Federal VCPR Waiver Rescission. Confused? Here’s What You Need To Know

The FDA recently announced its rescission of the COVID-era waiver to agency regulations concerning the VCPR.  Many veterinarians and vet nurses have since expressed confusion about how this will affect them and how they can ensure compliance while best serving their patients and clients.  Here is what veterinary professionals need to know:

1. This is not a new FDA policy, but simply a federal agency rescission of the
   COVID-era waiver pertaining to a regulation instituted decades ago.
2. The FDA regulation (not federal law) applies only to 2 circumstances for
   veterinary medicine:
   (1) veterinary feed directives, and
   (2) prescriptions of extra-label drugs.
   (3) Nothing else.
3. The FDA regulation is not a prohibition of any other aspect of veterinary medicine or a telemedicine VCPR in those states permitting such a VCPR.
4. FDA does not require a VCPR for prescription, administration or dispensing of drugs that are not off-label. State regulations govern these prescriptions, and practitioners should check their practice acts/regulations in any state where they practice.