ABVA Guidance on OOH Provision for Veterinary Surgeons Offering Acupuncture as their only service.

This guidance was produced as a result of consultation between the ABVA and the RCVS Head of Legal Services (Standards) and has been approved by the RCVS (date: 26^th February 2024).   We would advise any ABVA members who have further questions surrounding this to contact the RCVS (Standards) for clarification on your individual situation.  

• Are veterinary acupuncturists required to provide 24-hour ‘care’ for acupuncture patients? If so, what does this entail? Telephone support, the ability to visit and examine, the ability and equipment to provide first aid/emergency stabilisation/pain relief/euthanasia? 

Where patients are treated only by acupuncture and there is no prospect that POM-Vs will be prescribed, the obligation to provide 24/7 in person follow-up care under the new guidance is not triggered. 

However, as clinical services are being offered there is still an obligation to provide 24-hour emergency first aid and pain relief under the existing OOH guidance (this was the case before the changes to the guidance and continues to be the case now).  This 24-hour provision has a limited extent if the veterinary surgeon falls within the definition of a Limited Service Provider. (LSP). More on LSPs below.

• Most veterinary acupuncturists are not registered practices (RVPPs) on the RCVS register – does this now need to be the case as they are Limited Service Providers?

Under the new guidance, a veterinary surgeon is an LSP if they offer no more than one service to their clients. An acupuncture only clinic would fall within the scope of ‘one service’. 

The guidance currently states that registration as an RVPP is required to be an LSP. However, in consultation with the ABVA, the RCVS recognises that in the case of an acupuncture-only – where POM-Vs are not used or stored – registration is not legally required. The RCVS recognises that it would be disproportionate to require it.  The wording of the guidance will be revisited as part of the next review. 

To confirm, a veterinary surgeon offering acupuncture may operate as an LSP without RVPP registration so long as this is the only service offered and it supplies no medicinal products that trigger the legal requirement to register as an RVPP.

• Do veterinary acupuncturists need to identify themselves to the RCVS as LSPs? 

There is no need for any veterinary surgeon to identify themselves to us as an LSP. As long as only one service is offered, it is up to the individual veterinary surgeon to decide what proportionate 24/7 first aid and pain relief looks like

• How could we define emergency cover ‘proportionate to the services offered’ for these vets? 

That is a matter of veterinary judgement based on the issues that may foreseeably arise from carrying out acupuncture.

• Are acupuncturists able to insist that the primary vet is contacted by the client, in the first instance, in the case of emergency, regardless of whether the owner perceives the issue to be as a direct result of the acupuncture?

The ABVA recommendation would be:

 to include this instruction for clients on consent forms AND 

to request that the referring veterinary surgeon (via a completed referral form) acknowledges that they are still responsible for being the first point of contact in an emergency. 

This would be acceptable if the acupuncturist is a LSP as they would only be obliged to provide 24-hour emergency first aid and pain relief that is proportionate to the service they offer during the day.