The way the proposed regulation is written it places a significant burden on veterinarians treating feline patients and owners of feline patients. Buprenorphine is the most commonly used pain medication in feline patients because it is effective, safe, easy for owners to administer, and reasonably priced. Other alternatives like NSAIDs carry a greater risk to the feline patient and many owners refuse to use them.  Having to bring a feline patient back to the clinic after only 7 days of treatment will cause cats to suffer from pain as owners will simply not bring them back due to the hassle.

I urge the regulatory committee to provide an exception to the 7 day rule for buprenorphine for chronic pain (arthritis, pancreatitis) and for hospice patients allowing a 14 day supply to be obtained at each refill as long as there is a treatment plan in place and there is a valid client-patient relationship. For patients with chronic conditions or under hospice treatment, physical exams could be required every 6 months instead of yearly.