|Action||Prescribing of opioids|
|Comment Period||Ends 2/9/2018|
Questions & Concerns
Part D does not specify the number of days of continuation of treatment, whereas Part B specifies continuation of treatment beyond 14 days. What is the specific number of days with regard to part D? Can the re-evaluations be done in person, on the phone, by email, or text, video, or Skype? What is the name of the offense if these regulations are not followed? In the proposed changes, there is now no mention of extenuating circumstances being allowed in part A3. This needs to be included but also defined. Part C states that we have to discuss known risks and benefits of these drugs with owners. Since these drugs are being used in an extra-label manner and none has been approved for use in animals, who will tell us what constitutes the known risks and benefits of these drugs in animals? We are being expected to explain something for which there is no evidence base. For E2, this should be changed to allow 14 days or more as determined by the patient and the vet and the owner. Related to proper disposal, what are real options for clients/owners? The handout that we are instructed to give to clients does not provide actual options. It directs clients to go to a website for further information. Who has the burden of discussion and documentation when there is an off-site pharmacy filling these prescriptions? We need clear guidance related to documenting and managing the various numbers of days in the regulations/proposals related to initial visit and re-evaluations. Real life does not happen on day 1, day 7, and day 14. How much leeway do we have to accomodate patients and clients/owners around work schedules, holidays, travel, and so on? If Fido gets 7 days' worth of meds and doesn't need them again until 6 weeks later, is this 6 week date considered "prescribing beyond 14 days"? Or is it considered to be an initial evaluation and we all have to start over with documentation and rule-following? These regulations place an undue and misplaced burden on veterinarians who want to relieve pain and suffering in animals. We are not the source of the opioid addiction crisis in humans. They are abusing heroin and fentanyl according to reports of which I am aware.