Veterinarian Compliance with DEA and SUPPORT Act

Recently, DEA announced the launch of the Suspicious Orders Report System (SORS) Online, a new centralized database [https://deadiversion.usdoj.gov/sors/index.html], where DEA registrants, including veterinarians, must report suspicious orders of controlled substances. Reporting by practitioner registrants and creation of the database by DEA was required when Congress passed the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT Act) last year. The DEA indicates that reporting a suspicious order to SORS Online constitutes compliance with the reporting requirement.

  • The reporting requirement applies to all DEA registrants, including veterinarians.  This is why veterinarians who are DEA registrants have been receiving communication from the DEA on the SUPPORT Act.
  • The circumstances under which it will impact veterinarians should be extremely limited, but the Act does apply to them.
  • All DEA registrants, including veterinarians, are required to design and operate a system to identify suspicious orders for the registrant and to report suspicious orders to the DEA.  The DEA advised that the plan should be in writing and could be requested during an inspection. 
    • Suspicious orders are defined as including requests for controlled substances of unusual size, deviating substantially from a normal pattern and orders of unusual frequency.
    • The DEA also said the definition is not inclusive and a veterinarian should report anytime there is something that makes the veterinarian suspicious. 
    • The AVMA is looking to develop a brief model plan that can be utilized.
  • The reporting requirement applies anytime a registrant, including a veterinarian, is requested to distribute/provide a controlled substance to another registrant under circumstances identified by the registrant as suspicious.  The example provided by DEA was where a veterinarian at one clinic asks to obtain a controlled substance from another veterinarian at a different clinic, such as seeking to obtain ketamine from a nearby clinic due to low inventory.  A veterinarian who receives a request to provide a controlled substance to another practitioner must be aware of the requirement to report the ‘order’ if the circumstances raise any suspicion to believe that the controlled substance will go for an illegal or diversionary purpose.
  • The reporting requirement and SORS Online database are solely for reporting transfers of a controlled substance from one DEA registrant to another DEA registrant that seem suspicious. Veterinarians are not to report to the SORS Online reporting system anything related to the administration, prescribing or dispensing of controlled substances that occur in the ordinary course of veterinary practice.  The SORS Online database is also not to be used for reporting suspicious or drug-seeking behavior of clients. 
  • If a veterinarian believes a request from another practitioner is suspicious, the veterinarian should not supply the controlled substance.  The veterinarian should register for the program on the DEA website and report the order to the electronic database (SORS Online).  A veterinarian only needs to register for the database at the time of the need to file a report of a suspicious order.
  • The DEA will be promulgating rules that will be published in the Federal Register. AVMA will review the rules and respond as appropriate.

Download the AVMA guidance and draft “system” for veterinarians here.

Veterinary Leadership Conference 2020 Report

David Gans, DVM
Hawaii Kai Veterinary Clinic

This year’s Veterinary Leadership Conference (VLC) was a great experience that I would recommend to all veterinarians of any experience or position in Hawaii. The VLC is organized in a way to help “rising leaders, presiding leaders, and experienced leaders” in private practice and professional organizations such as the HVMA.

A big focus on the leadership presentations this year was on personal wellness. A growing concern that the AVMA is trying to address by spreading awareness, providing resources for outreach and management of mental health conditions/concerns, and education in techniques for prevention and risk reduction.

The HVMA’s generous support was a great experience and I would encourage any newer veterinarians to reach out for the 2021 VLC for the opportunity to attend with support. The AVMA and HVMA both are bending over backwards to support our amazing profession and it’s our role to reach out and use all of their resources.

David Gans, DVM

AVMA Update – Jan 2020

The AVMA House of Delegates (HOD) conducted association business, considered policies, discussed topics of interest to members, deliberated and presented action items at the winter session held January 10-11 in Chicago. The Winter session for the House of Delegates was held at the same time as the Veterinary Leadership Conference.

The Volunteer Leaders are committed to representing member interests with this years passionate discussion around AVMA’s Resolution: Policy on Declawing of Domestic Cats. The revised policy states that declawing should not be considered a routine procedure and emphasizes the importance of professional judgment and client education in making decisions that best protect the health and welfare of the patient: “The AVMA discourages the declawing (onychectomy) of cats as an elective procedure and supports non-surgical alternatives to the procedure. The AVMA respects the veterinarian’s right to use professional judgment when deciding how to best protect their individual patients’ health and welfare. Therefore, it is incumbent upon the veterinarian to counsel the owner about the natural scratching behavior of cats, the alternatives to surgery, as well as the details of the procedure itself and subsequent potential complications. Onychectomy is a surgical amputation and if performed, multi-modal perioperative pain management must be utilized.”

Other Resolutions discussed and were approved by the HOD:
Resolution 1: AVMA Policy on Use of Technology in Veterinary Medicine, which states, in part: “The AVMA affirms and encourages the responsible and ethical development and use of technology for a variety of applications in veterinary medicine that can benefit and protect public health, animal health and welfare, and environmental health.”
Resolution 2: AVMA Policy on Cribbing in Horses, which states, in part: “The AVMA condemns the use of hog rings or other devices placed around the teeth to prevent cribbing in horses. These devices are detrimental to the welfare and health of the horse due to the potential to cause persistent pain, damage to the gingiva, periodontal disease and abrasive wear to adjacent teeth. The AVMA encourages research to understand and address the underlying causes of cribbing.”
Resolution 4: Revised Policy on Microchips, which states, in part: “The AVMA endorses the implantation of electronic identification in companion animals and equids and supports standardization in materials, procedures, equipment, and registries. Veterinary healthcare teams are thereby encouraged to recommend the implantation of electronic identification of animals to their clients.”

Membership

The AVMA membership is stronger than ever, with the association’s membership at more than 95,300. Three out of every four veterinarians are members of the AVMA. HOD members also heard updates on the AVMA’s member-focused initiatives: digital education platform, AVMA Axon; our Direct Connect practice resource; our wellbeing and recent graduate initiatives; and efforts related to advocacy and public policy.

The Veterinary Information Forum

Three topics were discussed during the HOD’s Veterinary Information Forum:
Student extern/practice volunteer: Veterinary work experience prior to and during clinical time in colleges of veterinary medicine is valuable. These experiences are part of the non-academic evaluation; give an understanding of our profession; provide to the students and volunteers a degree of comfort with animals in the clinical setting; and provide some basic technical skills and insight into the veterinary working world. These experiences come with the concern of risk, particularly in the case of injury and determination of liability. The action item for this topic is the AVMA Board of Directors develop a toolkit, including potential forms and an awareness campaign, for the protection of practitioners, students and other
members of the veterinary health care team.
Telehealth: An update on AVMA activities in 2019 included support for state veterinary medical associations to engage with regulators; communication and collaboration with industry; and further development of member-focused resources, including continuing education and online resources. The AVMA will continue its work to develop guidelines on telehealth and
connected care.
Cannabis and cannabis-derived products: While the House made no specific recommendations related to cannabis, the AVMA remains committed in 2020 to advocacy for regulatory clarity and the development of additional member-focused resources and education.

Other topics discussed during the Veterinary Information Forum were updates on sexual harassment in the workplace and the utilization of veterinary technicians. During the 2019 annual meeting a resolution was passed recognizing that sexual harassment in the workplace is a serious issue and asked the AVMA Board of Directors to develop supporting resources and report back to the House. The AVMA will work in 2020 to update the AVMA web site to include additional resources on the prevention of sexual harassment in the workplace, as well as include sexual harassment education in AVMA continuing education programs. In addition, the AVMA will explore identifying specific workplace harassment training programs to recommend to veterinary practices.

The AVMA Task Force on Veterinary Technician Utilization report was also shared with House members. The focus of the report was on veterinary technician education, licensing and regulation, economics, supply and attrition, and wellness.

Public Service Loan Forgiveness Program

The AVMA continues to advocate to protect and enhance the Public Service Loan Forgiveness Program, which has been under scrutiny due to the incredibly low acceptance rate to date and concerns about overall costs. The AVMA’s past efforts include:
– Leading 127 animal health organizations in sending a letter to Congress underscoring the program’s importance to the industry and asking lawmakers to protect Public Service Loan Forgiveness.
– Joining a broad coalition of organizations in sending a letter to Education Department officials expressing concern about the loan forgiveness denials.
– The AVMA is continuing to communicate members’ concerns about the program’s administration to Congress and the U.S. Department of Education.

If you were denied forgiveness through PSLF or have experienced issues with the program, please share your story using the AVMA’s online advocacy tools.

Leianne Lee Loy, Hawaii Delegate
Carolyn Naun, Hawaii Alternate Delegate

Letter from the President – Jan 2020

Aleisha Swartz, DVM
Aleisha Swartz, DVM
HVMA President

Hau‵oli Makahiki Hou!

Our 66th annual conference was a great success. Thank you to all who attended and those present in spirit. It was a time to catch up with old friends, meet new colleagues and learn in our ever-changing field. The connections with one another are a large part of our “why” as the HVMA and we are fortunate to have such a connected community. If you want to learn more about finding your “why” I highly recommend watching Simon Sinek’s Ted Talk on the subject, or even better, read the book Start with Why. If you have suggestions for future speaker topics, entertainment or anything you think would make the conference even more incredible in the future, please let us know.

Membership renewal is now open and I encourage you to renew early and encourage your colleagues to do so as well. Don’t forget that new graduates are eligible for waived or reduced fees depending on your graduation year! Your dues enable us to host great CE in addition to our other efforts including providing scholarships for veterinary and veterinary technician students, advocate on behalf of the veterinary profession in Hawaii, and give back to our community.

Some of the activities we are working on this winter are monitoring the state legislative session, participating in the AVMA HOD January meeting, judging at the upcoming 63rd Hawaii State Science and Engineering Fair (HSSEF), and reviewing our wellness committee functions. If you are interested in participating in any of these functions, please let us know as we can always use more volunteers!

On behalf of the board I wish you good health and well-being in the upcoming decade and I hope to hear more from you on what we can do to support you as a Hawaii veterinarian.

Aloha,
Aleisha Swartz

Meet a Member – Jennifer Ruby

Jennifer Ruby, DVM, DACVR

Dr. Jennifer Ruby is from the Hudson Valley, NY and pursued her veterinary education at Cornell University. She completed a rotating internship in medicine and surgery at Red Bank Veterinary Hospital in Red Bank, NJ, followed by a second internship in diagnostic imaging at the Veterinary Imaging Center of San Diego. In 2016, Dr. Ruby went on to complete a three year residency in diagnostic imaging at the University of Georgia, where she developed a strong interest in abdominal ultrasonography and neuroimaging in companion animals, and advanced imaging in exotic pets. One project that Dr. Ruby enjoyed completing during her residency was a study evaluating the brain of koi fish using magnetic resonance imaging. She became board certified in Diagnostic Imaging in September 2019 and joined Oahu Veterinary Radiology.

Dr. Ruby is excited to provide high quality diagnostic imaging services to the islands. She looks forward to reading CT and MRI cases, as well as providing radiograph interpretation and mobile ultrasound services to the local community. In her spare time, Dr. Ruby enjoys developing her burgeoning fruit garden, baking, hiking, scuba diving and traveling, as well as spending time with her two cats, Fergie and Muffin.

Veterinary Leadership Conference in 2020

We want you – Rising Leaders, Experienced Leaders, Presiding
Leaders – to attend the Veterinary Leadership Conference. This
conference, presented by your American Veterinary Medical
Association (AVMA) will help you develop, and expand your
leadership skills wherever you are in your Veterinary Career.
Continuing education (10 hours), Networking with colleagues, and
mentorship will be available in Chicago, Illinois January 9-12,
2020.

Also happening at this conference will be the Winter Session of
the AVMA House of Delegates (HOD). Interactive Sessions will
be available to breakdown Governance of the AVMA so that you
can discover ways to be involved, have your voice be heard, your
ideas shared and to make a difference in our profession.

Visit AVMA@Work to get more information about this conference and
ways that you can attend at reduced cost. Deadline for
Scholarships are October 31, 2019.


Both Carolyn Naun (Hawaii HOD Alternate Delegate) and myself
(Leianne Lee Loy – Delegate) will attend this yearly conference
and invite YOU to express, expand, gain more of your leadership
skills.

If you have any questions – please feel free to contact us via email
at contact@hawaiivetmed.org.

A Hui Hou and Aloha!
Leianne Lee Loy

Cannabis Info from AVMA

AVMA submitted comments to the FDA regarding critical veterinary issues related to cannabis products, and the importance of addressing them. The AVMA submitted the comments following a public hearing held by the agency in late spring to gather stakeholder input while considering regulatory frameworks for hemp derivatives—including CBD—used for therapeutic purposes and as food additives.

“Veterinarians have a strong interest in, and enthusiastically support, exploring the therapeutic potential of cannabis-derived and cannabis-related products,” according to the AVMA comments. “But we want to be sure we can have continued confidence in the efficacy, quality, and safety of products used to treat our patients.”

The AVMA’s concerns stem largely from the widespread marketing of cannabis-derived products, including hemp products, with health claims that haven’t received the required FDA evaluation and approval. “The FDA should establish a clear and efficient process for approval of cannabis-derived and -related therapeutic products, and then conduct consistent enforcement against manufacturers and distributors who are noncompliant,” the AVMA said in their comments. Read full AVMA article here.

In addition to advocating for practitioners, the AVMA provides several resources regarding cannabis:

Extortion Scam Targeting DEA Registrants

DEA is aware that registrants are receiving telephone calls and emails by criminals identifying themselves as DEA employees or other law enforcement personnel. In an attempt to create the illusion that these criminals are DEA employees, they have masked their telephone number on caller id with a phone number for a legitimate DEA office.  For example, these criminals have used the phone numbers for DEA’s Office of Congressional and Public Affairs and DEA’s 800 number which is used to provide direct support to DEA registrants.

Impersonating a federal agent is a violation of federal law. Registrants should be aware that no DEA agent will ever contact members of the public by telephone to demand money or any other form of payment or threaten to suspend a registrant’s DEA registration.

If you are contacted by a person purporting to work for DEA and seeking money or threatening to suspend your DEA registration, submit the information through “Extortion Scam Online Reporting” posted on the DEA Diversion Control Division’s website, www.DEADiversion.usdoj.gov.

AVMA Report Summer 2019

Aloha HVMA Colleagues and Happy Summer!

We are preparing for the American Veterinary Medical Association (AVMA) Summer Session for the House of Delegates which will begin prior to the AVMA Convention – “A Monumental Experience.”

Here are the highlights for our session beginning on Thursday August 1, 2019 in Washington DC:

2019 D.C. Hill Visits: Because we are in DC, we are planning on visiting our legislators to discuss the issues that are important to the AVMA and the veterinary profession. With over 200 individual meetings, this will be the largest veterinary event on Capitol Hill ever conducted by the AVMA!

We are scheduled to meet with Hawaii’s Members of Congress or their staff – Senators Mazie Hirono and Brian Schatz; Representatives Ed Case and Tulsi Gabbard. We will be focusing on three issues for the visits: Veterinary Medicine Loan Repayment Enhancement Act (VMLRPEA); Fairness to Pet Owners Act (FTPOA) and Association Health Plans Act (AHP).

Resolutions to be discussed and voted by the House of Delegates:
a) Model Veterinary Practice Act: The AVMA adopt the revised policy Model Veterinary Practice Act
b) Revised Policy on Judicious Therapeutic Use of Antimicrobials
c) Revised joint AABP-AVMA Policy on Judicious Therapeutic Use of Antimicrobials in Cattle
d) Sexual Harassment Awareness
e) Revised Policy on Pet Heath Insurance
f) Revised Policy on Veterinary Dentistry

Proposed Bylaws Amendment:
a) Council on Research – Responsibility
b) Board of Directors – Qualifications
c) Board of Directors – Composition

AVMA Elections:
There are multiple positions that will be voted on by the House of Delegates:
a) President-Elect
b) House Advisory Committee
c) 6 Council Positions

Congratulations to Carolyn Naun who will be a speaker at this year’s AVMA Convention!

If you need to contact us with comments about the topics we mentioned, here is our email: AVMA_Delegate_HI@avma.org

Aloha!
Leianne K. Lee Loy
Hawaii Delegate

Carolyn Naun
Hawaii Alternate Delegate