Writing a VFD? VCPR definition requires vets to have ‘sufficient knowledge’ of herd

Swine veterinarians issuing a veterinary feed directive (VFD) are expected to comply with the federal definition of a veterinary-client-patient relationship (VCPR) or their state definition if it contains the key elements of the federal definition.

One key element of the federal VCPR definition requires veterinarians to have have “sufficient knowledge” of animals to provide at least a general or preliminary diagnosis of their medical condition. FDA expands upon that definition in its updated VFD rule.¹

A VCPR relationship exists, the agency says, only when the veterinarian has recently seen and is personally acquainted with the keeping and care of the animals by examining them or by making medically appropriate and timely visits to the premises where the animals are kept.

Most swine veterinarians have ongoing relationships with their clients and the animals being treated, FDA says. They are also familiar with the individual animal-production operations and have made previous visits to the producers’ facilities. The VCPR also allows veterinarians to provide education to producers about medications, including storage, use and withdrawal times, FDA says.

“FDA expects that a veterinarian will only authorize use of a VFD feed in animals for which he or she has such knowledge and familiarity,” according to the final VFD rule.

Most states incorporate the knowledge or acquaintance criterion in their VCPR definitions, the agency says. They also provide detail that’s similar to the federal definition. Some states are even more detailed and specify the time period in which the animal must have been seen by the veterinarian, FDA says.

A few states don’t have knowledge or acquaintance criterion but instead require the veterinarian to examine the animals or a representative segment of the herd. Thus, in most states, the VCPR requirements regarding responsibility are the same or similar to the current federal definition.

If swine veterinarians are not sure which VCPR definition to follow, they should check the FDA’s reference list to see which applies.

1. Veterinary Feed Directive. Final Rule. Federal Register/VOL. 80, No. 106/Wednesday, June 3, 2015/Rules and Regulations.