Submitted by the American Veterinary Medical Association
The AVMA has been working hard for the past few months, as veterinarians have been increasingly discussed as needing to be among those able to assist in efforts to vaccinate people against COVID, to have veterinarians specifically included in the declarations under the federal Public Readiness and Emergency Preparedness Act (PREP Act), which authorizes the HHS Secretary to issue emergency public health declarations and provides limited immunity from liability to those covered under the act.
As of March 12, 2021, veterinarians and veterinary students are included in the PREP Act:
· It allows veterinarians who are licensed to practice under the law of any state to administer COVID vaccines in any jurisdiction in association with a COVID vaccination effort by a state, local, tribal, or territorial authority or by an institution in which the COVID vaccine is administered.
· This also applies to veterinarians who have held an active license or certification under the law of any state within the last five years which is inactive, expired or lapsed, as well as veterinary students with appropriate training in administering vaccines. The intent is to include recently retired veterinarians who may want to help.
· Today’s amendment preempts any state law that would otherwise prohibit veterinarians or veterinary students who are a “qualified person” under the PREP Act from prescribing, dispensing, or administering COVID vaccines or other covered COVID countermeasures.
· Veterinarians and veterinary students will be afforded liability protections in accordance with the PREP Act and the terms of the amendment. However, specific conditions must be met in order for the authorization to administer the vaccines and the liability protections to apply. These liability protections apply from March 11, 2021, through October 1, 2024.
· In order for the authorization and liability protections to apply, veterinarians and veterinary students must be participating in association with a COVID vaccination effort by a state, local, tribal, or territorial authority, or by an institution in which the COVID vaccine is administered. Additional specific requirements also must be met, such as having basic certification in CPR, completing the CDC COVID vaccination modules, an observation period, etc. There is a separate section of the declaration that applies to those in the uniformed services and for federal employees, contractors and volunteers when authorized to administer COVID vaccine.
· While the liability outlined in the PREP Act is broad, it does not apply to willful misconduct, and the federal government does not provide a legal defense in the event that you are sued. Your state may have separate liability protections, along with separate requirements to qualify, and may or may not provide a legal defense. Veterinary malpractice will not likely respond to claims arising from a veterinarian intentionally vaccinating people against COVID.
The following guidance information has been provided by the AVMA
THE BASICS
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 use of animal drugs and human drugs by veterinarians, and the authority to define how a veterinarian-client-patient relationship (VCPR) is established for certain uses of animal and human drugs. [1]
For these uses, FDA has authority to require the keeping of veterinary medical records and to access them at any reasonable time to verify and copy them. [2] 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 and, if in animal feed, the feed is statutorily deemed adulterated. [3] The USDA, which regulates veterinary biological products, also has promulgated rules defining a VCPR using the same language as the FDA. [4]
APPLICATION OF THE FEDERAL VCPR
The federal VCPR applies to any use of an FDA-approved human drug in animals, including over-the-counter (OTC) human drugs. [5] It applies to any use of an FDA-approved animal drug in any manner that differs from its approved labeling (Extra Label Drug Use [6]), 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. [7] It also applies to the use of compounded drugs by veterinarians [8] and a veterinarian’s authorization of a veterinary feed directive (VFD). [9] All of these are very common occurrences in the day-to-day practice of veterinary medicine.
Establishing the federal VCPR requires a physical examination of the animal or timely and medically appropriate visits to the premises where animals are kept. The FDA does not allow the VCPR to be established through electronic means. [10] FDA does allow the VCPR to be maintained electronically through telemedicine. [11] Veterinarians must comply with the federal VCPR in each of the circumstances in which it applies, irrespective of whether state law defines it differently.
The federal VCPR also applies in two important, but more limited, circumstances under USDA authorities. Veterinarians who manufacture biological products for use in their patients must do so within the context of the federal VCPR. [12] Veterinarians also must have established a federal VCPR when using prescription platform product biologics, which are a new category of biotechnology vaccines. [13]
CONFLICTING STATE AND FEDERAL VCPR DEFINITIONS AND TELEMEDICINE
• Conflicting state and federal VCPR definitions (e.g., states allowing the VCPR to be established electronically) would cause significant confusion. The FDA and USDA have used the same regulatory definition to avoid such confusion. • Veterinarians must comply with the federal VCPR requirements where they apply, regardless whether state laws are more lax. Activities where the federal VCPR applies are extremely common in day-to-day veterinary practice. • State law and regulations relating to the establishment of a VCPR that conflict with federal law would also cause telemedicine encounters to be frustrating for many veterinary clients. A veterinarian who has not already established a VCPR that complies with federal requirements (i.e., by conducting an in-person examination/visit) could not even recommend the use of an FDA-approved human OTC product for an animal without violating federal law. • There are many valuable uses of telemedicine within the parameters of a federal VCPR.
https://www.fda.gov/animal-veterinary/resources-you/ins-and-outs-extra-label-drug-use-animals-resource-veterinarians#compounding; FDA Draft Guidance for Industry #256
21 CFR 558.6(b)
FDA letter to the American Veterinary Medical Association, April 6, 2017 – “Therefore, for the purposes of the federal definition, a VCPR cannot be established solely through telemedicine (e.g., photos, videos, or other electronic means that do not involve examination of the animal(s) or timely visits to the premises).”; During the pandemic FDA announced they will temporarily suspend enforcement of the federal VCPR physical exam and premises visit requirements. https://www.fda.gov/regulatory-information/search-fda-guidance-documents/cvm-gfi-269-enforcement-policy-regarding-federal-vcpr-requirements-facilitate-veterinary. In this announcement FDA reiterated that under normal circumstances – “Given that the Federal VCPR definition requires animal examination and/or medically appropriate and timely visits to the premises where the animal(s) are kept, the Federal VCPR definition cannot be met solely through telemedicine.”
Id. “The regulations do not specifically address the use of telemedicine to maintain an established VCPR. However, based upon the language of the VCPR definition provided above, nothing would prohibit the use of telemedicine (e.g., use of photos, videos, or other electronic means that may be considered virtual) to allow the veterinarian to keep informed and able to make medical judgments regarding the health of the animal(s) and the need for medical treatment between periodic examinations of the animal(s) and/or timely visits to the premises where the animal(s) are being kept.”
The state of Hawaii has indicated veterinarians and their staff are essential health care providers included in Tier 1b of the COVID-19 vaccination rollout. To receive more information, fill out the Department of Health survey. The Department of Health will directly contact you to follow up. You may also check their website for updates.
The Professional and Vocational Licensing Division warns of fake calls to Hawaii-registered licensees. These calls have been made with actual Hawaii board phone numbers showing up on Caller ID. A professional or vocational licensee that is under investigation by the department would first be notified in writing from the Regulated Industries Complaints Office (RICO). RICO will also never ask for private or sensitive information over the telephone.
With any suspicious phone call, licensees are advised to hang up before revealing any personal information and initiate a return phone call by calling a number researched on their own (see https://cca.hawaii.gov/pvl/contact/), to ensure that they are speaking with the actual agency. Read more here.
On July 1, 2020, the City and County of Honolulu implemented mandatory microchip identification for cats and dogs over the age of four months. This replaces the City and County of Honolulu’s dog license tag requirement, but does not replace the requirement that cats allowed outdoors have visible identification. Any dog or cat without a microchip who is impounded by Hawaiian Humane Society or taken into custody by an animal rescue nonprofit must have a microchip implanted before release. The microchipping obligation does not apply to private individuals returning lost pets or to veterinary clinics, but we hope you will urge your clients to comply with the law. Clients with a new pet who is already microchipped should be informed that they have 30 days to update the pet’s microchip with their owner information.
In addition, the Hawaiian Humane Society will no longer be updating their microchip registry. Instead, they are recommending that veterinarians help pet owners register their information with the microchip manufacturer or with a free online database such as FoundAnimals.org. Pet owners who have microchips implanted by your clinic also have a legal obligation to register their contact information with an online registry within 30 days. Please do not send microchip information to the Hawaiian Humane Society at this time.
Another provision of the new law requires that any intact dog impounded as stray three times in a 12-month period must be spayed/neutered before the dog can be returned to its owner unless a licensed veterinarian finds the dog is medically unfit for sterilization.
Questions or comments may be directed to the Hawaiian Humane Society at info@hawaiianhumane.org or 356-2200.
Update from Hawaiian Humane Society
July 1 marked the implementation of the most significant overhaul of Oahu’s animal welfare ordinance in 25 years. It made changes in three major areas:
Stray animal handling
Pet identification
Routinely stray dogs
The pet identification provisions are expected to affect the greatest number of pet owners.
FAQs
What law has changed? Revised Ordinance of Honolulu Chapter 7: Animals and Fowl
How did the rules change regarding stray animal holding? Hawaiian Humane now has legal custody of any stray dog or cat with microchip identification after five days in its care, down from nine. Dogs wearing a current county license tag still must be held for a minimum of nine days. The kenneling fee for stray animals has increased to $10 per day from $2.50. There is still no kenneling charge for animals reclaimed within 24 hours. This is not a legal requirement, but Hawaiian Humane is urging pet owners who travel, particularly if they will not have email or cell phone access, to list their pet sitter or veterinarian as a secondary contact on their microchip registration in the event that their animal gets lost while they are away.
What are the new rules for pet identification? All dogs and cats are now required to have microchip identification. Pet cats allowed outdoors are still required to have visible identification. That is highly recommended for dogs, as well, but not legally required.
What if you have a current dog license? Owner information can still be updated with the City and County of Honolulu. No new dog licenses are being sold and licenses can no longer be renewed.
What about microchip registration? Clinics that wish to upload microchip information should do so with the manufacturer’s database, not Hawaiian Humane. Hawaiian Humane is no longer maintaining a separate microchip database for Oahu and pet owners are no longer legally required to register their microchips with Hawaiian Humane. Under the new ordinance, pet owners who have microchips implanted have 30 days to register their contact information with the microchip manufacturer or a free online database. Similarly, they have 30 days to update any changes to their contact information or to transfer ownership of a pet.
What does the new law say about routine strays, or “frequent fliers”? Any dog brought to Hawaiian Humane as stray three times in a 12-month period must be spayed/neutered before the dog can be returned to its owner, unless medically contraindicated. Sterilization services will be offered at the Community Spay/Neuter Center, but owners may request that Hawaiian Humane transfer a dog falling under this requirement to a private veterinary clinic upon confirmation of a spay/neuter appointment.
What do we do if someone brings us a lost pet? Hawaiian Humane remains the official pet lost and found for Oahu. If you need help identifying the owner of a microchipped pet, call the admissions team at 356-2285.
The AVMA Advocacy team worked very hard to influence and improve the Paycheck Protection Program. The Small Business Administration recently released data on the loans and the uptake by the veterinary profession has been significant. About 56% of veterinary practices took PPP loans totaling an estimated $2.1 Billion, with over 80% of the loans being less than $150,000. Over 200,000 jobs in veterinary practices have been protected. A blog posting with data and an infographic can be found at https://www.avma.org/blog/covid-19-loans-are-supporting-veterinary-teams-and-patients.
Congress is working on additional legislation that will impact the PPP, which could include retroactive changes. It is expected to pass before Congress leaves for their August recess. AVMA is actively seeking measures to ensure favorable tax treatment of PPP loan proceeds, and for a streamlined forgiveness process for loans below $150,000, which would include the vast majority of veterinary PPP loans. We have a Congressional Advocacy Network Action Alert out on the tax treatment of PPP funds that can be found at https://avmacan.avma.org/avma/app/onestep-write-a-letter?0&engagementId=508320.
Routine testing of animals for COVID-19 is NOT recommended by the American Veterinary Medical Association (AVMA), American Association of Veterinary Laboratory Diagnosticians (AAVLD), National Association of State Public Health Veterinarians (NASPHV), or the National Assembly of State Animal Health Officials. Nor is it recommended by key federal agencies, including the CDC and USDA.
Current expert understanding is that SARS-CoV-2 is primarily transmitted person-to-person. There is currently no evidence that animals can transmit this virus to people. In rare instances, people have spread the virus to certain animals.
Veterinarians are strongly encouraged to rule out more common causes for clinical signs in animals before considering testing for SARS-CoV-2. The CDC, USDA, and other federal partners have created guidance, including a table of epidemiological risk factors and clinical features for SARS-CoV-2 in animals to help guide decisions regarding animal testing.
The decision to test an animal should be made collaboratively between the attending veterinarian and local, state, and/or federal public health and animal health officials after careful consideration of this guidance as provided.
Stay home and follow social distancing orders from authorities. Studies show COVID-19 is often spread by those who are not yet showing symptoms of disease. Consider yourself infected and take the proper precautions to protect your community.
DO NOT take your pet to a veterinary clinic for wellness visits, vaccinations, or elective procedures (such as spay/neuter) that may be safely delayed for a few months.
If you are concerned with your pet’s health issue, CALL YOUR VET. Many vets are practicing telemedicine with established and new clients and patients, and will be able to make a tentative diagnosis and prescribe medication over the phone or after an online consult.
If you are diagnosed with COVID-19 but do not need to be hospitalized, you can still safely care for your pet. Practice good hygiene practices by washing your hands before and after interacting with your pet, not kissing or sharing food with your pet, and avoiding close contact (hugging, sleeping together). If possible, wear a facemask to reduce your spread of virus particles.
Make a Plan for Your Pet
You should identify a family member or friend who can care for your pets if you need to be hospitalized.
Have an appropriate carrier/crate for each pet, and enough food, medication, and supplies for at least two weeks.
Ensure all medications are documented with dosages and administering directions. Including the prescription from your veterinarian is ideal.
Pets should have identification: Collar with ID tag and microchip.
COVID-19 and Pets
Infectious disease experts and multiple international and domestic human and animal health organizations agree there is no evidence at this point to indicate that pets become ill with COVID-19 or that they spread it to other animals, including people.
If you are not ill with COVID-19, you can interact with your pet as you normally would, including walking, feeding, and playing. You should continue to practice good hygiene during those interactions (e.g., wash hands before and after interacting with your pet; ensure your pet is kept well-groomed; regularly clean your pet’s food and water bowls, bedding material, and toys).
Out of an abundance of caution, it is recommended that those ill with COVID-19 limit contact with animals until more information is known about the virus. Have another member of your household take care of walking, feeding, and playing with your pet. If you have a service animal or must care for your pet, wear a cloth facemask; don’t share food, kiss, or hug them; and wash your hands before and after any contact with them.
CDC Recommends Cloth Facemasks
CDC recommends wearing cloth face coverings in public settings to slow the spread of the virus and help people who may have the virus and not know it from transmitting it to others. Cloth face coverings fashioned from household items or made at home from common materials at low cost can be used as an additional, voluntary public health measure.
Cloth face coverings should not be placed on young children under age 2, anyone who has trouble breathing, or is unconscious, incapacitated or otherwise unable to remove the mask without assistance.
The cloth face coverings recommended are NOT surgical masks or N-95 respirators. Those are critical supplies that must continue to be reserved for healthcare workers and other medical first responders, as recommended by current CDC guidance.
The betacoronavirus that causes COVID-19 is SARS-CoV-2 (formerly 2019-nCoV).
Person-to-person and community spread has been reported in numerous countries, including the United States.
Transmission primarily occurs when there is contact with an
infected person’s bodily secretions, such as saliva or mucus droplets in
a cough or sneeze. Transmission via touching a contaminated surface or
object (i.e., a fomite) and then touching the mouth, nose, or possibly
eyes is also possible, but appears to be a secondary route. Smooth
(non-porous) surfaces (e.g., countertops, door knobs) transmit viruses
better than porous materials (e.g., paper money, pet fur) because
porous, especially fibrous, materials absorb and trap the pathogen
(virus), making it harder to contract through simple touch.
There are currently no antiviral drugs recommended or
licensed by FDA to treat COVID-19, and there is no immunization
available.
Cases of COVID-19 and community spread are being reported in most states.
The best way to avoid becoming ill is to avoid exposure to the virus. Taking typical preventive actions is key.
Have Any Pets Been Infected with COVID-19?
On April 5th, the USDA National Veterinary Services Laboratories has confirmed the presence of SARS-CoV-2 in one tiger at a zoo in New York. Read full USDA article.
While two dogs (Hong Kong) and two cats (one in Belgium and one in Hong Kong) living with people diagnosed with COVID-19 have also been reported to have been infected with SARS-CoV-2, other dogs and cats also living with infected people remain uninfected. To date the CDC has not received any reports of pets or livestock becoming sick with COVID-19 in the United States. Infectious disease experts and multiple international and domestic human and animal health organizations continue to agree there is no evidence at this point to indicate that, under natural conditions, pets spread COVID-19 to people. To date, all animal cases have had no or mild symptoms that resolved with supportive care.
Because the situation is ever-evolving, public and animal health officials may decide to test certain animals out of an abundance of caution. The decision to test will be made collaboratively between local, state, and federal animal and public health officials. After the decision is made to test, state animal health officials will designate a state-appointed veterinarian, USDA-accredited veterinarian, or foreign animal disease diagnostician to collect the sample using appropriate personal protective equipment (PPE) and sample collection methods.
Again, current expert understanding is that COVID-19 is primarily transmitted person-to-person. This supports a recommendation against testing of pets for SARS-CoV-2, except by official order. If dogs or cats present with respiratory signs, veterinarians should test for more common respiratory pathogens.
Pets in homes with owners with COVID-19: Although there have not been reports of pets becoming sick with COVID-19, out of an abundance of caution, it is recommended that those ill with COVID-19 limit contact with animals until more information is known about the virus. If you are ill with COVID-19 have another member of your household take care of walking, feeding, and playing with your pet. If you have a service animal or you must care for your pet, then wear a cloth facemask; don’t share food, kiss, or hug them; and wash your hands before and after any contact with your pet or service animal. You should not share dishes, drinking glasses, cups, eating utensils, towels, or bedding with other people or pets in your home. Additional guidance on managing pets in homes where people are sick with COVID-19 is available from the CDC.
Keeping pets safe: For responsible pet owners, preparing in advance is key. Make sure you have an emergency kit prepared, with at least two weeks’ worth of your pet’s food and any needed medications. Usually we think about emergency kits like this in terms of what might be needed for an evacuation, but it’s also good to have one prepared in the case of quarantine or self-isolation when you cannot leave your home.
While we are recommending these as good practices, it is important to remember that, to date, there have not been any reports of pets or other animals becoming ill with SARS-CoV-2, and there is currently no evidence that pets can spread COVID-19 to other animals, including people.
Should any animal showing signs of respiratory illness be tested?
USDA and CDC do not recommend routine testing of animals for this virus. Because the situation is ever-evolving, public and animal health officials may decide to test certain animals out of an abundance of caution. The decision to test will be made collaboratively between local, state or federal public and animal health officials.
Should I avoid contact with pets or other animals if I am sick from coronavirus (COVID-19)?
You should restrict contact with pets and other animals while you are sick with COVID-19, just like you would with other people. Although there have not been reports of pets becoming sick with COVID-19 in the United States, it is still recommended that people sick with COVID-19 limit contact with animals until more information is known about the virus. When possible, have another member of your household care for your animals while you are sick. If you are sick with COVID-19, avoid contact with your pet, including petting, snuggling, being kissed or licked, and sharing food. If you must care for your pet or be around animals while you are sick, wash your hands before and after you interact with pets. More information is available on how to keep people and animals safe at https://www.cdc.gov/coronavirus/2019-ncov/daily-life-coping/animals.html.
What should I do if I think my animal has the virus?
Call your veterinary clinic with any questions about your animal’s health. In order to ensure the veterinary clinic is prepared for the household animal, the owner should call ahead and arrange the hospital or clinic visit. Make sure to tell your veterinarian if your animal was exposed a person sick with COVID-19, and if your animal is showing any signs of illness. Veterinarians who believe an animal should be tested will contact state animal health officials, who will work with public and animal health authorities to decide whether samples should be collected and tested.
The state of Hawaii has indicated veterinarians and their staff are essential health care providers included in Tier 1b of the COVID-19 vaccination rollout. To receive more information, fill out the Department of Health survey. The Department of Health will directly contact you to follow up. You may also check their website for updates.
COVID-19 Vet Resource Survey
Please help Hawaii better understand our veterinary resources (PPE, ventilator equipment, staff) by filling out our survey.
If you are looking to immediately donate any PPE or help with sewn cloth mask donations, please see UH School of Medicine’s Masks4HI webpage.
Guidance on Resuming Elective Services
Veterinary Medicine is an essential business that is part of the critical infrastructure of the United States. Many states did not place formal restrictions on the practice of veterinary medicine, while some states and localities instituted restrictions upon performing non-urgent or elective procedures.
During this crisis, veterinarians continue to exercise their professional judgment as to which services and procedures are urgent or potentially urgent (including those that may be necessary to protect certain vulnerable animal populations, prevent adverse effects on public health, or ensure the safety and security of the food supply if not performed) and which might be postponed. The AVMA also developed case management and triage decision trees to help veterinarians determine urgent and potentially urgent cases, using their professional judgment; support social distancing; and assist in conserving personal protective equipment (PPE).
At this time, resuming non-urgent or elective veterinary services is appropriate. There is a backlog of demand for elective or non-urgent veterinary care that is important for the health and welfare of animals. Failure to provide comprehensive veterinary care places both animal and public health at risk. Veterinarians have adapted to conserve PPE that is in short supply for the delivery of human healthcare, and the original concern that performing non-urgent or elective veterinary procedures would negatively impact the availability of PPE for human healthcare providers has largely been ameliorated. Veterinarians should have also incorporated creative and effective measures that are consistent with social distancing recommendations and limit person-to-person exposure for staff and clients.
As veterinarians resume providing non-urgent/elective services, veterinary practices should continue invoking strategies that conserve PPE and support social distancing as appropriate and practical. Some measures that have been adopted, as appropriate to practice type, include:
Triaging appointments by phone or videoconference, and handling via telemedicine as medically appropriate and as permissible under federal and state law and guidance on what is permissible during the COVID-19 disaster declaration.
Inquiring as to whether the client or caretaker is ill with, or may have been exposed to, COVID-19. If so, encouraging someone other than the ill client to bring the patient to the hospital, if in-person care is necessary, or providing care via telemedicine if medically appropriate and permissible under federal and state law and guidance on what is permissible during the COVID-19 disaster declaration.
Scheduling appointments so that patient flow can be managed, and social distancing of clients maintained.
Restricting the number of clients waiting in the lobby for their appointments and enforcing social distancing.
Directly admitting clients and patients to examination rooms from their cars, rather than having them wait in the lobby.
Curb-side pickup of patients, keeping clients out of clinics except when required. This includes having clients remain in their vehicles in the parking lot while the patient is evaluated, with veterinarian/client communication by phone or videochat.
Curbside delivery of medication refills and veterinary diets
Encouraging clients who travel to the clinic to don cloth face coverings.
Having staff, rather than owners, hold animals during examinations.
Extra attention to cleaning of often-touched surfaces, including an increase in frequency.
Adoption of PPE conservation strategies, including extended use of disposable PPE (as appropriate) and replacement of disposable PPE with reusable and appropriately maintained/sterilized cloth gowns and masks.
Conducting daily health assessments or self-evaluations of employees, requiring staff to stay home if sick, and immediately sending staff home if they become ill while at work.
Dividing clinic staff into teams, so that if a team member is known to be exposed to or becomes ill with COVID-19, it largely localizes risk to that team while allowing important veterinary services to continue to be provided.
Diligently apply practices to prevent the spread of infectious disease, such as frequent handwashing and wearing gloves whenever appropriate.
Routine testing of animals for COVID-19 is NOT recommended by the American Veterinary Medical Association (AVMA), American Association of Veterinary Laboratory Diagnosticians (AAVLD), National Association of State Public Health Veterinarians (NASPHV), or the National Assembly of State Animal Health Officials. Nor is it recommended by key federal agencies, including the CDC and USDA.
Current expert understanding is that SARS-CoV-2 is primarily transmitted person-to-person. There is currently no evidence that animals can transmit this virus to people. In rare instances, people have spread the virus to certain animals.
Veterinarians are strongly encouraged to rule out more common causes for clinical signs in animals before considering testing for SARS-CoV-2. The CDC, USDA, and other federal partners have created guidance, including a table of epidemiological risk factors and clinical features for SARS-CoV-2 in animals to help guide decisions regarding animal testing.
The decision to test an animal should be made collaboratively between the attending veterinarian and local, state, and/or federal public health and animal health officials after careful consideration of this guidance as provided.
On March 29th, Governor Ige signed an executive order allowing veterinarians to practice telemedicine without a previously established Veterinary-Client-Patient-Relationship (VCPR) or physical examination of the patient to establish a VCPR. This order remains in effect only during the COVID-19 emergency period. Read full executive order here.
We are extremely appreciative that our local government is enabling us to continue to care for patients while we respect the current social distancing and shelter-in-place orders to prevent the spread of COVID-19. AVMA has laid out specific guidance on Telemedicine.
On March 24th, FDA announced that they are taking steps to temporarily suspend enforcement of certain federal VCPR requirements as it relates to allowing veterinary telemedicine during this period of social distancing. This change only affects regulations regarding extralabel drug use in animals and veterinary feed directives. Read press announcement here.
CARES Act small business loan programs Learn how to prepare for the new Paycheck Protection Program launching Friday, and understand how it compares with the U.S. Small Business Administration’s (SBA) Economic Injury Disaster Loans.
COVID-19 Insurance Claims and CARES Act Leave Provisions Understand the paid leave and unemployment insurance provisions in the stimulus package and how they might apply to you and your business in this webinar with insurance and employment law experts – sponsored by AVMA LIFE and AVMA PLIT.
Essential vs. Non-Essential Services
HVMA and AVMA are working to educate our
state and local governments on the essential services that veterinarians
provide. We strongly discourage veterinarians from offering
non-essential services during this period as this undermines our
efforts. Continuing to offer or promote non-essential services during
this period of government-mandated social distancing increases the risk
of virus transmission to our staff, our clients, and our communities at
large. Additionally, continuing to perform non-essential procedures and
surgeries uses up limited resources that are in short supply and may be
necessary for essential procedures and surgeries in the near future.
Please consider the serious consequences of continuing practice as usual
in the face of the rapid and undetected spread of COVID-19. Below are
several guidelines to help you determine which services are essential.
“As restrictions in elective or non-essential services are put in place, either voluntarily or through government or regulatory body mandates, careful consideration of what is considered essential is needed. Essential procedures include those required to alleviate animal pain and suffering, to prevent imminent threat of death of the animal, and matters pertaining to public health (e.g. vaccination against rabies). Other considerations may be involved, including supply availability, the ability of the clinic to practice appropriate social distancing, and factors related to management of specific cases either in the clinic or at home.
“Recommendations may change based on our growing understanding of this disease, changes in messaging from governments and regulators, and as this pandemic evolves. Veterinarians and owners must understand this is a fluid situation and the goal cannot be maintaining “business as usual” but rather providing the optimal outcomes for animals, owners and veterinary facilities, while doing our part to support social distancing efforts. Any consultations that do not absolutely require physical contact with the animal should be done via telemedicine.”
The University of Florida Health’s department of anesthesiology has developed 2 prototypes for respirator masks that can be produced in large quantities using materials already found in hospitals and medical facilities. The makeshift mask uses Halyard H600 two-ply spun polypropylene that cannot be penetrated by water, bacteria, or particles. It blocks 99.9% of particulates, making the masks about 4% more effective at blocking particulate material than the N95 masks. Read more and see tutorials here.
Federal CARES Act
The Coronavirus Aid, Relief and Economic Security Act (CARES Act) was passed and signed on Friday March 27th. The CARES Act seeks to:
Support businesses to retain their employees and maintain operations
Expand unemployment insurance benefits in light of COVID-19 emergency
Provide individual support
AVMA has provided resources here to help veterinarians understand and interpret this legislation.
Effective March 25 through April 30, 2020, everyone in the State of Hawai‘i is required to stay at home or in their place of residence. This supplement to Governor David Ige’s emergency proclamation was announced on March 23, 2020. Read more here.
Under the proclamation, individuals may leave their home or place of residence only for essential activities, to engage in essential businesses and operations, and only if their work cannot be conducted through remote technology from home.
Veterinarians are currently considered essential businesses. Please continue to refrain from offering non-essential services during this period so we can maintain this status. Offering or promoting non-essential services uses up limited resources that are in short supply and may be necessary for essential procedures and surgeries in the near future. Additionally, encouraging clients to come into public spaces during this period of government-mandated social distancing increases the risk of virus transmission to our staff, clients, and communities at large.
Self-Quarantine for Travelers Arriving After 3/26
Effective, Thursday, March 26, 2020, all persons entering the State of Hawai‘i must self-quarantine for 14 days or for the duration of their stay in Hawai‘i, whichever is shorter. Residents returning to Hawaii must also self-quarantine in a designated location in their residence. If you are assisting with pet travel into the state of Hawaii, please notify pet owners of the self-quarantine requirement.
The Rabies Quarantine Station in Halawa Valley is currently closed to visitors. Pets may be released from quarantine as soon as the mandatory quarantine period is completed. Details on self-quarantine procedures (pdf)
During this time of undetected spread of COVID-19, please protect your staff, your clients, and your community. If you or one of your staff becomes ill or is known to be exposed to COVID-19, in addition to concerns about your and their wellbeing, there is the possibility that you will be asked by public health officials to temporarily close your practice for personnel isolation and facility cleaning.
With this risk in mind, veterinarians should work to reschedule all nonessential appointments so as to limit public exposure. This includes wellness visits for vaccinations, spay/neuter procedures, routine dental procedures, and anything that can be safely delayed for a few weeks to months.
Veterinary staff members who have symptoms of acute respiratory illness should stay at home and should not return to work until they are free of fever (fever is defined as a temperature of 100.4F or higher, using an oral thermometer), signs of a fever, and any other symptoms for at least 24 hours without the use of fever-reducing or other symptom-altering medicine (e.g., cough suppressants).
In addition, veterinary clinics should be aware that the limit on statewide gatherings of 10 people applies to activity in their clinics.
Telemedicine and emergency teletriage within the context of an existing VCPR can be extremely helpful in limiting your staff’s exposure, and enable you to support and monitor the health of your patients and conform to local requirements, while preventing the potential spread of COVID-19. Conducting pre-visit triage can help protect you and your staff as you prioritize and determine which patients need to be seen at the clinic.
Please do the right thing to limit the spread of this disease in our community.
COVID-19 and Pets
Infectious
disease experts and multiple international and domestic human and
animal health organizations agree there is no evidence at this point to
indicate that pets become ill with COVID-19 or that they spread it to
other animals, including people.
If
you are not ill with COVID-19, you can interact with your pet as you
normally would, including walking, feeding, and playing. You should
continue to practice good hygiene during those interactions (e.g., wash
hands before and after interacting with your pet; ensure your pet is
kept well-groomed; regularly clean your pet’s food and water bowls,
bedding material, and toys).
Out
of an abundance of caution, it is recommended that those ill with
COVID-19 limit contact with animals until more information is known
about the virus. Have another member of your household take care of
walking, feeding, and playing with your pet. If you have a service
animal or you must care for your pet, then wear a facemask; don’t share
food, kiss, or hug them; and wash your hands before and after any
contact with them.
Managing Veterinary Practice in a Pandemic:
Multiple universities and practices have implemented the following practices to protect the health of their employees, clients, and surrounding communities:
Limit
patient care to acutely ill animals and/or emergencies. Animals that
are sick or injured should receive veterinary attention.
Reschedule
existing new and recheck appointments that are considered non-essential
(unlikely to experience significant harm if treatment is not
administered in a timely manner).
Reschedule elective procedures.
Utilize telemedicine to assess patient condition and needs.
If
an animal needs to be seen in person, a healthy family member or friend
should bring their sick animal to a veterinary hospital or clinic.
Have clients drop off their animal and remain in their cars during appointments.
When meeting clients, veterinary team members should wear appropriate PPE.
In light of limited supply, be strategic in the use of personal protective equipment (PPE), including masks, gowns, and gloves.
If
a mobile or house call veterinarian must examine an animal in a home
where someone is ill with COVID-19 and no other options are available,
consult with local public health officials for guidance. Appropriate PPE
and access to handwashing and disinfection materials should be
considered in all cases.
Keeping Your Veterinary Team Healthy:
Veterinary
healthcare team members who have symptoms of acute respiratory illness
should stay at home and should not return to work until they are free of
fever (100.4F or higher, using an oral thermometer) and any other
symptoms for at least 24 hours without the use of fever-reducing or
other symptom-altering medicine (e.g., cough suppressants).
Communicate
about COVID-19 with your team. Flexible sick leave policies are
important and team members should be made aware of these policies. Team
members who appear to have symptoms of acute respiratory illness upon
arrival at work or who become sick during the day should be separated
from other team members and sent home immediately.
If
a team member is confirmed to have COVID-19, the veterinary practice
owner should inform other team members of their possible exposure to
COVID-19, but maintain confidentiality as required by law. Team
members who are exposed to another employee with confirmed COVID-19
should contact their physician or local health department to determine
how best to proceed.
Surfaces
in the veterinary clinic/hospital that are touched frequently, such as
workstations, keyboards, doorknobs, countertops, and stethoscopes,
should be cleaned often and wiped down by employees with disposable
wipes between cleanings.
Provide no-touch disposal receptacles.
Place hand sanitizers in multiple locations, including in exam rooms, offices, and conference rooms to encourage hand hygiene.
Team members should avoid close contact (within approximately 6 feet) with other people who are ill.
Avoid touching your eyes, nose, and mouth.
Cover your cough or sneeze with a tissue, then throw the tissue in the trash.
Wash
your hands often with soap and water for at least 20 seconds,
especially after coughing, sneezing, going to the bathroom, and before
eating.
If soap and water are not readily available, use an alcohol-based hand sanitizer with at least 60% alcohol.
Families First Coronavirus Response Act:
On March 18, 2020, the President signed into law the Families First Coronavirus Response Act (H.R. 6201).
The final bill included some significant policy changes from the
original proposals that were intended to address both the impacts on
small businesses and individuals. We expect lawmakers to continue to
address economic measures for small businesses and individuals through
future legislative packages.
Lawmakers and the Administration remain engaged in ongoing
negotiations to produce additional measures, and AVMA continues to
ensure the concerns of the profession are heard as this dynamic
situation unfolds.
The final bill includes:
FMLA COVID-19 benefit – This benefit provides up to 12
weeks of family and medical leave benefits related to the coronavirus to
be paid at 2/3 of regular pay rates after the first 10 days, which are
unpaid. The leave is only available for child care in the event of
school closure or if the employee’s child care provider is unavailable
due to the public health emergency.
COVID-19 sick leave – This benefit applies up to 80 hours of
additional paid sick leave for employees related to the coronavirus.
There are daily and aggregate caps on the sick leave benefit of either
$511 per day and $5,110 in the aggregate if the employee is sick or
quarantined, and $200 per day and $2,000 in aggregate if the employee is
caring for someone else.
Potential exemption – There is language granting authority to the
Department of Labor to create regulations that can exempt small
businesses with fewer than 50 employees from the leave requirements when
the imposition of the requirements would jeopardize the viability of
the business as a going concern.
Tax credits – There are tax credits for employers intended to mitigate the impacts of the expanded leave provisions; and
COVID-19 testing – It provides for free testing for the coronavirus during the emergency.
Significantly, the FAQ DOL indicates the effective date for the Families First Coronavirus Response Act is April 1, 2020, and applies to leave taken between April 1, 2020, and December 31, 2020.
For the exemption for business with fewer than 50 employees when
providing the leave under the act would jeopardize the viability of the
business, DOL advises that for now employers should document why they
believe this to be the case. DOL then indicates that more detail will
be forthcoming in regulations.
In recent weeks, several veterinary practices on O’ahu have reported seeing a number of feline panleukopenia cases. Below is a link to a summary on Feline Panleukopenia provided on the AVMA website for review. Veterinarians who have had patients suspected of dying from panleukopenia can contact Dr. Aleisha Swartz for information on further confirmatory testing including necropsy and PCR at president@hawaiivetmed.org.
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