BY: SAMANTHA BARTLETT, DVM

In late December 2022, the Food and Drug Administration announced it would withdraw the guidance document (GFI #269) entitled, “Enforcement Policy Regarding Federal VCPR Requirements to Facilitate Veterinary Telemedicine during the COVID-19 Outbreak.” The withdrawal would take effect February 21, 2023.

GFI #269 was created during the early stages of the COVID-19 pandemic in recognition of the important role that veterinarians play in public health. The pandemic created challenges to the veterinarian’s ability to make on-site examinations of patients. To facilitate the veterinarian’s ability to provide patient care during the pandemic, the FDA created GFI #269, temporarily suspending enforcement of the on-site portion of the federal VCPR requirements allowing the use of telemedicine to establish VCPR for the purposes of providing patient care. Although the FDA acknowledges the public health emergency for the COVID-19 pandemic still exists, the conditions for which GFI #269 was needed have evolved past the need for the guidance resulting in the withdrawal notice.

Withdrawal of the guidance means that the FDA will again enforce and uphold federal requirements for the veterinarian-client patient relationship (VCPR). The federal VCPR requirements state that animal examinations cannot be met solely through telemedicine. This also includes initial establishment of a VCPR through in-person examination or site visit. Once the initial VCPR is established in person however, it may be maintained through telemedicine as medically appropriate.