Category: Timely Topics

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.

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