PET MEDICATION 

PRESCRIBING AND 

DISPENSING OVERVIEW

Adrian Hochstadt

Assistant Director

State Legislative and 

Regulatory Affairs

American Veterinary Medical 

Association (AVMA)

 

 
AVMA PRINCIPLES OF

VETERINARY MEDICAL ETHICS

Sec. III

A. The veterinarian-client-patient 

relationship (VCPR) is the basis for 

interaction among veterinarians, their 

clients, and their patients.

C. Dispensing or prescribing a prescription 

product requires a VCPR. 

(All states except AK, CT, ME, WA and DC 

have a specific law or regulation requiring a 

veterinarian to have VCPR to treat a 

patient)
FEDERAL REGULATIONS

REQUIRING VCPR

 USDA APHIS CVB – Autogenous Biologics 

– 9 CFR 113.113. Autogenous biologics 

are restricted to use by or under the 

direction of a licensed veterinarian within 

a veterinarian-client-patient relationship, 

or, by an approved non-veterinarian 

specialist under certain situations.
FEDERAL REGULATIONS

REQUIRING VCPR

 FDA CVM – Extralabel Drug Use – 21 CFR 

530.10. An approved new animal drug or 

human drug intended to be used for an 

extralabel purpose in an animal is not unsafe 

under section 512 of the act and is exempt 

from the labeling requirements of section 

502(f) of the act if such use is: (a) By or on 

the lawful written or oral order of a licensed 

veterinarian within the context of a valid 

veterinarian-client-patient relationship; 

and(b) In compliance with this part.
FEDERAL REGULATIONS

REQUIRING VCPR

 FDA CVM – Veterinary Feed Directive –

21 CFR 558.6 (a)(2): You must issue a 

VFD only within the confines of a valid 

veterinarian-client-patient relationship 

(see definition at § 530.3(i) of this 

chapter).
AVMA PRINCIPLES OF

VETERINARY MEDICAL

ETHICS

Sec. III (c):

1. Veterinarians should honor a client’s 

request for a prescription in lieu of 

dispensing. 
SPECIFIC LAW, REGULATION OR POLICY STATEMENT

REQUIRING VETERINARIAN TO PROVIDE PRESCRIPTION

UPON REQUEST

(17 STATES)
ADOPT OR INCORPORATE AVMA PRINCIPLES OF 

VETERINARY MEDICAL ETHICS IN LAW OR REGULATION

(ADDITIONAL 10 STATES)
ARIZONA

A. A dispensing veterinarian shall notify an animal owner 

that some prescription-only drugs and controlled 

substances may be available at a pharmacy by:

 1. Stating the availability at or before the time of 

dispensing;

 2. Posting a written statement that is visible to the 

animal owner; or

 3. Providing the animal owner with written notification.

B. A dispensing veterinarian may provide a written 

prescription to the animal owner if requested by an 

animal owner. 

[Arizona Administrative Code, R3-11-801]
CALIFORNIA

(6) The prescriber, prior to dispensing, must offer 

to give a written prescription to the patient that 

the patient may elect to have filled by the 

prescriber or by any pharmacy. 

(7) The prescriber must provide the patient with 

written disclosure that the patient has a choice 

between obtaining the prescription from the 

dispensing prescriber or obtaining the prescription 

at a pharmacy of the patient's choice.

[Business and Professions Code, Article 12, Sec. 

4170] 
H.R. 1406, TITLED “FAIRNESS TO

PET OWNERS ACT”

Would require veterinarians to:

Provide pet owners with a copy of the 

prescription, regardless of whether or not a 

client requests one; 

Provide a written disclosure that the pet owner 

may fill the prescription through the prescriber 

or through another pharmacy determined by 

the pet owner; 

Provide or verify the prescription by electronic 

or other means if requested by any person 

designated to act on behalf of the pet owner.
H.R. 1406, TITLED “FAIRNESS

TO PET OWNERS ACT”

Would prohibit veterinarians from:

Requiring pet owners to purchase a 

prescribed drug as a condition for 

providing a prescription;

Requiring payment for providing or 

verifying a prescription; 

Requiring a pet owner to sign a waiver 

or disclaim liability for the accuracy of 

the veterinary prescription as a 

condition for providing or verifying a 

prescription.