advocacy & legislative update ~ dec. 21, 2023

DCVMA Testimony re: DC Council Health Occupations Revision General Amendment Act of 2023

Dear Council Member Henderson & The DC Council:

Thank you for the opportunity to submit comments regarding the Health Occupations Revision General Amendment Act of 2023. The DC Veterinary Medical Association (DCVMA) applauds the Council for updating health occupation standards and regulations to make medical care more accessible. DCVMA strongly supports the use of telemedicine in general, however we are opposed to the use of telemedicine to establish a veterinarian-client-patient relationship, or VCPR, virtually. Once the VCPR is established with an in-person physical exam, DCVMA supports the use of telemedicine, as appropriate, for follow up visits, management of chronic conditions, and consults with specialists as coordinated by the doctor(s) primarily managing the patient.

The federal government regulates veterinary medicine and animal drugs very differently than it does human health care and drugs intended for human use. This is, in part, because veterinarians are key to maintaining a healthy, safe, and wholesome food supply and because they also play an important role in overseeing the judicious use of antimicrobials in animals. One important difference between human and veterinary medicine is that the U.S. Food and Drug Administration (FDA) has authority under the federal Food, Drug, and Cosmetic Act (FDCA) over the the use of animal drugs and human  drugs by veterinarians, and the authority to define how a VCPR is established for certain uses of animal and human drugs.

Use of animal and human drugs by veterinarians that violates the federal VCPR parameters set forth in the FDCA and its implementing regulations results in the drug being statutorily deemed unsafe for the use. The federal VCPR applies to any use of an FDA-approved human drug in animals, including over-the-counter human drugs. It applies to any use of an FDA-approved animal drug in any manner that differs from its approved labeling, such as a different frequency of administration, different dose, different medical indication for its use, different route of administration, or use in a different species. It also applies to the use of compounded drugs by veterinarians. The FDA defines a VCPR to require an in-person examination to establish the relationship, and allows maintenance of such relationship via telemedicine.

Veterinarians must comply with the federal VCPR in each of the circumstances in which it applies, irrespective of whether state law defines it differently. Conflicting state and federal VCPR definitions have the potential to cause significant confusion, as veterinarians must comply with the federal VCPR requirements where they apply, regardless whether state laws are more lax.

DCVMA requests that the Council exclude veterinarians from this Act, and that the District maintain the
current VCPR definition as set forth in DC Municipal Regulation 2814, most recently amended in 2021.

Thank you again for the opportunity to provide input on this legislation. As the organization representing veterinary medicine in the District, the DCVMA is a source of expertise regarding veterinary medicine, animal health, and public health. Please do not hesitate to reach out to us with any questions, as well as any legislation that might impact these areas.

DCVMA Board of Directors

Opinion ~ Nov. 3, 2023

Honoring One Health Day Through Collaborations in the District

Every year, the world celebrates One Health Day on November 3rd. This year, the DC Veterinary Medical Association and the Medical Society of DC are collaborating to highlight the value of One Health coordination at the local level, here in Washington, DC.

One Health is an integrated approach, which recognizes that the health of humans is closely linked and interdependent with the health of animals, plants, and the environment. Effective One Health approaches mean we communicate, collaborate, and coordinate across these sectors. And, there are multiple benefits and reasons why veterinarians, physicians, and other health and social service professionals in the DC area should work together to address health challenges.

Animals as Sentinels for People

Just over 38% of households in DC own pets and this number is likely to rise. But, not only do pets and people live close together, in the DC area people and wildlife live in surprisingly close quarters. Just last year, multiple people on Capitol Hill were impacted by a rabid fox, and the rat population in DC poses on-going concerns for other zoonotic diseases, such as hantavirus. A zoonotic disease is one that can be transmitted between animals and people.

Local wildlife and zoo veterinarians, companion animal veterinarians, and physicians can work together to streamline data sharing and concerns of any increase in diseases with zoonotic potential. With awareness of these shared health concerns, physicians and veterinarians can work together to emphasize the importance of pet vaccinations and avoiding wildlife.

Moreover, with changing climate patterns, certain vector-borne diseases are spreading into areas not previously seen before. For instance, locally-acquired malaria was recently identified in Maryland and more ticks than usual were expected in DC this past summer. Veterinarians may very well be on the front lines of an uptick in tick and mosquito-borne diseases in the area as these might show up sooner as a problem in pets and wildlife than people. If local veterinarians begin noticing higher numbers of tick-borne diseases or novel disease patterns, they can alert health authorities to share that information with physicians and their patients. Similar to when West Nile Virus was first identified in the U.S. in 1999, communication between veterinarians and human health professionals is essential to identify a potentially shared health threat before it spirals out of control.

Animals can also be sentinels for environmental health concerns. Health effects from environmental toxins or contaminants, such as lead-contaminated water, can sometimes be elusive and often linger a long time before a proper diagnosis is made. But, veterinary offices have the opportunity to thoughtfully take the time to record thorough patient histories and listen with public health in mind to offer a chance of catching an environmental health risk in pets before it has severe impacts on communities at large.

Pets are Both a Bridge & Barrier to Care

In addition to diseases of mutual concern, veterinarians and physicians should talk with each other more as pets are becoming an essential part of many people’s family — occasionally, the only family member they have. Many pet owners would benefit greatly from close collaboration between their veterinary office and their medical providers. Veterinarians can be in direct conversation with their clients’ health professionals when pet health recommendations might be in direct conflict with the physical, mental, or emotional health realities of their clients.

These conversations are even more important in times of pet owner crisis. For instance, those working on the front lines of human and pet health indicate there is a need for temporary pet foster services so people can get medical treatment they have been delaying out of concern for neglect or loss of their pet. Veterinary clinics have the potential to build on the client-patient-relationship to treat the pet in the context of their family dynamic and offer possible resources for pet owners going through a crisis. To ignore the pet as an essential part of the family can be detrimental to human health, as studies have shown the benefits of pet ownership on mental, emotional, and physical health, which is even more important for those marginalized and without robust social support systems.

For those who are traditionally less able to access health services — those experiencing homelessness, in domestic violence situations, or struggling from the limitations of poverty — offering services for their pets can often be a bridge to connecting them with services for themselves. While traumatized individuals can often be distrustful of institutions and human health care professionals, trust in veterinarians’ concern for their pets can be a gateway to eventually connect the pet owners with health services for themselves, whether that be social services, mental health treatment, medical treatment, housing, etc.

Both veterinarians and physicians value offering quality and accessible care. A key piece of ensuring care is inclusive means recognizing pets as legitimate members of the family for those who rely on them as such. Through collaboration, communication, and coordination, veterinarians, physicians, and other health professionals can create innovative care solutions that decrease barriers, increase equitable access, and offer improved outcomes for both people and pets.

Veterinarians & Physicians Face Similar Challenges

In addition to better serving our patients, collaboration and communication between veterinarians and physicians is paramount because our professions have similar challenges. Both veterinarians and physicians are facing a mental health crises, including burn-out and concerning rates of suicide. Both professions are also grappling with workforce shortages, adding even more strain on both how well we can serve our patients and our own personal well-being. Working across sectors, we can share information about what is working, what is not working, and creative solutions to these critical problems.

The list of reasons for improving communication across sectors does not end there. There are plenty of other ways veterinarians and human health professionals can collaborate, including on advocacy and policy proposals that can protect human and animal health, such as the Combating Illicit Xylazine Act.

So, how are we going to support continued and enhanced collaboration, communication, and coordination amongst veterinarians and physicians in the DC area? We are beginning communication efforts in the hopes of sparking multiple smaller conversations. Our two professional medical societies are committing to working together to host joint webinars, extending cross-sectoral invitations to our associations’ meetings, and seeking avenues for hosting joint continuing education and information sessions. We hope to plan joint health events to reach both people and pets in one venue, as well as sharing stories, data, and cross-sectoral health ideas all in one place.

All of this will take time, as nurturing lasting relationships usually does. But, please, hold us accountable. Let your health care providers know if you have a pet and how caring for that pet might impact your own health decisions. Let your veterinarians know if there are concerns you have about being able to follow through on their recommendations and request your health care providers work together as collaborative teams. Creating effective collaborative teams at the primary care level is a hard thing to ask and, while there will be many nuances to sift through, it is worth the challenge. Committing to the One Health approach can improve health outcomes across sectors — the time is right to act now.

Leslie Brooks, DVM, MPH

DCVMA Executive Director