Practice Pulse

QUESTION: Should an exam be performed with every rabies vaccination? Is an exam within the last year considered acceptable? If a client declines an annual exam, can a rabies vaccination still be given?

A: The standard of practice for a limited service (vaccination) clinic requires a physical exam be performed on every animal to be vaccinated. There seems to be no reason why the standard for a regular clinic would be less.

61G18-15.007 Minimum Standards for Limited-Service Veterinary Medical Practices.

(1) The term “limited-service veterinary medical practice” shall mean a privately or publicly supported vaccination clinic where a veterinarian performs for a limited time vaccinations and/or immunizations against disease on multiple animals, and where the veterinarian may also perform microchipping and preventative procedures for parasitic control, and shall not mean a premise otherwise permitted by the Board. (2) The Limited-Service permittee shall register each clinic with the Board of Veterinary Medicine by name, address, date of clinic, time and duration, at least 28 days prior to offering a limited-service clinic. A copy of the limitedservice permit shall be clearly visible at each limited service clinic held during its hours of operation and posted at the main office where the records are stored. (3) A veterinarian must remain on site throughout the duration of a limited-service clinic and must maintain autonomy for all medical decisions made. A physical examination and history must be taken for each patient receiving veterinary medical care at a limited-service clinic. Recommendations and preventive medicine protocols must be developed from current accepted veterinary medical practice. The veterinarian is responsible for proper immunization and parasitic procedures and the completeness of recommendations made to the public by the paraprofessional staff that the veterinarian supervises or employs. The veterinarian is responsible for consultation and referral of clients when disease is detected or suspected.

The annual exam is a fairly common standard of practice. If the animal was examined by the veterinarian/practice less than 1 year ago, another exam may not be necessary.

If a client declines an annual exam, the veterinarian should explain that the standard of practice requires that examination be performed before providing the vaccination. If the veterinarian gives the rabies vaccination without having performed some type of physical examination and there is an adverse reaction that could have been avoided with a physical examination, the veterinarian will not be able to defend him/ herself.

QUESTION: What type of signature is needed on rabies vaccination certificates? I recently had a situation where a receptionist changed a patient's weight in the medical record and provided the certificate to a client without my knowledge. Should I be signing each rabies certificate personally? What is the recommended policy on protecting signature stamps if those are used?

A: A rabies vaccination certificate can be signed using a rubber stamp:

(3) Upon vaccination against rabies, the licensed veterinarian shall provide the animal’s owner and the animal control authority with a rabies vaccination certificate. Each animal control authority and veterinarian shall use the “Rabies Vaccination Certificate” of the National Association of State Public Health Veterinarians (NASPHV) or an equivalent form approved by the local government that contains all the information required by the NASPHV Rabies Vaccination Certificate. The veterinarian who administers the rabies vaccine to an animal as required under this section may affix his or her signature stamp in lieu of an actual signature.

A signature stamp should be protected to the same extent as blank certificates or your prescription pad. If you leave these out in the open and people forge certificates or prescriptions, you may be deemed to have acted negligently.

QUESTION: We recently had a client come in and ask us if we could give her a copy of her pet's rabies certificate. Our receptionist fulfilled this request for her. The next day the same client's daughter came in and said that she lost the copy and asked for another. She then told the receptionist that the weight we had on the certificate was incorrect and asked that we change it. The receptionist changed it and reprinted the certificate with the lower weight, based on what the client was telling her. The receptionist then told the client's daughter that she could not permanently change it, until she brings the pet in for a weight check and reverted the weight back. This client gave her new apartment complex an old rabies certificate in addition to the new one with the lowered (unverified) weight listed on it. The apartment complex is now calling and asking what is going on and which weight/certificate is correct.

A: Our legal counsel advises the following:

One of the benefits of an FVMA membership is our Helpline (800.992.3862), which is available to members Monday through Friday from 8 a.m.-6 p.m. The concerns voiced on our Helpline provide the FVMA staff with insight into the challenges our members face. In this feature, we will highlight topics from the questions we received in preceding weeks in an effort to keep our members up to date on current concerns as well as regulatory and legislative changes. GOT A QUESTION? THE FVMA CAN HELP.

should NEVER make any change without the express direction/ instruction of the veterinarian.

2. The moment the daughter came back with the story of the “lost” certificate that should have been a red flag. The receptionist should not have changed the weight because that would make it easy for the client to use that certificate for another animal.

3. The practice should contact the owner and ask that the owner bring in the animal and the certificates. The owner should be informed that the complex has called the practice, but that they (the practice) will not do anything without first giving the owner the opportunity to correct any mistake.

QUESTION: We have experienced a reoccurring issue; pharmacies keep calling to request DEA numbers for the filling of non-controlled drugs. A handful of pharmacies are now saying our DEA number must be written on a prescription or it won’t be filled. Has something changed?

A: Nothing has changed. It is simply an unfortunate reality that many pharmacies (and drug wholesalers) have adopted the DEA registration number as a very handy (and unique) identification number in their systems. Individual veterinarians can complain to the pharmacies (or the Board of Pharmacy) or they can comply, in order not to inconvenience themselves and their clients.

QUESTION: I'm interested in fullfilling the mandatory portion of the Florida required CE to renew my license. I have plenty of CE, but I just got my license by endorsement in Florida last November (2019). I didn't realize I would already need those required credits to renew in 2020. Any information you can provide would be much appreciated.

A: You need to renew your license, but you do not need the CE. Referencing 61G18-16.002(5):

“A licensed veterinarian shall not be required to complete a continuing education requirement prior to the first renewal of his license, but it shall be required prior to any subsequent renewal.”

You will need to get your 30 hours of CE during the 2020-2022 biennium.

QUESTION: I wanted to inquire about a question that was asked in The Advocate, Issue 5 of 2019, regarding veterinary technicians performing dental extractions. Recently, I was told by a potential employer at a job interview that as long as a licensed veterinarian is “supervising” a dental procedure, then technicians can perform extractions in the state of Florida. However, after reading The Advocate, it sounds like, legally, that isn’t the case.

A: The definition of the term “veterinary medicine” in §474.202(13) includes dentistry. Therefore, anyone performing dental extractions would have to be a veterinarian, or be otherwise exempt under the Veterinary Practice Act. Under §474.203(7), a veterinary aide may “…render auxiliary or supporting assistance under the responsible supervision of a licensed veterinarian...” The question then becomes whether actually performing the procedure can be interpreted as “rendering auxiliary or supporting assistance.” Although the Board’s rule on delegable tasks does not specifically state what can or can’t be delegated (except for certain vaccinations), the general consensus and understanding is that a veterinary technician can’t perform surgery (i.e. neuter a cat), but they can close up an incision after surgery is completed. Applying the same logic leads to the conclusion that the non-veterinarian (no matter how eminently qualified) should not perform dental surgery.

QUESTION: Our immediate area is under a rabies alert. A 10-month old feline was attacked in his yard by a raccoon, which was killed by the owners. The racoon tested positive for rabies. What should my course of action be in response to this?

A: You should forward the information to the Florida Department of Health. They will work with your County Department of Health to ensure the safety of the people involved and make a determination of how to handle the rabies-exposed kitten.

END NOTE: The ultimate responsibility in the practice of veterinary medicine lies with the licensed veterinarian. Professional discretion must always be exercised.