Humane Society Veterinary Medical Association (October 21, 2021)

Summary

A letter dated October 21, 2021 from the Humane Society Veterinary Medical Association (HSVMA) to the Honorable Julie Alexander, Chair of the House Agriculture Committee, and the Honorable Jim Lilly, Chair of the House Rules and Competitiveness Committee. On behalf of more than 250 Michigan veterinary professional members, it opposes a House bill on veterinary telemedicine unless it is amended to align the term "sufficient knowledge of the patient" with rules adopted by the Michigan Board of Veterinary Medicine on April 15, 2021. The letter estimates that more than 630,000 pets live with families in poverty across Michigan. It recommends safeguards such as a real-time video exchange, client consent and the option of an in-person visit.

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HUMANE SOCIETY

VETERINARY MEDICAL

ASSOCIATION.

BOARD OF DIRECTORS

Michael Blackwell, DVM, MPH
Knoxville, TN

Gary Block, DVM, MS, DACVIM
East Greenwich, Ri

Barry Kellogg, VMD

North Port, Fi.

Barry Kipperman, DVM,
DACVIM, MSc

San Ramon, CA

Paula Kislak, DVM

Santa Barbara, CA

Nicole Paquette, JD
Washington, DC

Gwendy Reyes-Ill, DVM
Milwaukie, OR

Meredith Rives, DVM
Evanston, iL

LEADERSHIP COUNCIL

Holly Cheever, DVM
Voorheesville, NY

Nicholas Dedman, BVMS5,
DACVB, DACVAA
Grafton, MA

Anne Fawcett, BSc,
MvVetStud GradCertEd,
MANZCVS, DipECAWBM
NSW, Australia

Brenda Forsythe, MD, PhD,
DVM, CAAB

Guadalupe, CA

Zarah Hedge, DVM, MPH,
DACVPM, DABVP

San Diego, CA

Joann Lindenmayer, DVM, MPH
North Grafton, MA

Sheila (D’Arpino) Segurson,
DVM, DACVB

Pleasanton, CA

Erin Spencer, M.Ed,

CVT, VTS (ECO)

Derry, NH

October 21, 2021

Honorable Julie Alexander, Chair
House Agriculture Committee
N-998 House Office Building

PO BOX 30014

Lansing, MI 48909-7514

Honorable Jim Lilly, Chair

House Rules and Competitiveness Committee
374 Capitol Building

PO BOX 30014

Lansing, Ml 48909-751

RE: HSVMA VETERINARY OPPOSITION to House Bill 4932, UNLESS AMENDED
Dear Chairs Alexander and Lilly:

On behalf of our more than 250 Michigan veterinary professional members, the
Humane Society Veterinary Medical Association (HSVMA) is writing to express
our opposition to House Bill 4912 unless amended. More specifically, we are
requesting the inclusion of an amendment aligning the term “sufficient
knowledge of the patient” with the rules adopted by the Michigan Board of
Veterinary Medicine on April 15, 2021.

House Bill 4912, as written, Section 18818{1)(b) stands in direct conflict with the
landmark rules (R 338.4901A) issued in April 2021 by the Licensing and
Regulatory Affairs Board of Veterinary Medicine regarding telehealth services.
Prior to the rules being adopted in April, the Michigan Veterinary Medical
Association had reported the success that some veterinary practices had had in
offering telehealth services, which prompted the Board to update the code and
clarify the rules relating to the use of telemedicine to care for Michigan pets.
Rolling back this important option may cause unnecessary harm to companion
animals across the state.

We estimate that at minimum more than 630,000 pets are living with their
families in poverty across Michigan—pets that could benefit greatly from access
to quality veterinary care. This immense number accounts only for those living
at or below the federal poverty line; it doesn’t account for the thousands more
hovering just above that line and still facing financial challenges. Additionally,
our country is experiencing a widespread veterinary professional shortage.

700 Professional Drive, Gaithersburg, MD 20879 | P.O. Box 208, Davis, CA 95617
MD: t 301-548-7771 f 301-548-7726 | CA: 530-759-8106 530-759-8116
hsvma.org info@hsvmaorg
HUMANE SOCIETY
VETERINARY MEDICAL
ASSOCIATION.

Together, limited access and sparse availability of appointments has intensified an already
difficult situation for people living in rural areas or in underserved communities without access
to personal transportation.

Removing barriers to veterinary services will help create equity in access to pet resources and
information for people living in underserved, and often overlooked, communities. With the
average cost of a preventative veterinary care visit estimated at approximately $250 and
emergency visits often running upwards of $500, it is no surprise that families struggling
financially often have difficulty accessing pet medical services, especially if their pet becomes
sick or injured unexpectedly. By expanding access to telemedicine, more families will be able
to obtain important veterinary services, particularly families living in communities, both rural
and urban, where there are no neighborhood veterinary hospitals or clinics.

Veterinarians have undergone rigorous education and training, and we should be trusted to
exercise good judgement in our practice, including in the utilization of telemedicine.
Telemedicine and the use of electronically transmitted images and medical records can help
increase access to veterinary services and allow for more flexibility in treating patients,
especially those whose caregivers may have limited mobility or other transportation
challenges. While we acknowledge that a legitimate need exists for routine veterinary
consultation and treatment of non-emergent pet medical issues in person, allowing virtual care
means that more pet owners, no matter their circumstances, will be able to access vital
services and help assure the health and wellbeing of their companion animals.

Given these many benefits, we support allowing veterinarians to use their professional
judgement to determine whether a patient can be diagnosed and/or treated through
telemedicine. However, we also recommend the committee considering requiring safeguards
for establishing a VCPR through electronic means, including:

1. Require the veterinarian to establish a relationship with the client/patient via real-time

video (visual) exchange.

2. Require the veterinarian to give clients the option to alternatively have an in-person
visit.
Require the veterinarian to obtain written consent from clients to use telemedicine.
Require the clinic to be available for in-person follow up if needed.
Establish controls/restrictions on writing prescriptions for controlled substances.
Maintain or establish physical examination/in-person veterinary visitation
requirements for commercial enterprises, including any entity operating as a Large-
scale Dog Breeding Kennel under Michigan Penal Code Act 287 and Regulation 151.

aus w

700 Professional Drive, Gaithersburg, MD 20879 | P.O. Box 208, Davis, CA 95617
MO: t 301-548-7771 f 301-548-7726 | CA:t 530-759-8106 f 530-759-8116
hsvma.org info@hsyma.org
hsWma

HUMANE SOCIETY
VETERINARY MEDICAL
ASSOCIATION.

These provisions will help ensure that all parties are protected, and that their best interests are
considered. Most importantly, it will be left to veterinarians’ discretion as to whether or not
we choose to use telemedicine as a tool to reach more people and pets. We are not
advocating for any mandate by the legislature or the Board to require veterinarians to offer
telemedicine services.

We thank the committee for your attention to this important issue and urge the committee to
consider amending H.B. 4912 to reflect the language promulgated by the Michigan Board of
Veterinary Medicine on April 15, 2021, regarding the definition of ‘sufficient knowledge of the
patient.’ There are a variety of reasons why increasing the flexibility of telehealth services can
expand critical care to people and their pets, and the outcomes have proven to be lifesaving
without causing undue harm to animal patients. These changes will bring greater access to
veterinary care to Michigan pet owners for their companion animals and allow veterinarians to
better serve Michigan communities.

Sincerely,

Barbara Hodges, DVM, MBA
HSVMA Program Director, Advocacy and Outreach

cc. Members of the House Agriculture Committee and House Rules and Competitiveness
Committee

700 Professional Drive, Gaithersburg, MD 20879 | P.O. Box 208, Davis, CA 95617
MD: t 301-548-7771 £ 301-548-7726 | CA:t 530-759-8106 530-759-8116
hsymaorg info@hsvma.org


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