VCPR and Telemedicine Rules in Virginia
Virginia's VCPR rule is not where most practices go looking for it.
It lives in § 54.1-3303(B), inside the Drug Control Act, and codifies a real electronic-establishment path: a physical exam or an exam via image-transmitting diagnostic equipment both count as evidence the relationship has been assumed.
A board rule, 18VAC150-20-174, still requires a physical exam before opioid pain prescribing regardless of how the VCPR was formed.
What remains unresolved is narrower: whether the statute's telemedicine conditions bind other Schedule II-VI prescribing.
Last amended July 1, 2025.
Verify before you rely on this
At a glance
A bona fide VCPR exists where a veterinarian has assumed responsibility for an animal's care and a client has consented, evidenced by sufficient knowledge for a diagnosis, an examination, and follow-up availability. Defined "for purposes of this section" (prescription issuance under § 54.1-3303) and expressly excludes equines (as defined in § 3.2-6200); the sources read don't address how a VCPR is established for horses.
Codified — the examination element is satisfied either by a physical exam or by an exam "through instrumentation and diagnostic equipment through which images and medical records may be transmitted electronically," or by medically appropriate and timely premises visits.
The statute itself adds no separate maintenance-specific telehealth rule once a VCPR exists, but a board rule constrains one common remote workflow: delegating duties electronically requires the veterinarian to have physically examined the patient within the previous 36 hours (18VAC150-20-172(D)).
Not stated in the sources read.
Resolved for opioid-containing controlled substances prescribed for pain: 18VAC150-20-174(A) requires a history and physical examination before the first prescription, caps it at a 14-day supply, and requires the patient to be seen and evaluated again to continue past 14 days. For terminal illness or certain chronic conditions, subsection (B) instead permits prescribing within the standard of care without that pain-specific reevaluation, but still requires re-examination at least every six months for continued prescribing; the text doesn't say whether (A)'s initial exam and 14-day cap also apply to those cases. Outside opioids (non-opioid Schedule II-VI drugs), whether § 54.1-3303(B)'s telemedicine conditions bind veterinary prescribing is also unresolved.
Resolved for opioids prescribed for pain: 18VAC150-20-174(A) requires a physical exam before the first prescription (14-day cap) and reevaluation to continue past 14 days. For terminal illness or certain chronic conditions, (B) permits prescribing within the standard of care without that pain-specific reevaluation, but still requires re-examination at least every six months for continued prescribing; whether (A)'s initial exam and 14-day cap also apply to those cases isn't stated. Unresolved outside opioids: § 54.1-3303(B) sets nine conditions (a)-(i) for a Schedule II-VI telemedicine relationship that are written for human medicine and not restated for veterinary practice.
2025-07-01 (amended by 2025 Acts cc. 391, 408; statutory history runs back to 1983).
Electronic establishment allowed — State statute.
Va. Code Ann. § 54.1-3303(B), Title 54.1, Subtitle III, Chapter 33 (Pharmacy / Drug Control Act) — not Chapter 38, the veterinary practice act, which is silent — supplemented by Board of Veterinary Medicine rules 18VAC150-20-174 (controlled-substance pain prescribing) and 18VAC150-20-172(D) (delegation)
What actually establishes the relationship
Virginia defines a bona fide veterinarian-client-patient relationship around three pieces of evidence: sufficient knowledge of the animal to reach a general or preliminary diagnosis, an examination or equivalent familiarity with how the animal is kept, and availability for follow-up care.
A veterinarian, another veterinarian in the same practice group, or a consulting veterinarian can be the one who has assumed that responsibility, and the client has to have consented and agreed to follow instructions.
This is a codified, three-part test rather than a single bright line, which means a practice building an intake policy should be able to point to which piece of evidence — the diagnosis knowledge, the exam, and the follow-up commitment — each client file rests on.
Two scope limits matter: the statute defines this specifically "for purposes of this section" — § 54.1-3303, prescription issuance — rather than as a general practice-act VCPR definition, and it expressly excludes equines (as defined in § 3.2-6200); the sources read don't address how a VCPR is established for horses.
“a bona fide veterinarian-client-patient relationship is one in which a veterinarian, another veterinarian within the group in which he practices, or a veterinarian with whom he is consulting has assumed the responsibility for making medical judgments regarding the health of and providing medical treatment to an animal... and a client who is the owner or other caretaker of the animal... has consented to such treatment and agreed to follow the instructions of the veterinarian.”
A remote exam can establish the relationship itself
This is the correction that matters most about Virginia: the examination element of the VCPR test is satisfied either by a physical exam or by an exam conducted through instrumentation and diagnostic equipment that transmits images and medical records electronically.
That is a real, codified telemedicine-establishment pathway, not an interpretation stretched from silence — the statute puts the two routes side by side as equivalent evidence.
A practice offering a first-visit telemedicine consult in Virginia has statutory text to point to for that pathway.
The same subsection separately accepts medically appropriate and timely premises visits as a third route, aimed at herd and production settings rather than individual companion-animal exams.
“has made an examination of the animal, group of agricultural animals, or bees, either physically or by the use of instrumentation and diagnostic equipment through which images and medical records may be transmitted electronically or has become familiar with the care and keeping of that species of animal or bee on the premises of the client, including other premises within the same operation or production system of the client, through medically appropriate and timely visits to the premises at which the animal, group of agricultural animals, or bees are kept”
Resolved for opioid pain prescribing; unresolved beyond it
For opioid-containing controlled substances prescribed for pain, 18VAC150-20-174(A) requires a history and physical examination before the first prescription, caps it at a 14-day supply, and requires the patient to be seen and evaluated again to continue past 14 days.
For terminal illness or certain chronic conditions, subsection (B) instead permits prescribing within the standard of care without that pain-specific reevaluation, but still requires a re-examination at least every six months for continued prescribing; the text doesn't say whether (A)'s initial exam and 14-day cap also apply to those cases.
Outside that rule, the statute separately sets nine conditions — (a) through (i) — for a Schedule II-VI telemedicine relationship, plus a preceding sentence requiring the prescriber to have a physical presence or referral capacity in the Commonwealth; both govern the general human practitioner-patient relationship just before the veterinary-specific paragraph, and only condition (e), active Virginia licensure, sits inside the (a)-(i) list.
Whether that text binds non-opioid Schedule II-VI prescribing, or the initial exam/14-day cap for terminal illness/chronic conditions, is unresolved.
“the prescriber shall perform a history and physical examination appropriate to the complaint and conduct an assessment of the patient's history as part of the initial evaluation”
Last amended July 2025
§ 54.1-3303 was last amended effective July 1, 2025, part of a statutory history running back to 1983.
The saved statutory history does not specify what the 2025 amendment changed.
Any guidance, vendor summary, or internal policy describing Virginia's VCPR should be checked against the current text rather than assumed current.
Where the rule actually lives, and what a common tracker claim gets right
The veterinary practice act itself, Title 54.1 Chapter 38, still does not define a VCPR or address telemedicine at all — that chapter is genuinely silent, and a source citing it as Virginia's VCPR authority is citing the wrong chapter.
The operative statute sits in Chapter 33, the Drug Control Act, at § 54.1-3303(B) instead.
Separately, secondary trackers (including AVMA's November 2023 summary) describe Virginia as allowing virtual establishment for non-controlled-substance prescribing while requiring an in-person exam for controlled substances; for opioid pain prescribing specifically, that characterization is supported — 18VAC150-20-174 expressly requires a physical exam.
The genuinely open question is narrower than that tracker claim: whether the statute's separate telemedicine conditions bind non-opioid Schedule II-VI prescribing, described above.
There are two VCPRs, and the federal one does not move
What This Page Does — and Doesn’t — Cover
This page describes Virginia’s own text — Va. Code Ann. § 54.1-3303(B), Title 54.1, Subtitle III, Chapter 33 (Pharmacy / Drug Control Act) — not Chapter 38, the veterinary practice act, which is silent — supplemented by Board of Veterinary Medicine rules 18VAC150-20-174 (controlled-substance pain prescribing) and 18VAC150-20-172(D) (delegation) as read for this series, current as of September 2026, with the provision itself last changed 2025-07-01 (amended by 2025 Acts cc. 391, 408; statutory history runs back to 1983). It does not cover licensure, scope of practice, or the terms of a specific prescription, and it is not a compliance sign-off for a telemedicine service.
VCPR and telemedicine rules are the fastest-moving area this site covers — nine states changed theirs between 2024 and 2026, and bills are live in others. Confirm the current text with the board before you build an intake policy, a prescribing workflow or a remote-care service on it, and read the federal note above alongside it rather than instead of it.
Frequently Asked Questions
Can a Virginia veterinarian establish a VCPR over video?
Yes, with the right equipment. § 54.1-3303(B) accepts an examination "either physically or by the use of instrumentation and diagnostic equipment through which images and medical records may be transmitted electronically" as evidence the relationship has been assumed.
That is a codified electronic-establishment path, not an inference from silence.
Confirm the current statute text and any board interpretation with the Virginia Board of Veterinary Medicine before building a service on it.
Once a Virginia VCPR exists, what telehealth is allowed?
The statute itself does not add a separate maintenance-specific telehealth rule once a bona fide VCPR exists through either the physical or the electronic-examination pathway.
One board rule still constrains a common remote workflow, though: 18VAC150-20-172(D) requires the veterinarian to have physically examined the patient within the previous 36 hours before delegating duties electronically.
The statute also does not enumerate what telehealth may do absent a VCPR; that question is not addressed in the text this page relies on.
Verify current practice with the board.
Does Virginia's electronic-establishment path cover controlled-substance prescribing?
For opioid-containing controlled substances prescribed for pain, no — 18VAC150-20-174(A) requires a history and physical examination before the first prescription regardless of how the VCPR was established, caps it at 14 days, and requires reevaluation to continue past that.
For terminal illness or certain chronic conditions, subsection (B) instead permits prescribing within the standard of care without that pain-specific reevaluation, but still requires re-examination at least every six months for continued prescribing; the text doesn't say whether (A)'s initial exam and 14-day cap also apply to those cases.
Outside opioids, it's unresolved whether § 54.1-3303(B)'s telemedicine conditions bind veterinary prescribing.
Check with the board.
Does satisfying Virginia's VCPR rule make a practice federally compliant?
No, and this is the trap.
The federal VCPR at 21 CFR 530.3(i) is a separate relationship governing extralabel drug use and Veterinary Feed Directives, it requires that the veterinarian has recently seen the animal or visited the premises, and the FDA has said it cannot be met solely through telemedicine.
It applies regardless of what Virginia permits, and extralabel use is routine rather than an edge case.
Check both, and confirm with the board.
When did Virginia's VCPR statute last change?
§ 54.1-3303 was last amended effective July 1, 2025 (2025 Acts cc. 391, 408), with a statutory history running back to 1983.
Any summary or internal policy written before that date, or one that relies on Chapter 38 of the veterinary practice act rather than Chapter 33 of the Drug Control Act, may be describing an outdated or wrong provision.
Confirm the current text with the Virginia board before relying on it.
More Virginia VCPR & Telemedicine Resources
Sourced from Virginia’s own statute or board rule (see the citations above). Verified September 2026. This page is general information, not legal advice — confirm current rules with the Virginia board before relying on them.