Date Published: 25 March 2020

FDA helps enable veterinary care via telemedicine during COVID-19 pandemic

Pet owners in the USA have been informed of the temporary easing of certain regulations that will enable pets such as cats and dogs to receive veterinary consultations remotely, for example in the form of the animal's carer showing a video of the animal to the vet. This has been confirmed by a statement on the U.S. health regulator's website1 where it is explained that the reason is to enable vets to continue to care for animals during the coronavirus (COVID-19) pandemic while still maintaining the 'social distancing' recommended to limit the further spread of coronavirus across the USA and globally.

The U.S. Food and Drug Administration (FDA) announced on 24 March 2020 that as part of its "commitment to combatting the coronavirus (COVID-19) pandemic and providing flexibility across FDA-regulated industries" it will temporarily not enforce certain requirements such as will enable animal health professionals (veterinarians) to make more effective use of telemedicine to support animal health during the present situation of restrictions due to the pandemic.

Telemedicine, also known as 'Telehealth' can be summarised as "the distribution of health-related services and information via electronic information and telecommunication technologies"2. Telehealth is a huge subject area with many methods, modalities and sub-divisions, telemedicine being described2 as only a part telehealth because while telemedicine includes remote clinical services, such as diagnosis and monitoring, it excludes delivery of preventative, promotive, and curative care included in the broader scope of telehealth.

In a statement on the FDA website, FDA Commissioner Dr Stephen M. Hahn said:

" The FDA recognizes the vital role veterinarians play in protecting public health. This pandemic has had impacts on many of our everyday lives and professions, and during this time, we need to provide veterinarians with the latitude to expand the use of telemedicine in the care of animals, not only pets but also the animals that produce our food," adding that:
" The FDA is providing flexibility that will help veterinarians maintain the health of animals during the pandemic, while allowing for the social distancing that is so important in limiting the further spread of coronavirus disease across the country and the world."

In the more specific information that followed it was explained that the FDA intends to temporarily suspend enforcement of portions of the federal veterinarian-client-patient relationship (VCPR) requirements relevant to certain FDA regulations.

Context: The VCPR is the professional relationship between the veterinarian, client (e.g., animal owner or caretaker), and the animal patient(s). The federal VCPR definition requires that veterinarians physically examine animal patients and/or make medically appropriate and timely visits to the location where the animal(s) are kept. This means vets cannot meet the requirements of the federal definition of the VCPR by telemedicine, or telehealth, alone.

Temporary relaxation of enforcement: In order to help animal health providers use modern communication facilities to continue to provide animal health care in the present circumstances of the COVID-19 pandemic, the FDA has announced that, in general, it 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 gives vets more flexibility in the present circumstances by enabling them to prescribe drugs in an "extralabel manner" or authorize the use of VFD drugs without direct examination of or making visits to their patients. This relaxation of the usual requirements supports general effors to reduce and limit human-to-human interaction, such reduction and limitation having been recommended by governments to contain the possibility of spread of COVID-19 across human populations.

To explain how this temporary easing of strict rules might help in the present context of minimising human-to-human interaction in person, the FDA gave the example of the owner of a sick dog being able to show a video of the dog to a vet. If necessary, that vet could then prescribe a drug not approved for use in dogs or for that illness (extralabel use).

Another example given relates to animals in agriculture and mentions how a vet could remotely examine and diagnose a group of food-producing animals with a skin disease before authorizing use of certain drugs in the animals' feed.

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