Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Veterinary Medicine
 
chapter
Regulations Governing the Practice of Veterinary Medicine [18 VAC 150 ‑ 20]
Action Prescribing of opioids
Stage Emergency/NOIRA
Comment Period Ended on 8/9/2017
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7/28/17  2:21 pm
Commenter: Sandy Christmus, DVM; Oakton-Vienna Veterinary Hospital

Emergency Regulations are detrimental for our patients
 

Points other commenters have made are excellent. The most difficult part of the Emergency Regulation is the requirement to recheck in 7 days. Asking us to examine these patients for which opiates have been prescribed every 6 months is good medicine, plus we should be seeing these (typically) older patients that often anyway. In replacment of the 7-day recheck requirement, I'd prefer a rule requiring us assure the refills are being filled "on-time" with some defined "wastage" percentage of the amount dispensed. The occasional pill is wasted and the occasional volume of a liquid solution is lost, so there would need to be some leeway that allows us some professional judgment that the drug isn't being abused and that we can refill as needed for 6 months. Requiring a recheck seems optional to me because generally we're not prescribing amounts of opiates in quantities to be abused, especially if we're closely monitoring refill timing.

CommentID: 62735