By: Dr. Ashley Morgan, assistant director, Governmental Relations Division
Given an ambiguous response from the Drug Enforcement Administration late this spring regarding how veterinarians should transport and dispense controlled substances while away from their clinics, AVMA continues to seek confirmation and clarification from the agency.
In a May 2013 letter to Congress, DEA stated that veterinarians are allowed to bring and use controlled substances–which are used to provide pain management, anesthesia and euthanasia–on an “as-needed and random basis” so long as the locations are within a state where the veterinarian is registered and the location is not a principal place of practice. Previously, the agency said that the Controlled Substances Act (CSA) does not permit veterinarians to bring these medications away from their principle places of business, often their clinics or homes.
Although the agency has responded to Congress, it still remains unclear as to what constitutes an “as-needed and random basis” and a “principal place of professional practice.” It also does not resolve the issue of a veterinarian who registers in one state where he or she is licensed, but also practices in another state (such as a veterinarian who lives on the border of two states and practices in both states). AVMA requested a meeting with the DEA to discuss the matter in June, but the agency denied that request. AVMA plans to send a follow-up letter to the agency again in January seeking clarification for its members (UPDATED BELOW).
In the meantime, AVMA continues to hear from veterinarians who are experiencing issues when they try to register using a residential address to provide veterinary care beyond their clinics or across state lines. DEA has failed to explain when they will notify their field offices of its updated stance on this issue.
AVMA’s Governmental Relations Division continues its strong advocacy campaign on Capitol Hill, encouraging members of Congress to pass the Veterinary Medicine Mobility Act (H.R. 1528/S. 1171), which will amend the CSA to explicitly allow veterinarians the access to the medications they need to do their jobs. To date, the bills have gained 123 cosponsors in the House and 11 in the Senate, and congressional leaders continue to push for this bill to be included in larger pieces of legislation, like the Farm Bill.
Please take a moment to send a message of support to your Congressional representatives through AVMA’s Congressional Advocacy Network.
Updated as of Dec. 18, 2013
AVMA’s Director of Governmental Relations Dr. Mark Lutschaunig sent a letter to DEA’s Chief of Liaison and Policy Cathy Gallagher on Dec. 17 requesting a meeting to discuss how the agency is enforcing the regulation. Read the letter here.