The VCPR and Veterinary Telemedicine

Stripped to its elements, the AVMA Model Veterinary Practice Act formulation has three parts.

The veterinarian has assumed responsibility for clinical judgements about the patient's health.

The client has agreed to follow the veterinarian's instructions.

And the veterinarian has sufficient knowledge of the patient to reach at least a general or preliminary diagnosis — through a timely examination of the animal, or medically appropriate visits to where the animal is managed.

That third element is where all the argument lives. "Sufficient knowledge" is what a physical examination or a premises visit is supposed to produce, and the question telemedicine raises is whether a video call can produce it too.

It matters because the VCPR is a gate rather than a formality.

Without a valid one, prescribing is not permitted — which means the relationship is the thing that makes most of veterinary medicine legally possible.

Almost every discussion of veterinary telemedicine treats the VCPR as one rule.

It is two.

Your state's VCPR is defined by its practice act and enforced by its veterinary board.

It governs whether you may practise, prescribe within the state, and what your board expects.

The federal VCPR is defined by the FDA and governs extralabel drug use — using an approved drug in a way not on its label — under the Animal Medicinal Drug Use Clarification Act and its implementing regulations.

Extralabel use is routine in veterinary practice, which is exactly why this is not an edge case.

The two definitions are not identical, and the federal one does not permit electronic establishment.

Establishing a federal VCPR requires a physical examination of the animal, or timely and medically appropriate visits to the premises where the animals are kept — and that requirement applies everywhere it applies, regardless of what a state has decided.

So a practice in a state that permits virtual VCPR establishment can lawfully establish a state VCPR by video, and still lack a valid federal VCPR for any extralabel prescribing that follows.

The distinction that makes telemedicine workable at all, and the one worth getting precise about.

Establishing a VCPR is the initial step that creates the relationship — the physical examination or premises visit that produces sufficient knowledge of the patient.

Maintaining it is everything afterwards.

The FDA position is that a VCPR can be maintained using telemedicine between physical examinations or timely and medically appropriate premises visits.

That is a substantial permission, and it is where most legitimate veterinary telemedicine actually operates: follow-ups, recheck conversations, triage for existing patients, medication adjustments within an established relationship.

The constraint is on the front door, not on the whole house.

It also means the practical question for a practice adding virtual care is rarely "is telemedicine allowed?" — it is "which of these encounters involve patients we have already established a relationship with, and how recently?"

A small number of states have moved to permit establishing the state VCPR electronically, and the legislative activity around this has been sustained.

Arizona is the clearest worked example.

It enacted legislation allowing veterinarians licensed in the state to establish a VCPR virtually through telemedicine — with limits written into the permission rather than left to practice: prescribing capped at a defined short window from the visit, and a single refill before an in-person examination is required.

Those guardrails are worth noticing, because they show what a legislature that permits virtual establishment still worries about.

The concern is not the video call itself; it is prescribing at length on the strength of one.

The AVMA's position remains that a VCPR should be established by in-person physical examination or a premises visit, and that it cannot be established solely by telephonic or other electronic means.

So this is a genuine disagreement between a professional body's position and where some legislatures are going — which is why it keeps generating bills.

The questions that determine whether a virtual-care workflow is compliant, rather than whether it is technically possible.

The record-keeping item is easy to skip and hard to fix retrospectively.

If a board or the FDA asks how a relationship was established, the answer needs to be in the record at the time — not reconstructed afterwards.

Three forces are pushing against each other, which is why the rules are unsettled rather than simply strict.

Access to care. Virtual establishment is argued for on the grounds that it reaches animals who would otherwise go unseen — rural households, people without transport, and clients priced out of an in-person visit.

Diagnostic quality. The counter-argument is that a physical examination produces information a video call cannot — palpation, temperature, mucous membranes, gait — and that prescribing without it is a different standard of care.

Commercial pressure. Telehealth platforms have a direct interest in virtual establishment being permitted, and much of the public advocacy comes from businesses whose model depends on it.

That does not make the access argument wrong, but it is worth knowing whose material you are reading.

For a practice, the useful posture is to treat this as a moving area, keep the two-VCPR distinction firmly in mind, and document establishment carefully.

For an owner or manager, it also belongs on the same shelf as practice ownership rules — both are places where the regulatory frame, not the clinical work, decides what your business can do.