Frequently Asked Questions
Check out some of the most frequently asked questions we receive from veterinarians and the pet-owning public.
Below are frequently asked questions that the MVMA office staff has received. Please contact the office if you have a question that isn't mentioned here and we'd be happy to help you (or point you in the right direction)!
Please note: The MVMA does NOT offer legal advice. For specific questions related to the practice of veterinary medicine in the state of Massachusetts, contact the Board of Registration in Veterinary Medicine at vetmedboard@state.ma.us
Click on one of the below topics to jump through the FAQ page or simply scroll through for answers to all questions.
- General Practice
- Medical Records
- Licenses
- Continuing Education
- Prescriptions
- Controlled Substances
- Rabies
- Mobile and Relief Veterinarians
- Complementary Medicine
General Practice
Q: How can I dispose of animal remains if an owner does not claim them?
A: You must give notice of the intention to dispose of remains of an abandoned animal to the owner's last known address by registered or certified mail, return receipt requested. You must allow a period of 10 days to elapse after the receipt if returned before disposing of the animal (General Laws/Part I/Title XVI/Chapter 112/Section 59A).
Q: My client brought in wildlife they intend to keep as a pet. How do I know if it's legal?
A: There are very specific animals that can be kept as pets. Check MDAR's list HERE.
Q: I work at a multi-doctor practice. Is the VCPR I establish with a client restricted just to me?
A: The VCPR extends to all associates at a practice. CLICK HERE for the citation from the Board.
Q: Do you have to be a licensed veterinarian to own a practice in Massachusetts?
A: In Massachusetts, non-veterinarians can own practices but it depends on the legal business structure of a veterinary practice. Professional corporations under MGL 156A must be owned by licensed professionals. Other forms of business, such as a sole proprietorship or a partnership, do not require that owners be licensed veterinarians.
Per the Board of Registration in Veterinary Medicine guidelines on practice - 256 CMR 5.06 - "In those facilities/practices which are not owned by a licensed veterinarian, the owner(s) shall appoint a licensed veterinarian as the Veterinary Medical Director."
If in doubt, we advise you seek the opinion of an attorney versed in corporate law in the Commonwealth.
Q: How do I know which materials are considered hazardous and how to dispose of them if they are?
A: Discarded chemicals, off-specificiation products, and liquid or solid residues are regulated as "hazardous waste" if they are: corrosive (pH of less than 2 or 12.5 and greater), ignitable (flash point of 140 F), reactive with water or acid, or toxic as determined by a special laboratory test. Mass Department of Environmental Protection (MassDEP) produced a flyer to help you HERE.
Q: I have out-of-date reference books that I'd hate to throw away. Where can I donate them?
A: Project V.E.T.S. may be interested in the books, though the vet is responsible for shipping. All costs are tax-deductible, according to their website. AVMA also has a website listing organizations and individuals across the country who may collect these. CLICK HERE to access that list. Recycling is also an option.
Q: Can I vaccinate a pet without owner consent?
A: No. Per the Board of Registration in Veterinary Medicine, you must obtain consent from the owner unless otherwise exempted by the regulations. Note that vaccination against rabies is required for dogs, cats, and ferrets unless the veterinarian determines there is a valid reason not to vaccinate. Massachusetts law provides for an exemption for a specified medical condition when the veterinarian deems the rabies vaccination to be potentially harmful to the animal’s health. CLICK HERE for more information on the requirements for rabies vaccine.
Q: What are the guidelines related to telemedicine in Massachusetts?
A: The Board of Registration does permit the use of telemedicine when appropriate only after an in-person VCPR is first established. Read the full policy HERE.
Q: What's the deal with interstate health certificates?
A: MDAR stopped using APHIS 7001 in 2019 and created the small animal health certificate. All accredited veterinarians are highly encouraged to move to electronic CVI services. The two most common are Global Vet Link and CVI Central. CLICK HERE for more info from USDA for accredited veterinarians.
Q: Are malpractice payouts from PLIT to owners reportable to the board?
A: Licensees are required to notify the Board of any criminal convictions or discipline taken against the licensee or a voluntary surrender of a veterinary license or any discipline regarding the licensee’s DEA certificate or DPH registration. The Board’s regulations require that LLCs and LLPs which own or operate a veterinary facility or business providing veterinary services maintain professional liability insurance. Per 256 CMR 10.01(6), if the insurance coverage of the LLC or LLP is canceled or interrupted for some reason, the LLC or LLP must notify the Board within 5 business days. (Source: Correspondence with the Board of Registration in August 2023).
Q: Can I refuse to treat an animal that comes to my clinic in an emergency?
A: A licensee shall NOT refuse to provide first aid or advice for an animal already on the premises in an emergency situation, or to help identify an alternate source of veterinary medical care. (See 256 CMR 7.00 Code of Professional Conduct). Furthermore, licensees shall conform to currently-accepted professional and scientific standards in the profession such as but not limited to the AVMA Principles, which state that "In emergencies, veterinarians have an ethical responsibility to provide essential services for animals when necessary to save lives or relieve suffering."
Q: Do I need to directly supervise my assistant while he or she administers a microchip?
A: The MA Board of Registration in Veterinary Medicine discussed what level of autonomy a veterinary technician or other type of assistant is required for microchip implantation in animal shelters. The Board stated that such individual working in the same facility as the licensed veterinarian may perform this task as long as it is within the individual’s experience and training, the veterinarian has prescribed administration of a microchip, and the veterinarian is available. Citation is available in a copy of the meeting minutes from February 10, 2022 HERE.
Q: Do I need to report any specific diseases.
A: Massachusetts has a list of reportable diseases through the Department of Agriculture and State Vet's office. CLICK HERE to access the list and how to report.
Medical Records
Q: How long is it required to keep medical records, including x-rays?
A: Four (4) years after the last contact with the animal, even if the animal is deceased. Read more HERE.
Q: Does the Board have specific regulations or guidelines related to electronic medical records (EMR)?
A: No, The Board’s regulations regarding medical records are applicable to any medical record created and/or maintained by a licensed veterinarian. There may be some additional information in the Board’s policies but the Board does not otherwise have guidance specific to electronic medical records.
Q: Are veterinarians allowed to hold an animal or withhold medical records if there is an outstanding open amount owed to the practice?
A: No, a veterinarian may not hold an animal even if there is money owed. Regarding medical records, upon the request of the owner, a licensee shall provide copies of medical records and radiographs to the owner of an animal or another veterinarian. A reasonable fee may be charged for the cost of such copies. Read the full text HERE.
Q: Can I release medical records without an owner's consent?
A: Unless you suspect abuse/cruelty and are going to report it to the authorities or if there is a legal order demanding the records, you should treat the records as confidential. See 7:01(g) under the Board of Registration's Rules and Regulations - Code of Professional Conduct HERE.
Licenses
Q: I have a new graduate who has passed boards but is awaiting their license. Can they see cases under my license if I oversee all the cases?
A: No, if they are not licensed (AKA if they are unlicensed) to practice they cannot practice as a veterinarian under someone else's license. The scope of practice for veterinarians is outlined in the statute. If their application is pending they are unlicensed.
Q: I just received my license in November. Do I still have to renew for the March 1 cycle for the full fee even though I just paid for my licensure?
A: Yes, unfortunately, all must pay to renew, even if just recently licensed. (correspondence with the Board of Registration staff 2023 November 29).
Q: Where should I display my MCSR/DEA licenses?
A: These should not be displayed and the information is private. Please keep in a binder along with their records or in the medication storage room (Source: email on February 14, 2023 from Mallory Gentile, MCSR)
Q: Is a radiation license required for new x-ray machines?
A: Yes, you do need to obtain a license. What needs to happen is you will have to get a Shielding Design Package sent to you (if you call the RCP they will send it out). This package will let you know what needs to be submitted, which includes how the x-ray machine will be built in the facility. An inspection will then be done to make sure everything is safe and the machine was built according to what was submitted. There is also a fee involved in this process. (Learn more on the Mass Radiation Control website or contact 617-242-3053 (RadiationControl@massmail.state.ma.us).
Q: I received an e-mail from the DEA saying I need to complete opioid continuing education to renew my DEA license. Is this true?
A: Federal law specifically exempts veterinarians from this requirement. You do NOT need to complete any opioid education to renew your DEA license as a veterinarian. CLICK HERE to review that letter.
Continuing Education
Q: How many hours of CE may I obtain online?
A: Licensed Veterinarians are required to complete a minimum of 15 continuing education credits during the prior calendar year to renew a license. All credits can be obtained online but at least 9 must be "interactive" (instruction occurs live in real time and interaction occurs between the instructor and licensee). 6 online credits can be "non-interactive" (pre-recorded for home study). Read more HERE.
Q: Do I have any options if I am unable to complete the annual CE requirements needed to renew my license?
A: The Board may, at its discretion, fully waive or extend the deadline of the continuing education requirements for any licensee who, for reasons of health, disability, out of state military service, or undue hardship, cannot meet the requirements. Licensees shall submit such requests to the Board in writing. The Board can make exceptions/grant extensions under certain circumstances. Contact them directly to see if you are eligible: Phone 617-701-8723; Email vetmedboard@mass.gov. Read more HERE.
Q: Do new licensees/new graduates have to complete all CE requirements?
A: Per the Board of Registration in Veterinary Medicine, new licensees are exempt from CE requirements for the license period that includes the date of initial licensure, unless the new license was obtained by reciprocity. The Board does encourage new licensees to voluntarily take CE during the first year, though. HERE is the full citation.
Prescriptions
Q: What information is required to be on prescription labels?
A: Read guidelines from the Board of Registration in Veterinary Medicine HERE. You can purchase tamper-resistant pads through Curry Printing. Click HERE to go to their order portal.
Q: Is a client allowed to take a prescription to whatever pharmacy they prefer?
A: Yes, at the request of a client a veterinarian shall provide prescription to the pharmacy of choice. A licensee shall provide prescription information to an off-site pharmacy or a written prescription to the client if requested. The prescription may be written or transmitted by any electronic means at the discretion of the prescribing licensee and in accordance with M.G.L. c. 94C. Read more HERE.
Q: Are prescription medications and prescription pet food exempt from MA sales tax?
A: No. According to the MA Department of Revenue in a call in July 2021, only prescriptions for humans are tax-exempt. CLICK HERE (and see section 6L) for the citation from the Department of Revenue. Because there is no mention of animals, it is to be assumed that this references humans only. Tax authorities confirmed that everything but veterinary services are taxed. CLICK HERE for the AVMA's chart of state taxes imposed on veterinary sales and services.
Q: Am I required to provide electronic prescriptions? Some pharmacies are telling me I MUST use electronic prescribing.
A: No. Veterinarians are exempt from e-prescribing regulations. CLICK HERE for the exemption language (page 2 under Exceptions):
- Prescriptions issued by veterinarians. This exception is available to all licensed veterinarians with a Massachusetts Controlled Substance Registration (MCSR).
Q: Am I allowed to charge a fee to write a hard copy prescription for a client?
A: There is no federal law preventing your veterinarian from charging you a fee for their services and time invested in writing a prescription. Some veterinarians charge a nominal fee for writing prescriptions, but others don't. Individual states might have specific guidance for veterinarians on prescription fees. Read more HERE.
Q: Can veterinary clinics fill prescriptions for other veterinarians to use?
A: No, a veterinary clinic cannot act as a drug supplier for other veterinarians. (Source: Leija Meadows, Board Administration)
Q: What are the current regulations regarding prescribing Gabapentin?
A: While the FDA has NOT changed the schedule of Gabapentin, the Commonwealth of Massachusetts has added it to the list of drugs that must be reported to the Prescription Monitoring Program (veterinarians are exempt from the PMP in Massachusetts).
Q: I had a pharmacy tell me that they have to have a written prescription for Gabapentin because it is a controlled drug in MA.
Q: Pharmacies are requesting a DEA number for Schedule VI (non-controlled drugs) that don't otherwise require DEA information. What should I do?
A: If a DEA number is requested when it is not necessary, the veterinarian should have the pharmacy contact their IT Department/Help Desk to walk them through the data entry process without it. The Board of Pharmacy has sent many reminders out to pharmacies and can re-address with the corporate entities such as CVS and Walgreens. Citation: Board of Pharmacy email correspondence 2022 April 14.
Q: How can I dispose of old medications?
A: AVMA has some good resources on this page (geared toward pet owners but could be used by professionals, too).
- Search online drug disposal locators (e.g., AWARxE, Dispose My Meds, and others by entering "find drug disposal location" or variation of that into your web browser) to find authorized pharmaceutical disposal sites near you.
- Contact your local environmental authority, department of public health, or Drug Enforcement Administration (DEA).
- If there is not an authorized pharmaceutical collection program available in your area, visit Unwantedmeds.org to learn how you can get one started
Q: What should I do if I suspect my prescription pad has been lost of stolen?
A: In a conversation with the DEA diversion department on January 16, 2024, they provided the following suggestions:
* Report suspected theft to MCSR and the DEA.
* Keep records of EVERYTHING (including your theft report to the authorities)/
* Check the Prescription Monitoring Program (PMP). Even though veterinarians aren't required to participate in PMP, you can still create an account and view all prescriptions filed under your DEA # reported by external pharmacies. If anything looks suspicious, alert the DEA and state.
Compounded Medications:
Mass General Law has a section pertaining to compounding medications for animals HERE.
The AVMA has a great list of FAQ on their website HERE.
You can also confer with the Board of Registration in Veterinary Medicine HERE or the Massachusetts Board of Registration in Pharmacy HERE.
The FDA also has resources for veterinarians:
General information about compounding for animals
For Veterinarians: Prescribing Animal Drugs Compounded from Bulk Drug Substances
Controlled Substances
Q: Can I keep a digital log of controlled substances in MA or does it have to be on paper?
A: Computerized logs are acceptable but you must be sure to do periodic spot checks for accuracy. You must be able to pull reports identifying date, client, patient, drug, and amount in the event you are inspected. The balance on hand need not be on the report but must be easily available for verification. The Massachusetts Board of Registration in Veterinary Medicine does not have additional requirements for digital logs and directs you to confer with Federal DEA regulations. See more in the article Keeping Controlled Drugs Under Control from VIN.
Q: How does the MCSR define "principal place of business"? If a veterinarian works very part time (one day per week) at the practice, can they use the practice address for their MCSR registration? How about if they work one day per month?
A: Per our regulations, the address provided for your MCSR must be a place where you conduct business, specifically, prescriptive practice. See, 105 CMR 700.004(F).
Q: Do you have a list of registered reverse distributors through the DEA?
A: Yes, CLICK HERE for a current list (provided to MVMA staff via email on January 12, 2023).
Q: Can you tell me more about what I need to dispense controlled substances?
A: In MA all substances are considered controlled. Veterinarians must register with MCSR before registering with the DEA. Each individual vet in MA must have his/her own MCSR and DEA registration for schedule II - VI, as the state doesn't register animal/veterinary practices/hospitals. Hospital DEA registration only applies to human medicine. Prescriptions for schedule II - V drugs require a DEA number but not for schedule VI medications. Schedule VI prescriptions must have the MCSR number provided.
Q: What is a Schedule VI drug?
A: Schedule VI drugs consist of all prescription drugs which are not included in Schedules II-V. This is a special Massachusetts schedule (MGL 94C, 105 CMR 720.002). MGL 94C Section 3 states: “SCHEDULE VI.— (A) The substance is a prescription drug; and (B) Said prescription drug has not been included in Schedules I through V.” In short, this states that Schedule VI substances are any “normal” prescriptions that are not considered controlled substances in other states. Some examples of drugs that would fit into Schedule VI are antibiotics and “maintenance meds,” such as penicillin, azithromycin, metoprolol, simvastatin, lisinopril, gabapentin, levothyroxine, metformin, etc. Read more from MCSR HERE.
Q: How should I store substances that are not federally controlled?
A: If a drug is not federally controlled it does not need to be secured in the same way as federally controlled drugs. We do recommend it is in a locked cabinet and not accessed by unauthorized personnel, same as any drug whether federally controlled or not. We also do suggest you inventory anything that is not federally controlled to prevent loss, theft, diversion etc. This will also help with knowing when something is recalled you know the lot number, amount dispensed etc. (Source: Correspondence with MCSR on March 1, 2024).
Q: What about cannabis and CBD products?
A: CBD/THC cannot be marketed for animals as dietary supplements. There are currently no approved animal drugs that contain cannabis. FDA has, however, approved one cannabis-derived and three cannabis-related human drug products. Examples of what FDA has indicated it considers to be therapeutic claims associated with the marketing of CBD products for animals include:
- "...CBD and other chemicals found in cannabis have an antitumor effect and could be used to improve standard treatments..."
- "Due to its anti-inflammatory effect, cannabinoids may provide relief of joint pain and swelling, and decrease joint destruction and disease progression..."
- "...how [product] may help your dog or cat...reduce cancer-associated symptoms, aid in decreasing severity of dementia, reduce bronchial spasm in asthmatics..."
- "...for all pets, but especially for those with arthritis, allergies, anxiety or behavior issues, compromised immune systems, diabetes, digestive issues, nausea, chronic pain, cancer, seizures..."
Here are additional cannabis-related resources:
AVMA Cannabis use and pets - HERE
AVMA Cannabis regulatory status FAQ (Members Only) - HERE
AVMA Cannabis as Drug, Food, or Supplement - HERE
USDA Establishment of Domestic Hemp Production Program - HERE
Article from MassVet News (2020) on CBD and Pets - HERE
Q: If controlled substances are going to be stored at more than one location, do you have to have two separate DEA licenses?
A: Yes,if you're ordering, storing, and dispensing at different facilities you need a license at each facility. (Source: Phone conversation with DEA Drug Diversion representative on June 2, 2021).
Rabies
MDAR has a rabies coordinator: Ashley Kraft, 617-626-1810
Q: Are there exemptions for an animal to be vaccinated?
A: (d) A licensing authority may grant an exemption from this section for a dog, cat or ferret that:
(i) the local board of health has declared exempt from the rabies vaccination requirement upon presentation of a veterinarian’s certificate stating that because of an infirmity, other physical condition or regimen of therapy, such inoculation is considered inadvisable for a specified period of time for such reasons; (ii) is in transit; or (iii) was brought into the commonwealth temporarily for the sole purpose of display in a show or for exhibition.
(e) This section shall not apply to a dog, cat or ferret housed in a research institution.
The legitimate reasons for exemption relate to allergic reactions resulting in anaphylaxis, or some form of immune mediated disease. Mild reactions like rashes do not outweigh the public health significance of leaving an animal susceptible. Read more HERE.
Q: Can you clarify the 1 vs 3-year vaccines?
A: The former “primary series” regulation that required the first two rabies vaccines to be between 9 and 12 months apart was eliminated in 2016. All manufacturers label vaccines to say the animal’s first shot is only good for one year (see 330 CMR 10.02 (2)). Remember the only proof of a previous rabies vaccine is a vaccine certificate so the veterinarian will need to validate ( USDA vaccine, appropriate age according to manufacturer, etc) an initial/ prior vaccine. Any subsequent shot, regardless of how much time has elapsed /overdue (whether 1 month or 5 years), can be good for 3 years as long as the veterinarian is using a licensed 3-year vaccine ( see attached 330 CMR 10.02 (3)) HERE.
Q: Can anyone other than a licensed veterinarian administer a rabies vaccination?
A: No, only a licensed veterinary can administer a rabies vaccination. Other vaccines can be given under the immediate supervision of a licensed veterinarian. Technically, a veterinarian may only administer rabies to an animal after a VCPR is established but because it is a public health issue the rules are a little more lenient. Read more HERE.
The vaccinating veterinarian must also sign the certificate. Electronic or stamp is acceptable. See 10.03 HERE.
Q: What do I do about a bite of unknown origin?
A: MDAR has a form to be filled out for a bite of unknown origin.
Q: Our order for rabies has been delayed by the distributor. What should we do?
A: If the vaccinating veterinarian does not have rabies tags to issue at the time of vaccination as required by law per MGL 140 section 145 b (b) then it is best to vaccinate the pet now and catch up with the rabies tag at a later time. We recommend the veterinarian provide a statement on letterhead to those receiving vaccines without tags. When the tags do come in, the veterinarian should take all necessary measures to follow up with the clients by providing rabies tags and a valid rabies certificate, including tag number, in accordance with MGL CH 140 section 145B (a). Source: Ashley Kraft, Rabies Program Coordinator with Mass Department of Agricultural Resources.
Q: Who is responsible for sending a rabies vaccination certificate to a city or town?
A: The vaccinating veterinarian must file a copy of the certificate within 30 days with the clerk of the city or town where the dog, cat or ferret resides, one copy is to be provided to the owner of the animal, and one shall be retained by the vaccinating veterinarian. CLICK HERE for more information.
Even if late, you should still send the certificates. If certificates have never been sent then please submit the most recent rabies vaccine certificate for all of the patients. Moving forward, this should become a regular practice to submit the rabies certificates within 30 days to the town clerks in the municipality the owner resides.
Q: Where can I get rabies vaccines and titer testing for me and my staff?
A: AVMA has resources HERE.
Mobile and Relief Veterinarians
Q: I am a relief veterinarian and as such work at many practices. Am I required to carry a framed copy of my license with me and display it while I am working at each individual practice?
A: (1) Each veterinarian engaged in practice shall have all current required licenses, certificates and permits on display. This includes a copy of the license certificate to practice veterinary medicine in the Commonwealth, and any applicable certifications by AVMA specialty boards. (2) Each licensee practicing at a location where the display of certificates is not possible or practical shall have on his/her person a license card as proof that his/her license is current. Read more HERE.
Q: I employ a relief veterinarian in my practice to fill in for staff who are out on vacation or other types of extended leave. Do I have to pay them as an employee, or are they considered an independent contractor?
A: In Massachusetts, most people who work or provide services are considered employees under the law. There is a 3-part test for an employer who wants to treat someone as an independent contractor whereby you have to show that the work: 1) is done without the direction and control of the employer; and 2) is performed outside the usual course of the employer's business; and 3) is done by someone who has their own, independent business or trade doing that kind of work. Relief veterinarians generally perform the same work in the normal course of business as would the person they are filling in for, and so generally speaking, should be treated as an employee under the law. Read more HERE.
Q: I'm interested in becoming a mobile veterinarian. Can you tell me what I need to know?
A: First and foremost, we would recommend you contact the Board of Registration in Veterinary Medicine with specific questions about practice and refer to 256 CMR5 found HERE. That being said, here are some regulations directly from the Board that relate to mobile practice:
5.06: Practice Standards and Facilities (1) Veterinary Medical Director. All Veterinary Facilities, including but not limited to, Emergency Service Veterinary Facilities, and Mobile Clinics are required to appoint a Veterinary Medical Director, as defined in 256 CMR 2.01: Veterinary Medical Director.
(5) Requirements of Mobile Practice. A mobile practice shall have the ability and equipment to provide care at a level commensurate with the specific veterinary medical services it is providing.
3.06: License Display (2) Each licensee practicing at a location where the display of certificates is not possible or practical shall have on his or her person a license card as proof that his or her license is current.
Q: If I work out of two clinics, go on a house call with controlled substances ordered from one clinic, and finish my day closer to the other clinic, can I bring the controlled substances back to the closer clinic?
A: No, drugs must be returned to the facility from which they originated.
Complementary Medicine
Q: What is the protocol for chiropractic practice of non-human vertebrates?
A: It is not illegal for human chiropractor to administer care, but there are certain guidelines.
1) There must be a written referral/direct authorization from the animal's vet and;
2) The appointment cannot take place where the chiropractor works on humans.
Read more HERE.
Q: What are the guidelines for complementary and alternative veterinary medicine?
A: Read the guidelines HERE.