgia and how does what they did affect anything here?

On March 24, 2020 the FDA directed that “the FDA generally does not intend to enforce the animal examination and premises visit portion of the VCPR requirements relevant to the FDA regulations governing Extralabel Drug Use in Animals and Veterinary Feed Directive (VFD) drugs. This will allow veterinarians to prescribe drugs in an extralabel manner or authorize the use of VFD drugs without direct examination of or making visits to their patients, which will limit human-to-human interaction and potential spread of COVID-19 in the community.”

However, the FDA did not overrule state requirements, their goal was merely not to make their requirement stricter than those of the States–“Although the FDA intends to temporarily suspend certain federal VCPR requirements, veterinarians still need to consider state VCPR requirements that may exist in their practice area.”

The DEA has guidance effective March 31st, that in certain circumstances, a controlled substance can be used to Evaluate patient in one of the following ways: in person, or via telemedicine using a realtime, two-way, audio-visual communications device… unless it is for buprenorphine.
In addition, there is new waivers for prescription refills from the DEA – “With respect to schedule III through V controlled substances, which can be refilled under the CSA, some states have issued orders allowing pharmacies to dispense early refills of prescriptions. Subject to the provisions of 21 CFR 1306.06, requiring a pharmacy only to dispense controlled substances in the usual course of professional pharmacy practice, and if the prescription meets the requirements of 21 CFR 1306.04(a), this practice may be permitted if the early dispensing is allowed by state law and regulation. In all cases, it bears repeating that every prescription for a controlled substance must be issued for a legitimate medical purpose by an individual practitioner acting in the usual course of professional practice and that a pharmacist bears a corresponding responsibility for the proper dispensing of controlled substances. See 21 CFR 1306.04(a). All prescriptions must also comply with applicable state laws.”

Each of these waivers is limited to state laws, which does permit prescribing according to the requirements for telemedicine listed above.

(Dr. Robert Cobb, State Veterinarian & Dr. Lee Myers, USDA APHIS AVIC) When the practice is unable to provide a safe environment for clients and staff or is unable to provide necessary veterinary care, the practice should evaluate the options available. The closure of a veterinary practice will be related to the practice owner’s decision and in consultation with the Department of Public Health’s recommendations.

(Dr. Robert Cobb, State Veterinarian & Dr. Lee Myers, USDA APHIS AVIC) The routine testing of animals for COVID-19 is not recommended at this time. Currently, there is no evidence to indicate that animals are a source of infection with COVID-19 in humans. Information on testing of animals can be found at CDC, USDA, GA DPH, UGA Athens Diagnostic Lab and GDA State Veterinarian office.

If an animal is suspected of being infected with COVID-19, upon request by the attending veterinarian, the decision to test will be made jointly by the State Animal Health Veterinarian’s office and the Public Health State Veterinarians office.

Official testing will be done by regulatory officials or approved accredited veterinarians, utilizing approved sample collection and transport procedures, at approved state animal health laboratories. The collection of inappropriate samples and non-approved testing will lead to confusion, waste of critical supplies and possibly unnecessary exposure and spread of disease. The State Veterinarian’s office can be contacted at 404-656-3671. All testing should follow USDA/CDC recommendations and all positive tests must be confirmed by the National Veterinary Services Laboratory (NVSL). COVID-19 in animals is reportable to OIE once confirmed by NVSL. Practicing healthy habits when around animals is recommended.

See useful links below:

• http://agr.georgia.gov/COVID-19.aspx
• https://dph.georgia.gov/novelcoronavirus
• https://www.cdc.gov/coronavirus/2019-ncov/daily-life-coping/animals.html?CDC_AA_refVal=https%3A%2F%2Fwww.cdc.gov%2Fcoronavirus%2F2019-ncov%2Fprepare%2Fanimals.html
• https://www.aphis.usda.gov/animal_health/one_health/downloads/faq-sapho-on-companion-animal-testing.pdf
• https://www.avma.org/resources-tools/animal-health-and-welfare/covid-19
• https://www.gvma.net/2020/03/23/covid-19-resources/
• https://www.aavld.org/assets/1_Oasis2020/HomePage/COVID-19Info/AAVLD%20Guidance%20for%20SARS%20TestingF.pdf

Based on recommendations from the USDA/CDC/AVMA and our state officials:

• Routine testing is still not recommended at this time. Since supplies (chemical reagents) are limited within the human health field, testing of animals should not be routine practice. Also, a large majority of the reagents come from China—so the logistics regarding supply chain has become a problem as well.
• At this time, there is no evidence that animals play a significant role in spreading SARS-CoV-2, the virus that causes COVID-19.
• Our state officials are not changing their protocol that a collaborative effort between the state veterinarian and state PH veterinarian is needed to determine if an animal warrants testing. This is with the understanding that the animal came from a household with a confirmed COVID-19 owner.
• If an animal is suspected of being infected with COVID-19, upon request by the attending veterinarian, the decision to test will be made jointly by the State Animal Health Veterinarian’s office and the Public Health State Veterinarians office.
• The State Veterinarian’s office can be contacted at 404-656-3671.

The CDC published guidelines for veterinary facilities on 4/22. This has a chart with precautionary measures and how to deal with patients from healthy or suspected COVID-19 households.

https://www.cdc.gov/coronavirus/2019-ncov/community/veterinarians.html

(Dr. Duffy Jones, Owner, Peachtree Hills Animal Hospital) March 16 was when we went to curbside service. We tried to make it voluntary but had to make it mandatory on March 17 because we had way too many people coming into the office. I made the decision the week before because I had some other vets who I regularly talk to across the country who were in harder hit spots that said people were coming in and coughing all over their staff. We started emails and Facebook posts the Friday before and continue every day through the next two weeks. We did slow them down as things started to settle into the new normal.

(Dr. Keri Riddick, Owner, Benning Animal Hospital) The week of March 16th we began limiting staff interaction with clients, limiting the number of clients in the exam rooms, closed our lobby, and not allowing children in the building. The clients were continuing to do the things that they’d always done so we had to changet that. By the end of the week, we began practicing curbside and drop off services only. We have used our website and Facebook page to communicate how we adapting to new recommendations and protocols as well as posting brightly colored signs on our entrances and exit.

(Dr. Duffy Jones, Owner, Peachtree Hills Animal Hospital) We used a combination of email, FB, and we text everyone before their appointment, so we used what we were currently doing but went to an everyday model of our messaging. We emailed everyone a daily message that we are open and what has changed—curbside, telemedicine, and fillng out your forms prior to coming in. We stressed safety. We also let them know that we were probably going to have to communicate a lot—1 to 2 emails a day—as we got our new processes in place. We also put signage out front and labeled our parking spaces and told the clients which space they were to take, etc.

(Dr. Keri Riddick, Owner, Benning Animal Hospital) We are sending out frequent Facebook posts to notify clients as our policies adapt. We have also sent a general “Letter to Clients” on our website that a client must click on in order to view the site. We initially called and rescheduled “non-essential” services to a later date; however, at first we just planned for 2 weeks later, now we realize that was not enough. Our Facebook page has really been effective—and helps us detail all our procedure changes.

(Dr. Duffy Jones, Owner, Peachtree Hills Animal Hospital) This has been ever changing for us. Staff is told every day if you feel sick even in the slightest way stay home. I stressed that if we get shut down because someone is positive and comes to work, it will be very difficult for the business so be safe. I discussed with them about limiting travel. We started by wearing neck scarves as masks because we wanted to conserve all our PPE. I was able to purchase cloth masks with filters so now we wear those all the time while working. We also wash them every day. We also ask them to wash their hands all the times and we converted our exam rooms to individual rooms for doctors. One team of tech and doctors are limited to that room, that computer, and we all use our cell phones to call clients. Also, we have alternating staff – where one group of people work one day and then they are off the next day. We also have a lot of front people working from home—we had this already set up prior to this so that worked out really well.

(Dr. Keri Riddick, Owner, Benning Animal Hospital) Handwashing, handwashing, handwashing and hand sanitizer! We have a normal supply of surgical masks, but definitely not an oversupply. We have dispensed masks to all employees and are spraying them down at the end of the day, trying to extend their “life.” We are practicing social distancing even inside the hospital. Since we cannot apply that when we are working with our patients, we are still trying to be mindful of how close we are to each other.

We are requiring masks to be worn in the hospital, and if we are interacting closely with a client, we will don gowns and disposable (1 time use) gloves. We are trying to get masks made by family so we will have 4-5 per person. We have extended appointment times so we can disinfect the surfaces the pet has been on and handwash appropriately between patients. It is like we hit reset with each patient.

Our reception team is only taking payments over the phone, and we have developed 2 teams that work opposite each other, trying to eliminate crossover between each other. We are handling any cash with disposable one time use gloves.

(Dr. Duffy Jones, Owner, Peachtree Hills Animal Hospital) We are currently going outside to get pets from owners / wearing masks. We wear masks all the time – even inside but especially when getting pets. We grab the pet and tell them we will call them from inside. Many have already filled out history sheets so we know what they are here for. We have them wash their hands as soon as they come in and after they deliver the pet.

(Dr. Keri Riddick, Owner, Benning Animal Hospital) First, we must model the behavior we want our staff to follow. Second, we communicate directly what the protocols are and why we must follow them. We have weekly Zoom meetings with our staff (started last week) to discuss what we must do to protect ourselves. We are requiring that the staff is only going to work and out to stores as necessary for essential items. We have discussed that if they are not following this, they are not participating in our group’s safety and they will be placed on furlough.

If a staff member is suspected to be ill, they are required to remain at home. Those that are in the high risk group, we have encouraged to work from home. We have extended phone lines through Google voice to our doctors and personnel that work from home to limit contact between staff with our hospital phones. We have assigned computers or iPads to staff to limit group contact with keyboards. We are trying, but this is difficult to 100% follow. We are currently going outside to get pets from owners, not taking in the client leashes.

(Dr. Duffy Jones, Owner, Peachtree Hills Animal Hospital) Currently, because of the split shifts, all the staff is down about ½ the amount of pay. During the first two weeks, I paid them all for 40 hours no matter how much they worked. I did that because we had been proactive and contacted many of our clients and got all our spays and neuters done before the stay at home order was given. We also happened to see a lot of emergencies because the weather was nice. So, during the first payroll period, we were only down about 20% and I could cover it. This payroll period I am hoping my Payroll Protection Program (PPP) loan will come through to cover the difference between their scheduled hours and their working hours. If I do not hear about the PPP before that time, I will look at the numbers and see if I can carry them again. It is not their fault I reduced hours. I tell them not to continue to expect this because I might not be able to. We cut out their 401k payments and I’ve talked to them individually about things that they can do to help them financially.

(Dr. Keri Riddick, Owner, Benning Animal Hospital) We talked to our employees in the beginning and several of them opted to furlough so that helped. We are functioning more in shift work, assigning teams to work together. We have been very transparent with our staff, communicating with what we are doing on the backend to have financial security so they can feel secure in having a job. We have reduced some of our full time people to part time and file weekly unemployment for them.

Also, for some of our employees, such as our kennel technicians, we are teaching them reception and assistant skills. We have also communicated our target financial goal that we need to reach daily so we can sustain our hospital hopefully indefinitely without the need for any aid. This has really helped empower the staff to know what tangible goals we need to reach. Also, it has helped as we work to control what the essentials of business are. People were nervous at first thinking they wouldn’t be getting bonuses and raises but I think they all understand that now. Initially this was a source of frustration but now that they see others like nail salons and restaurants aren’t working at all, they appreciate that they are still able to work

(Dr. Duffy Jones, Owner, Peachtree Hills Animal Hospital) Our team has been great about conserving everything. We all carry hand towels so as not to use paper towels to dry our hands, we have reusable masks. We use our sterile gloves only for surgery. I was able to get a bunch of gloves through amazon – non-sterile used for tattoos. But I have to stay we are all saving everything right now.

(Dr. Keri Riddick, Owner, Benning Animal Hospital) Great question! My mother–in-law is making masks, we are being stingey with supply and have applied as an “other” on Amazon, hoping to qualify for some supply. Everywhere we contact, especially all our typical venders, are out of supply.

(Dr. Duffy Jones, Owner, Peachtree Hills Animal Hospital) So we have only had the staff working per day so we have limited our appointments to those doctors and another doctor on call if we get busy. Surgery has dropped a lot and many times we would have 4 to 8 per day we are down to one. We have added blocks in our schedule to give the doctors and tech teams some time to go outside and get some fresh air (2 hours for lunch). So basically, we have reduced by about 1/2. We have staggered our emergency slots as well.

(Dr. Keri Riddick, Owner, Benning Animal Hospital) We have extended all appointments to 30 minute appointments, this allows us to call the owner, connect with them on video chat for those who would like it, and text photos of bloodwork or radiographs to the owner so we can discuss findings. We are encouraging drop off appointments for those clients who do not have air conditioning in their cars. We are not turning clients away if the appointment book is full—we are then just creating a drop off appointment.

(Dr. Duffy Jones, Owner, Peachtree Hills Animal Hospital) We talked about this as a staff and decided what we felt was critical to do. We’ve pushed off routine dentals and nail trims, etc. We are seeing anything that needs to be seen. We feel vaccines and wellness are critical to keeping pets healthy and their owners at this time because of how much time they are spending together. We are also seeing tons of emergencies.

(Dr. Keri Riddick, Owner, Benning Animal Hospital) This is a challenging question for me. There are a lot of routine visits that are seen as concerning in the eyes of a client. Also, this pandemic has not reduced the requirement that we practice to the minimum standard of care, and ultimately we should continue to practice good medicine. So, if a client’s pet is overdue rabies vaccination and an exam, then we will discuss appropriate vaccination/heartworm testing, etc. Our State Board requires the VCPR, so if the animal is already presenting itself for an exam plus rabies vaccination, then I feel obligated to discuss general wellness for the pet.

Different example, if a pet is current on heartworm prevention but their annual heartworm test is due, we will waive the heartworm test and dispense the prevention. We have discontinued elective surgical procedures, dentals, OFA radiographs and general grooming such as nail trims, anal glands and non-medicated baths. We are definitely trying to conserve our PPE. However, we are continuing to do medicated baths for those owners who cannot do them at home. I feel like this is the most difficult question and would say realistically that about 75-80% of what we are doing is essential and 20-25% of what we are doing is non-essential and that is the piece we are continuing to try and whittle away at. I feel like we are learning more each day and improving our decision making each day.

(Dr. Duffy Jones, Owner, Peachtree Hills Animal Hospital) Yes, we have some that have requested not to work. Those that qualify for FMLA, I have put them on FMLA. Those that do not qualify said they would go without pay. I have been able to pay them so far but that might not continue. It’s really hard to look at the people who are working really hard and getting the same as the people who decided not to work so those folks eventually furloughed. I am hoping the PPP comes through and that will make things easier.

(Dr. Keri Riddick, Owner, Benning Animal Hospital) Yes. We have 4 employees that have requested to not work. We have accommodated all 4. We cannot force people to work and for us this has helped to give work hours to other staff.

Initially we asked the employees that either wanted to self quarantine or were required to self quarantine due to school age children to furlough (3 weeks ago), then we reported their hours to the Department of Labor as they developed their protocols to help handle the changes in work force. Now, we have added the opportunities to work from home for 2 employees and that is helping tremendously. One of these handles the scheduling of appointments and paperwork from clients and the other is getting calls transferred to her to help assist clients. In addition to scheduling appointments, that assistant is also checking VetSource for and approving prescription requests, or forwarding to us for those that require doctor approval. She is attaching all the lab work to patient records, as well as doing client callbacks to check on sick patients.

(Dr. Duffy Jones, Owner, Peachtree Hills Animal Hospital) I am looking at my financial week to week. I use the income from the previous week to set my budget for staff 41% and Cost of Goods Sold at 20%. This gives me a budget for the following week. That way I can make adjustments as needed. It does require me to keep my quickbooks up to date but it is worth it.

(Dr. Duffy Jones, Owner, Peachtree Hills Animal Hospital) I have tried to be the leader of my office that the employees can trust. I have been up front with them on what the challenges are but also what my plan for a solution is. Every morning I would send out the plan for the day and any adjustments that we need from the day before. I let them know that I was talking to people, watching the news, and planning based on what I learned. I keep telling them our best way to keep everyone paid and our patients safe is to figure a way to see as many of them as we can safely.

There is no longer a requirement to keep the 6’ distance.

The shelter in place order issued on 4/03 expired on 5/13. Governor Kemp issued another executive order on 5/12 covering the reopening of businesses. The main item that relates to veterinarians is #17 on pg. 11 concerning the use of PIN pads, which now can be used if disinfected frequently. Click here to read the executive order. For the sake of health & safety concerns, there should be no rush to get back to “normal” and the GVMA recommends that you continue observing the safety protocols that you have instituted for your staff and your clients.

(Don Riddick, Esq., GVMA Legal Expert) The answer is you are not required to have a physical signature on a consent form—it just needs to be in the medical record (so you could have an email or text as consent as well).

(Don Riddick, Esq., GVMA Legal Expert) If they are showing no symptoms, there is really nothing for you to do. There is no exclusion/reason under FFCRA or CARES ACT for self isolation if they are not showing symptoms. If they feel like they’ve been exposed, they should consult a physician and if they are advised by their doctor to stay in isolation for a period of time, they should do that. The way that FFCRA is currently structured, you have to either be seeking a medical diagnosis or you have to self quarantine on the advice of a health care provider. If you self quarantine just because you are either afraid you’ll be exposed or you already have been exposed but you are showing no symptoms and you haven’t gone to a doctor, the only benefits that are available to that employee are unemployment and that could be declined. I spoke to the Georgia Department of Labor about this and this is being done on a case by case basis. The employee would have to file on their own. The answer is that you ask them to come to work unless they feel like they can’t.

(Don Riddick, Esq., GVMA Legal Expert and co-owner of Benning Animal Hospital in Columbus) Only if they are coming in for euthanasia or challenging diagnostics. We have not required it for curbside yet. I would say if this makes you or your staff more comfortable, you should do it.

(Don Riddick, Esq., GVMA Legal Expert and co-owner of Benning Animal Hospital in Columbus) We have discontinued nail trims, anal glands. If an owner feels that the pet needs to be seen, we are making ourselves available to see the pet. However, if they are due for a heartworm test, we are dispensing the heartworm prevention and delaying the test as an example.