Why are the legislators in Maine including veterinarians in a bill that is geared towards stemming the opiate epidemic?
The nation has an opioid abuse problem and it’s naive to think some animals owners have never diverted their pet’s medication or sought drugs for the animal when it’s really for them. To vet shop, however, requires more than doctor shopping. When doctor shopping one much be a very good actor. If you have a history of chronic pain even better. Veterinarian shopping requires a prop; your animal. It means establishing a profile for your pet at numerous veterinary practices. It means paying multiple veterinary bills to get drugs which A. aren’t really the type an addict wants and B. could be obtained cheaper on the street or through friends.
It’s not uncommon for veterinarians to prescribe painkillers to animals that suffer from chronic pain or that have undergone surgery. In some cases, these painkillers can be opioid-based. But what our legislators fail to take into consideration is the dosing difference between humans and animals; the dosing difference between felines and canines. And unlike a human who can “act” the part of a person in pain and verbalize their symptoms, animals can’t. Because they cannot communicate, non-verbal cues are the best way to determine the severity of a pet’s pain regardless of what the owner says. The veterinarian listens to the owner describe what Pup or Kitty are doing but then does a physical assessment of the animal. The last two decades have seen a huge change in the way veterinary medicine addresses pain in an animal. Whereas the previous line of thinking was “Animals don’t feel pain” or “Keep them quiet and it will speed their healing because they won’t move around much”. Thankfully the veterinary profession has embraced the idea of pain management for both large and small animals and several pain scales are currently in use. Colorado State University Veterinary Medical Center uses this scale to evaluate acute pain in kittens and this one to evaluate acute canine pain.
A November 2015 publication from JAMA gives an excellent overview of how pain is assessed and evaluated in animals whether it’s acute as in surgical or chronic like osteoarthritis. And if one is fortunate to live in a progressive area, there are even pain management clinics for animals like the one at Cummings Hospital which is part of The Veterinary School of Medicine at Tufts University in Massachusetts. More than ever, veterinarians are aware of the pain in animals whether it be a broken leg, advanced arthritis or cancer. This excellent article, The Hurt Unlocker, by Genevieve Rajewski, Editor for Tufts Veterinary School, gives a great overview of pain in animals and how it’s best managed.
PL 488 requires the following parameters for veterinarians:
- All veterinarians who prescribe opiates or benzodiazepines must register as data requesters with the PMP
- All veterinarians must check the records of the individual seeking care for the animal, and if appropriate the owner, prior to prescribing opiates or benzodiazepines. A valid state or federal photo ID should be checked, and a birthdate and the full name must be acquired in order to check the PMP of an individual. This would also apply to anyone you had to drop off or pick up Fido.
- All written prescriptions must include a DEA number.
- All prescriptions intended for use by an animal must indicate such use on the prescription.
- Diagnosis and exemption codes are not required for veterinary prescriptions.
- As of July 1, 2017, veterinarians with the capability to prescribe electronically will be required to do so. In April 2017 a waiver is expected to be released that will allow veterinarians without the capability to apply to be exempt.
- The Aggregate Morphine Milligram Equivalent for the person who either owns the animal or is transporting. The 100 MME/daily limit would include the anticipated new prescription.
- The number of prescribers currently prescribing controlled substances to the individual.
- The number of pharmacies currently filling prescriptions for controlled substances for the individual.
- Veterinarians will be required to complete three hours of CE (continuing education) related to the prescription of opioids by December 31, 2017, and subsequently every two years. **
The Maine Veterinary Medical Association has even “helped” veterinarians by preparing a presentation plus consent form for the humans to sign which gives the veterinarian or his designate permission to access the person’s drug records. What exactly does that mean? If narcotics are being prescribed, the human bringing the animal in or picking the animal up must consent to have their drug records accessed by someone in the veterinary practice. Let’s think about this for a minute. Your dog has surgery and because of the postoperative pain, the veterinarian wants to prescribe tramadol, a Schedule III narcotic as of 2014. Because of work hours, you ask your neighbor to pick Fido up. Imagine their shock when they have to fill out the consent form, show their driver’s license or another form of photo ID and wait while their drug profile is accessed and evaluated by a veterinarian, highly trained and skilled in animal medicine. And if the veterinarian calculating the human dosage determines your neighbor is at the top of the 100 MMEs daily allotment and the tramadol for your dog would exceed that amount, legally they can’t prescribe it. Also, a veterinarian had no way of knowing why a person is on the controlled drugs; only that they are. Based on numbers found in a database, a highly skilled veterinarian is being ordered by the State of Maine to practice veterinary medicine but use human protocols. In short, they are being mandated to practice outside their scope which is a violation. To ask a veterinarian who as I outlined in my previous post has extensive knowledge of animal physiology to prescribe pain medication for an animal based on how much of the daily allotment a human already has prescribed for them by a medical doctor is absolutely ludicrous.
Then there is palliative care for an animal with an end-stage disease that is painful. The State has not set any exemptions for veterinarians but has for human doctors.
Prescribers are exempt from the limits on opioid medication prescribing established in this rule if:
Pain associated with active and aftercare cancer treatment. Providers must document in the medical record that the pain experienced by the individual is directly related to the individual’s cancer or cancer treatment. An exemption for aftercare cancer treatment may be claimed up to six months post remission
Palliative care in conjunction with a serious illness;
As someone who had a beloved dog diagnosed with canine lymphoma in October 2015, I would have been beyond furious if her oncologist couldn’t prescribe opiates for her as she neared the end ~ simply because my daughter or I were at the top of the daily allotment.
Addiction is an epidemic that can no longer be ignored. However the welfare of innocent animals should not be impacted, veterinarians mandated to operate at best, on the fringe of their scope of practice, nor our guarantee of privacy under HIPAA violated because neither veterinarians nor their staff is bound by HIPPA regulations.
Yet the State of Maine is doing all of these things.