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Consultant and expert reviews rise; committee debates whether California should keep condition‑specific VCPR

5407548 · July 16, 2025
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Summary

Consultant and expert case reviews increased in the quarter; experts transmitted more cases to the Attorney General's Office, and the MDC discussed whether California should retain a condition‑specific veterinarian–client–patient relationship (VCPR) given telemedicine and access‑to‑care concerns.

Consultants and subject matter experts reviewed more cases in the February–April 2025 round than in the prior period, and the MDC used a quarterly expert roundtable to discuss report quality and broader policy questions, including the scope and interpretation of the veterinarian–client–patient relationship (VCPR).

Statistics presented to the committee (Feb–Apr 2025) - Consultants reviewed 121 cases: 57 closed as no violation, 12 closed with an educational letter, 6 closed for insufficient evidence, and 46 referred for full expert review. The consultant round represented a 20% increase in cases reviewed compared with the prior round and a 12% drop in no‑violation closures. - Experts reviewed 159 cases: 46 closed as no violation, 30 closed with an educational letter, 7 cited or prepped for citation, and 74 transmitted to the Attorney General’s Office for disciplinary action. This was a 26% increase in expert reviews and a more than 40% increase in AG referrals compared with the prior round.

Why it matters: rising referrals to experts and the Attorney General indicate either a higher caseload or a change in screening thresholds; at the same time, the MDC is debating whether California’s long‑standing condition‑specific VCPR rule is compatible with telemedicine and with current clinical practice.

VCPR and telemedicine discussion - The committee considered a hypothetical case: a dog examined and vaccinated at an annual visit later developed diarrhea; a stool sample returned positive for Giardia, the clinic had an opening only eight days later, and staff dispensed fenbendazole for pickup after discussing the result by phone. Consultants asked whether a new, condition‑specific VCPR was required to prescribe treatment for the new condition. - Some subject matter experts said the described practice (phone discussion plus prescription) reflected common professional practice and would be considered within the standard of care; others said the law’s condition‑specific VCPR requirement technically required reestablishing a VCPR for the new condition unless telemedicine rules were used to establish it.

Stakeholder input - Grant Miller (California Veterinary Medical Association) urged the committee not to “gloss over” this topic and said the CVMA plans to consider legislation; he argued that the condition‑specific interpretation restricts access to care and that the law could be enforced in a less restrictive manner without changing statutory text. - Nancy Elrich (California RVT Association) said she supported reverting to the earlier, broader interpretation that allowed a veterinarian ‘‘recently acquainted’’ with a patient to treat new conditions without repeated in‑person examinations in every instance.

Committee conclusion - The committee did not reach consensus on whether to recommend changing the condition‑specific VCPR requirement; members asked staff to report to the full board on the discussion and to track potential statutory or regulatory follow up, including cross‑board coordination on telemedicine rules.

Quality of expert reports and training - The expert roundtable stressed plain‑language reports for lay readers, avoiding insertion of codes or citations into standard‑of‑care statements, and calling out absent or incomplete medical‑record elements. The subcommittee recommended continuing quarterly case reviews and more targeted guidance for experts writing opinions.

Next steps - The MDC will report the range of views and the lack of committee consensus to the board. The committee flagged the topic as a potential future agenda item and noted that the CVMA may pursue legislation that the board will need to consider.