ARE YOU READY FOR A COMPLIANCE INSPECTION?
We continue to document chronic problems that exist in the areas of Continuing Education (CE), Controlled Substances, and Prescription Labels. Licensees are subject to unannounced on-site inspections at anytime. Veterinarians are strongly encouraged to keep their CE records in the facility where they are practicing. Under rule 573.64, CE records must be maintained for the last 3 renewal cycles and be provided to the Board investigators for inspection upon request. When practicing veterinary medicine, relief and mobile veterinarians are requested to keep with them copies of their CE records, current renewal certificate and DEA/DPS Controlled Substances Permits/Certificate. Controlled Substances logs must maintain balance on hand at all times. The log book must also contain the proper information concerning the purchase, identification and use of controlled substances. For more information on controlled substances and record keeping, please review rule 573.50. Prescription labels must contain the species being treated. For further information on labeling, please review rule 573.40.
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Compliance visits have revealed that some licensees are not posting the required Complaint Information Notice " . . . in an effective way to inform his/her consumers . . . about how to file complaints . . ." as required by rule 573.29.
Also, many practitioners are under the impression that DEA and DPS Drug Permits/Certificates must be posted. These notices do not need to be posted and in fact we discourage posting them. The registrant's drug license number is shown on these certificates and if the wrong person got these numbers, drugs could be ordered under the practitioner's registration number.
Patient Record Keeping
Rule 573.52 of the Rules of Professional Conduct, addresses patient records and what should be included in each record. Section (a)(14) of this rule states ". . . Each entry in the patient record shall identify the veterinarian who performed or supervised the procedure recorded." When reviewing the patient records involved in consumer complaints, we continue to have difficulty identifying the DVM that performed a given procedure. Please remember each entry on the record should include at least the initials of the licensee that performed the procedure.