Authorisation of adult cat and dog vaccinations for administration by veterinary nurses during the current veterinary workforce shortage
This document sets standards for the authorisation of cat and dog vaccines (which are restricted veterinary medicines) for an existing client during the veterinary workforce shortage. These are requirements that we expect all veterinarians to follow.
Some parts of this document temporarily remove the restrictions as set out in the Code, to help manage the current impacts on veterinary resources and to maximise delivery of veterinary services to meet animal welfare needs.
This use of Restricted Veterinary Medicines (RVMs) by a veterinary nurse in the absence of a veterinary consultation is not a default setting and may only be authorised by veterinarians during this exceptional period. The normal standards will apply again when the veterinary workforce shortage has abated.
The use and administration of vaccines for vaccinations for adult cats and dogs by veterinary nurses
The expectations for authorising and good stewardship of RVMs and Prescriptions Medicines (PMs) are set out in the Code of Professional Conduct and the ACVM Notice: Requirements of Authorising Veterinarians.
Under normal circumstances, veterinary authorisation of RVMs and PMs involves the veterinarian examining the patient (or having recently seen the patient themselves or by another veterinarian from the same practice) as part of a Veterinary Consultation and practices such as veterinary nurses administering RVMs and PMs are conducted as an extension of this in person consultation.
In these unique circumstances and the ongoing need when a veterinarian or their business is unable to provide veterinary services to their clients, VCNZ will temporarily allow veterinarians to authorise vaccines for adult cats and dogs for veterinary nurses, considered by the authorising veterinarian to be competent, to use and administer vaccinations in the absence of a concurrent physical examination by the veterinarian and beyond the RVM’s maximum period of supply.
Competency and RVM risk assessment
During this period, vaccines for adult cat and dog vaccinations can be authorised by a veterinarian for use by a veterinary nurse providing the veterinarian meets the requirements set out in this document. This allowance will enable veterinarians to continue to prioritise animal welfare, while minimising the risks to themselves, their colleagues and the wider public.
Veterinarians must take care not to substitute examination by a veterinary nurse when an in person physical examination by a veterinarian is necessary. For example, it may be appropriate for animals with comorbidities or on long term medication to receive a veterinary examination rather than a veterinary nurse examination e.g. cases such as a diabetic cat, a dog with congestive heart failure, or a patient on long term NSAID therapy for arthritis.
Before authorising a cat or dog vaccine for use by a veterinary nurse in these circumstances, the veterinarian(s) must be satisfied, and it should be included in the clinical record, that it is appropriate to do so. To make that decision, veterinarians must use their professional judgment and consider RVM risk factors and staff competency in each circumstance.
Competency and RVM risk considerations
- Have you seen the animal recently enough to have sufficient personal knowledge, in the circumstances, of the condition/health status of the animal including for example factors such as age, breed and physical maturity, and any existing conditions (or has it been, for example, over a year since their last examination)?
- Given the understanding of the condition/health status of the animal – do you consider it is possible to gather enough information via a veterinary nurse examination to make a safe decision to administer the vaccine (or is it possible that a physical exam performed by a veterinarian of this animal could make a material or significant difference to your assessment)?
- Is the veterinary nurse able to competently (safely and effectively) gather the animal’s history, perform an examination, interpret the information gathered and determine it is appropriate to proceed, and administer the correct vaccine including for example triennial vaccination regimes (or are there risks involved that may impact the safety of the person or animal or reduce the efficacy of the product including the absence of appropriate competence)?
- Is the administration of the vaccination necessary in the interests of animal welfare (or can the treatment be performed by another veterinarian or reasonably delayed until a physical examination can be performed by a veterinarian)?
- Is the age of the animal such that there are manageable risks (or is the animal less than two years or more than 10 years old, for example)?
- Is the breed of the animal such that there are manageable risks (or is the breed predisposed to particular issues that impact the risks)?
- What are the natures of, and risks associated with, the vaccine? This includes thinking about the potential for adverse events.
Veterinarians should refer to our Technical Advice: Authorising restricted veterinary medicines for dispensing and use by non-veterinarian staff, which outlines the veterinarians’ responsibilities.
Decision to authorise
If a veterinarian has considered the risks and decides NOT to authorise the vaccine the veterinarian can decline to authorise a veterinary nurse to vaccinate the animal. They may then organise for a veterinarian to examine and vaccinate the animal or to refer the client to another veterinarian for this purpose
If a veterinarian has considered the risks and decides to authorise the vaccine, they MUST ensure they are satisfied that their decision is justified and appropriate to achieve the intended effect and ensures the welfare of the animal.
- The animal’s owner is an existing client AND the animal has been seen recently (within the last year) by the veterinarian.
- Any consent given by the client is fully informed and with an understanding of the risks involved including those associated with the absence of a physical exam by a veterinarian.
- The correct RVM product is being administered and there is an appropriate adverse event reporting system.
- Any veterinary nurse who will administer the vaccine is appropriately trained and is able to competently carry out the authorising veterinarian’s instructions for use
- There is a detailed clinical record, including the:
- reasons for using a veterinary nurse to administer the vaccine and evidence in the record which may be for example a reference to a clinic policy, systems, and training records that the veterinarian has considered the risks
- details of the RVM products authorised including batch number, expiry date, site of administration etc, and appropriate advice given to meet the requirements above.
- The veterinarian can justify their decision, in the context of the current veterinary shortage (e.g. by reference to this Statement in their policy document).
RVM information and adverse events
All other aspects of the requirements upon authorising veterinarians, which includes providing owners with all of the information they need and ensuring that they have access to veterinary care in the event of an emergency or adverse event, still apply.
Timeframe and review
This provision will continue to apply during the veterinary shortage. It will be reviewed regularly to assess its fitness for purpose.
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