Who can deliver medication to the client?
Earlier this week, we sent out a newly revised Task Guide, the reference chart for veterinarians who assign tasks to licensed veterinary technicians (LVT), unregistered assistants (UA), and registered veterinary medication clerks (VMC), as well as for LVTs who supervise UAs, and VMCs. Most of the chart remained unchanged, but there were a few important revisions made for accuracy and clarity.
Here are the following changes:
- UAs are prohibited from maintaining anesthesia per WAC 246-935-010. No change was made on the chart. However, it’s understood to be a common violation in many practices.
- Removed “Assist surgeon by tissue handling” as an allowed task for LVTs. This task is not stated in the WAC, so was removed for accuracy. LVTs and UAs are allowed to assist with instrument and tissue handling, although it falls to the discretion and responsibility of the veterinarian.
- Removed “Assist surgeon by instrument handling” as an allowed task for LVTs. This task is not stated in the WAC, so was removed for accuracy.
- UAs are prohibited from administering biological vaccines for rabies and diseases listed in WAC 16-42-026 (2) unless under direct supervision. They must be supervised by the veterinarian, not an LVT.
- UAs may collect blood pressure and electrocardiogram readings under direct supervision. The previous version confused many by the way it was stated.
- UAs and other staff are prohibited from delivering the medication to the client. Only a veterinary, LVT or VMC can deliver medication to a client. Deliver is defined in RCW 18.64.011 (8).
Number six (6), about who can deliver medication to the client surprised a few members and prompted many calls and emails. For the record, only registered veterinary medication clerks, LVTs or veterinarians can “deliver” legend drugs to the client. This doesn’t represent a change to the law, but there was a concern that many practices were unaware of this requirement, so we revised the chart to make it as clear as possible.
Here’s how the language reads from WAC 246-937-030, the regulations that govern veterinary medication clerks:
(1) A registered veterinary medication clerk may perform the following tasks only under the direct supervision of a licensed veterinarian: Counting, labeling, and packaging of legend drugs. A licensed veterinarian must personally inspect all packaged medication orders to ensure the accuracy of the order prior to delivery to the client. The licensed veterinarian will document the medication inspection by placing his/her initials in the patient’s record.
(2) A registered veterinary medication clerk may perform the following tasks under the indirect supervision of a licensed veterinarian: Ordering, stocking, inventorying, and the delivery of legend drugs. The identity of the client must be confirmed before the delivery of legend drugs.
Controlled drugs can only be handled by the veterinarian or by an LVT under indirect supervision.
The Veterinary Board of Governors tentatively plans to open the rule next year that addresses tasks performed by LVTs and UAs. The WSVMA and the public will have ample opportunity to comment on proposed changes.
If you have any questions, please call our office at (800) 399-7862 or reach out to the Veterinary Board of Governors at (360) 236-4947.
Download the new version of the Task Guide here (login required.)
Posted September 6, 2019