COVID-19 FAQs: Telemedicine

COVID-19 FAQs: Telemedicine

Get the latest information on telemedicine and how it can help you and your patients during COVID-19.

  • What are the Colorado requirements currently for telemedicine during COVID-19?
    • Currently, C.R.S. § 12-315-104(19)(b) requires a VCPR be established by physically seeing and examining an animal. There is no executive order in effect that currently suspends this requirement. For patients a veterinarian has an existing VCPR with, telehealth appointments may be conducted.
  • What are the state requirements regarding telemedicine?
    • Colorado’s Veterinary Practice Act allows veterinarians to conduct telemedicine with patients they have an established veterinarian-client-patient relationship (VCPR) with. In Colorado, a physical examination is required to establish a VCPR. Generally, this means that a veterinarian must first examine an animal in-person to establish a VCPR prior to conducting telemedicine.
  • What are the FDA requirements for telemedicine at this time?
    • FDA announced on March 24 (click here to read) that it has temporarily suspended enforcement of certain aspects (in-person examinations and premise visits) of the federal VCPR requirements that apply to extralabel drug use and VFDs (21 CFR 530 and 21 CFR 558.6) only. This is enforcement discretion, not a rule change. The guidance acknowledges individual state VCPR requirements that may exist, acknowledges current federal VCPR requirements related to in-person animal examinations/premise visits, and indicates the suspension of requirements outlined in guidance is a temporary measure during the COVID-19 outbreak. Federally, this allows veterinarians to prescribe drugs in an extralabel manner or authorize the use of VFD drugs without direct examination of or making visits to their patients to limit human-to-human interaction and potential spread of COVID-19 in the community.
  • What are the DEA requirements for telemedicine at this time?
    • DEA is allowing registered practitioners to begin issuing prescriptions for controlled substances to patients that have not been the subject of an in-person medical evaluation. DEA-registered practitioners, who—by definition—include veterinarians, have been advised that they may issue controlled substance prescriptions via telemedicine for the duration of the emergency declaration (i.e., a temporary exception) if the following conditions are met: prescription is issued for a legitimate medical purpose by a practitioner acting in the usual course of his/her professional practice; the telemedicine communication is conducted using an audio-visual, real-time, two-way interactive communication system; the practitioner is acting in accordance with applicable federal and state law. The latter is important because state veterinary practice acts and state pharmacy laws continue to apply.
  • What do Colorado’s pharmacy laws require?
    • According to DORA, Colorado Law (section 18-18-414(2)(a), C.R.S.) mandates, in summary, the following:
      • A pharmacist may dispense no greater than a 72-hour supply of a schedule II controlled substance to a patient in an emergency situation pursuant to a telephonic order from a prescriber.
      • The corresponding prescriber must then reduce the order to writing or electronic (electronic prescribing) format and shall deliver the order to the dispensing pharmacy by either electronic (electronic prescribing), facsimile, or mail (or have postmarked for mail delivery) within 72 hours of issuing the emergency telephonic order.
  • How does the Colorado State Board of Veterinary Medicine define telehealth?
    • “Telehealth” means a mode of delivery of veterinary medicine through telecommunications systems including but not limited to, video and digital technologies used to facilitate the assessment, diagnosis, treatment, or care management of an animal’s medical care while the client/patient is located at an originating site and the provider is located at a distant site. The term includes synchronous interactions and store-and-forward transfers. Read more in the Veterinary Policies and Guidelines (scroll to page 22).
  • Does CVMA have recommendations for veterinary professionals when it comes to telemedicine?
    • During this time, it is important to minimize the exposure of you and your team to COVID-19, and to consider alternative approaches to delivering health care for your patients whenever possible. CVMA strongly encourages veterinary professionals to exercise their professional judgement when it comes to specific patients and scenarios based on both state and federal requirements, and to keep the health and wellbeing of their veterinary teams at the forefront of decision making.


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