Mobile veterinary care continues to offer California veterinarians new ways to serve patients, from fully equipped mobile clinics to practices that bring veterinary services directly into the communities they serve. However, mobility does not mean fewer regulatory obligations.
The California Veterinary Medical Board (VMB) has established minimum standards for mobile veterinary premises and published a Mobile Veterinary Premises Minimum Standards Self-Evaluation Checklist to help licensee managers and veterinary office managers evaluate their compliance.
For veterinarians operating or considering a mobile practice, understanding these requirements is an important part of protecting both the practice and its patients.
What Is Considered a Mobile Veterinary Premises?
Under California regulations, a mobile veterinary premises is generally a mobile unit or vehicle within or from which veterinary services are provided.
Importantly, mobile units and vehicles may be exempt from independent registration with the VMB when they operate from a building or facility that serves as the managing licensee’s principal place of business, that building is properly registered with the Board, and its registration identifies and declares the use of the mobile unit or vehicle.
The distinction matters. Veterinarians should understand how their particular practice model is classified and which registration and operational requirements apply.
The VMB Can Inspect Mobile Veterinary Premises
Mobile veterinary practices are subject to oversight by the VMB.
The Board has authority to inspect premises where veterinary medicine, dentistry, or surgery is practiced. Medical records, equipment, and drugs used or possessed for purposes of the veterinary practice may also be subject to inspection.
The VMB maintains a regular inspection program that can include random, unannounced inspections.
In other words, compliance should not begin when an inspection notice arrives. Mobile practices should be prepared to demonstrate compliance as part of their everyday operations.
A New Focus on Client Disclosures
One particularly important requirement for mobile veterinary practices involves information provided to clients.
A mobile veterinary premises must provide a written disclosure in at least 18-point type when veterinary services are first provided. That disclosure must include:
- A telephone number clients can use for questions, concerns, or emergency needs;
- The mobile veterinary premises’ hours of operation; and
- The name, telephone number, and location of a veterinary premises where after-hours emergency care may be available.
If that information changes, an updated disclosure must be provided the next time veterinary services are rendered.
Practices should review their intake materials, client handouts, and other communications to confirm that these disclosures are both present and formatted appropriately.
Compliance Goes Far Beyond the Vehicle
The VMB’s self-evaluation checklist demonstrates just how broad mobile-practice compliance can be.
Depending on the services offered, the Board’s checklist addresses areas including sanitation, lighting, examination areas, fire precautions, hot and cold water, temperature and ventilation, emergency drugs and equipment, laboratory and radiological services, waste disposal, animal housing, surgery, anesthesia, controlled substances, drug dispensing, CURES reporting, DEA registration, recordkeeping, and practice management.
For practices performing surgical procedures, for example, additional requirements concerning clean and aseptic surgery, equipment sterilization, surgical packs, sanitary attire, anesthesia equipment, and patient monitoring may apply.
The takeaway is simple: a mobile practice may look very different from a traditional veterinary hospital, but many of the same professional and patient-safety obligations remain.
Controlled Substances Require Particular Attention
Controlled substances can create significant compliance exposure for veterinary practices, and mobile practices are no exception.
The VMB checklist specifically addresses drug security controls, controlled-substance records, dispensing requirements, veterinary assistants’ handling of controlled substances, CURES reporting, and current DEA registration.
Mobile practices should consider whether their policies account for the realities of transporting and securing medications outside a traditional brick-and-mortar environment.
Written procedures, accurate records, appropriate security, and staff training can all become especially important when drugs routinely travel with the practice.
Don’t Overlook Staff Identification and Practice Management
Compliance also extends to the people working within the mobile practice.
The VMB checklist addresses identification requirements for registered veterinary technicians, veterinary assistants, and veterinary assistant controlled substance permit holders when they are working in areas accessible to the public.
The checklist also addresses responsibilities involving the Licensee Manager, veterinary reference resources, and medical recordkeeping.
These requirements reinforce an important point: regulatory compliance is not solely the responsibility of the veterinarian performing treatment. A compliant practice requires appropriate systems and staff-wide awareness.
Use the Checklist Before an Inspector Does
Perhaps the most useful way to approach the VMB’s checklist is exactly as its name suggests: as a self-evaluation tool.
The Board encourages veterinary practices to involve their entire staff in becoming familiar with and maintaining minimum standards.
Rather than viewing the checklist solely as preparation for an inspection, practices can use it to identify potential gaps before they become regulatory problems.
Consider periodically reviewing your mobile operation from an inspector’s perspective. Are required disclosures being provided? Are medications properly secured and documented? Are medical records complete? Is equipment maintained appropriately? Do employees understand the rules that apply to their roles?
Small compliance issues are often easier to address proactively than after they appear on an inspection report.
What Happens If an Inspection Identifies a Deficiency?
During an inspection, a VMB inspector or Special Investigator completes an inspection report and reviews the findings with the Licensee Manager or designated representative. When deficiencies are identified, the inspection process can include identifying required corrections and specifying what the practice must submit to demonstrate compliance. Depending on the issue, that might include photographs, receipts, written explanations, photocopies, or other documentation.
Veterinary professionals should take inspection findings seriously and carefully evaluate both the underlying deficiency and the appropriate response.
Compliance Is an Ongoing Responsibility
California’s regulatory framework for veterinary medicine continues to evolve, and the growth of alternative and mobile models of care creates additional compliance considerations for veterinary professionals.
For veterinarians operating mobile practices, the VMB’s self-evaluation checklist provides a valuable roadmap, but a checklist cannot account for every circumstance a particular practice may face.
If you have questions about California veterinary licensing requirements, an upcoming or completed VMB inspection, an alleged deficiency, or another professional licensing matter, Simas & Associates, Ltd. can help you understand your obligations and evaluate the appropriate next steps.