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  1. #1
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    Default Legislation Bad For Your Vet

    http://www.capwiz.com/avma/issues/al...gMeQs.facebook

    Help Ensure that Veterinarians Can Provide Complete Care to Their Animal Patients

    Veterinarians treat multiple species of animals in a variety of settings.
    Unfortunately, the Controlled Substances Act (CSA) makes it illegal for veterinarians to take and use controlled substances outside of the locations where they are registered, often their clinics or homes.

    This means that it is illegal for veterinarians to carry and use vital medications for pain management, anesthesia and euthanasia on farms, in house calls, in veterinary mobile clinics, or ambulatory response situations.

    Veterinarians must be able to legally carry and use controlled substances for the health and welfare of the nation’s animals, to safeguard public safety and to protect the nation’s food supply.

    We encourage you to contact your members of Congress and urge them to support the Veterinary Medicine Mobility Act of 2013 (H.R. 1528), which would amend the CSA that currently prohibits veterinarians from transporting controlled substances to treat their animal patients outside of their registered locations.

    The Drug Enforcement Administration (DEA), which enforces the law, has informed organized veterinary medicine that without a statutory change, veterinarians are in violation of the CSA and cannot legally provide complete veterinary care.

    The DEA has already notified some veterinarians in California and Washington State that they are in violation of this law.

    The practice of veterinary medicine requires veterinarians to be able to treat their animal patients in a variety of settings, such as in:

    •rural areas - for the care of large animals where it is often not feasible, practical or possible for owners to bring livestock (i.e., cows, pigs, horses, sheep, and goats) into a veterinary hospital or clinic;

    • “house call” services or mobile clinics - where veterinarians offer a variety of veterinary services for their patients or in the communities;

    •research and disease control activities - where it may be necessary to conduct research away from the veterinarian’s principal place of business;

    •emergency response situations – where injured animals must be cared for onsite; and

    •the removal or transfer of dangerous wildlife (e.g. bears, cougars) or to rescue trapped wildlife (e.g. deer trapped in a fence).

    Tell Congress that veterinarians need to legally be able to transport controlled substances to the locations of the animal patients, not only for the health and welfare of the nation’s animals, but for public safety.

    ************************
    \"Horses lend us the wings we lack\"


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  2. #2
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    I am glad to see this posted here as I was going to. The word needs to get out on this and we need to put a stop to it. I'm surprised that mobile vet trucks aren't considered their clinic. This impacts horse, cattle, any type of livestock vet as well as those of us that want to have our small animals put to sleep at home. We simply can't be hauling all these animals into a brick and mortar building to have them euthanized and then haul them somewhere else for disposal.



  3. #3
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    There are quite a few vets in our area that don't even have a "clinic". Their "office" is mobile - literally.

    There was one equine vet years and years ago, who showed up in an actual ambulance he had converted to carry every piece of equipment he could fit in that he may need to treat horses.
    And a refrigerator to keep the meds cool.

    ************************
    \"Horses lend us the wings we lack\"


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  4. #4
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    Sounds like as more and more vets are sent to school as 'select' HSUS vets, there may be a problem with them putting their hands in the old cookie jar! What else could explain this?


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  5. #5
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    We only have one large animal vet in town w/a clinic all the rest are mobile.



  6. #6
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    Quote Originally Posted by 7arabians View Post
    Sounds like as more and more vets are sent to school as 'select' HSUS vets, there may be a problem with them putting their hands in the old cookie jar! What else could explain this?
    My understanding is that issues on the human side lead to tightening of regulations which created the issue of ordinary parts of mobile practice being a violation. The new legislation is to fix that.


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  7. #7
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    They need to fix this.
    This is stupid.

    Just imagine the vets at the race track.

    ************************
    \"Horses lend us the wings we lack\"


    3 members found this post helpful.

  8. #8
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    Dec. 15, 2005
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    It needs to be fixed. I can't imagine having a horse with a fracture who needs to be euthanized and being told that the DEA required that the vet could only euthanize at the clinic. Shooting a horse in that circumstance is also illegal as we live in suburbia.


    3 members found this post helpful.

  9. #9
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    Sent, and shared!
    Failure is always an option*
    -Mythbusters

    *As long as you figure out what you f'ed up and fix it! -Me


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  10. #10
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    More over reach in the war against drugs. Kentucky has passed some really bad legislation...emergency room doctors were supposed to check a drug data base before giving a controlled substance to a badly injured patient, for instance.

    So, how has the war on drugs and more control of prescription pain killers affected Kentucky? Heroin use has skyrocketed and people with a legitimate need for narcotic pain medication are having a really rough time. Good job Kentucky.
    "We can judge the heart of a man by his treatment of animals." ~Immanuel Kant


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  11. #11
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    Quote Originally Posted by 7arabians View Post
    Sounds like as more and more vets are sent to school as 'select' HSUS vets, there may be a problem with them putting their hands in the old cookie jar! What else could explain this?
    What in blue blazes is the above drivel supposed to mean?

    The situation is as follows: DEA licenses for controlled substances are issued for practice at a given address. They do not have any provisions for ambulatory practice. So, technically, any transportation and use of these drugs other than at the specified address is against regulations.

    This legislation is an attempt to remedy that situation.

    It has bugger all to do with your paranoid fantasies about any AR takeover of the profession.
    "It's like a Russian nesting doll of train wrecks."--CaitlinandTheBay

    ...just settin' on the Group W bench.


    16 members found this post helpful.

  12. #12
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    I read the section of the Controlled Substances Act and I cannot see what they are complaining about.

    (b) Authorized activities
    Persons registered by the Attorney General under this subchapter to manufacture, distribute, or dispense controlled substances or list I chemicals are authorized to possess, manufacture, distribute, or dispense such substances or chemicals (including any such activity in the conduct of research) to the extent authorized by their registration and in conformity with the other provisions of this subchapter.


    (e) Separate registration
    A separate registration shall be required at each principal place of business or professional practice where the applicant manufactures, distributes, or dispenses controlled substances or list I chemicals.

    I cannot see how it prohibits veterinarians from carrying drugs, or storing them at a secondary place of business.
    ... _. ._ .._. .._



  13. #13
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    I recently picked up a total of 1 cc of pain meds for my cat that was divided into ten 0.1 ml cat-sized doses. We of course had to fill out all the controlled substances paperwork.

    I understand the rationale but I'm still ROTFL about the idea of going from vet to vet, accumulating narcotics one cc at a time.
    If you are allergic to a thing, it is best not to put that thing in your mouth, particularly if the thing is cats. - Lemony Snicket


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  14. #14
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    Quote Originally Posted by Equibrit View Post
    I read the section of the Controlled Substances Act and I cannot see what they are complaining about.

    (b) Authorized activities
    Persons registered by the Attorney General under this subchapter to manufacture, distribute, or dispense controlled substances or list I chemicals are authorized to possess, manufacture, distribute, or dispense such substances or chemicals (including any such activity in the conduct of research) to the extent authorized by their registration and in conformity with the other provisions of this subchapter.


    (e) Separate registration
    A separate registration shall be required at each principal place of business or professional practice where the applicant manufactures, distributes, or dispenses controlled substances or list I chemicals.

    I cannot see how it prohibits veterinarians from carrying drugs, or storing them at a secondary place of business.
    I think it can be read to mean that if I drive to your house and dispense a controlled drug without that separate registration, that I could be in violation.

    In any case, I think clarity that a licensed medical professional (human or veterinary) is permitted to have a mobile practice and dispense drugs appropriately and otherwise within the law is a good thing.
    If you are allergic to a thing, it is best not to put that thing in your mouth, particularly if the thing is cats. - Lemony Snicket


    3 members found this post helpful.

  15. #15
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    Thanks for posting that, luvmytbs. I'll be sure to share it and contact my reps.
    Brothers and sisters, I bid you beware
    Of giving your heart to a dog to tear.
    -Rudyard Kipling



  16. #16
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    Quote Originally Posted by poltroon View Post
    I recently picked up a total of 1 cc of pain meds for my cat that was divided into ten 0.1 ml cat-sized doses. We of course had to fill out all the controlled substances paperwork.

    I understand the rationale but I'm still ROTFL about the idea of going from vet to vet, accumulating narcotics one cc at a time.

    But you are an exception;

    • (c) Exceptions

    The following persons shall not be required to register and may lawfully possess any controlled substance or list I chemical under this subchapter:

    • (1) An agent or employee of any registered manufacturer, distributor, or dispenser of any controlled substance or list I chemical if such agent or employee is acting in the usual course of his business or employment.
    • (2) A common or contract carrier or warehouseman, or an employee thereof, whose possession of the controlled substance or list I chemical is in the usual course of his business or employment.
    • (3) An ultimate user who possesses such substance for a purpose specified in section 802(25) (FOOTNOTE 1) of this title.
      (FOOTNOTE 1) Section 802(25) of this title, referred to in subsec. (c)(3), was redesignated section 802(26) of this title by Pub. L. 98-473, title II, Sec. 507(a), Oct. 12, 1984, 98 Stat. 2071, and was further redesignated section 802(27) of this title by Pub. L. 99-570, title I, Sec. 1003(b)(2), Oct. 27, 1986, 100 Stat. 3207-6.

      Section 802
    • (27) The term ''ultimate user'' means a person who has lawfully obtained, and who possesses, a controlled substance for his own use or for the use of a member of his household or for an animal owned by him or by a member of his household.
    ... _. ._ .._. .._



  17. #17
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    AVMA April 12th 2012

    We’ve previously posted information on this blog and on our online discussion boards after we heard concerns from members that a California district office of the DEA might be changing its enforcement of the Controlled Substances Act (CSA). Although at this time the situation appears to be limited to California, it is a symptom of an underlying, national-level problem: the CSA was not written with veterinarians and their unique circumstances in mind, and therefore does not address veterinarians’ frequent needs to transport controlled substances on house calls or farm calls. Although we’ve been assured by the national DEA office that they are understanding of veterinarians’ needs and they acknowledge the shortcomings of the CSA regarding our profession, we’re concerned that any change in this position could bring many veterinary practices to a standstill and prevent veterinarians from providing quality veterinary health care to their patients.
    ... _. ._ .._. .._


    1 members found this post helpful.

  18. #18
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    Quote Originally Posted by Equibrit View Post
    I read the section of the Controlled Substances Act and I cannot see what they are complaining about.

    (b) Authorized activities
    Persons registered by the Attorney General under this subchapter to manufacture, distribute, or dispense controlled substances or list I chemicals are authorized to possess, manufacture, distribute, or dispense such substances or chemicals (including any such activity in the conduct of research) to the extent authorized by their registration and in conformity with the other provisions of this subchapter.


    (e) Separate registration
    A separate registration shall be required at each principal place of business or professional practice where the applicant manufactures, distributes, or dispenses controlled substances or list I chemicals.

    I cannot see how it prohibits veterinarians from carrying drugs, or storing them at a secondary place of business.
    Each "secondary place of business" would need to be registered with the DEA. In other words, every.single.farm. an ambulatory DVM visits. With, I assume, a separate registration fee for each.

    It is the DEA itself which has interpreted the current regulations to mean that transportation of controlled substances in the course of ambulatory work is no allowed.
    "It's like a Russian nesting doll of train wrecks."--CaitlinandTheBay

    ...just settin' on the Group W bench.


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  19. #19
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    Thank you, OP. Saw this on FB over the weekend, and wanted to remember to respond.

    7arabians, it's a wonder you can hear anything else but the voices in your head.
    I tolerate all kinds of animal idiosyncrasies.
    I've found that I don't tolerate people idiosyncrasies as well. - Casey09



    5 members found this post helpful.

  20. #20
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    Jul. 19, 2007
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    Quote Originally Posted by Ghazzu View Post
    Each "secondary place of business" would need to be registered with the DEA. In other words, every.single.farm. an ambulatory DVM visits. With, I assume, a separate registration fee for each.

    It is the DEA itself which has interpreted the current regulations to mean that transportation of controlled substances in the course of ambulatory work is no allowed.
    Exactly. It's that "dispenses" under (e) that's the kicker. I'm all for controlling narcotics (and honestly having received opioids in the hospital ONCE, after which I stopped telling the nurses if I hurt, anyone who takes them for fun is a moron who deserves what they get-they're NOT FUN) but the way that law got written it means technically a vet would have to register every location where they dispense those drugs. For a large-animal vet, who generally goes to the clients instead of the other way around, that could be a serious problem.


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