What the FDA’s “Dear Veterinarian” Letter Means

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The U.S. Food and Drug Administration (FDA) released on September 4 its “Dear Veterinarian” letter in response to the many questions the agency has received from stakeholders about the role of veterinarians in dispensing animal prescription drugs as mandated by federal laws. The letter also addressed inquiries about the veterinarian-client-patient relationships (VCPR) that are established in the course of the veterinarians’ practice.

In the letter, the FDA reiterated that only licensed veterinarians are authorized to dispense animal prescription drugs pursuant to Section 503(f) of the Federal Food, Drug, and Cosmetic Act. The law requires the use of animal prescription drugs under the supervision of a licensed veterinarian because these types of drugs are highly toxic and potentially harmful. The premise of the law recognizes the expertise and training of veterinarians to dispense such drugs, and that the FDA expects that veterinarians will take the appropriate steps to ensure that directions for the proper use of these drugs are clearly conveyed to pet owners.

Federal laws, under FDA regulations, also require that veterinarians must have clearly established VCPR before they can prescribe the extralabel use of any FDA-approved animal or human drugs. Furthermore, the FDA letter explained that VCPR cannot be established through telemedicine. However, VCPR can be maintained through telemedicine between physical visits and checkups with the veterinarian.