Policy Guideline – Policy No. 13-01


From:       Board of Registration of Veterinary Medicine

Re:            Board Policy Guidelines: Vaccination Clinics

Date:         November 14th, 2013

The Board of Registration of Veterinary Medicine (“the Board”) voted today to adopt the following Policy Guideline the administration of rabies vaccines at a vaccination clinic. The Policy Guideline set forth below does not have the full force and effect of law, as would a Massachusetts General Law or a Board rule or regulation. The Policy Guideline is intended to assist licensees with a recommended protocol and to assist the Board in formulating decisions that relate to issues in the practice of veterinary medicine.   

Policy No. 13-01

The Board seeks to clarify the services that can be provided by veterinarians in settings such as vaccine clinics, which are typically outside of a veterinarian's normal practice locations.

Under 256 CMR 7.01: Code of Professional Conduct (1), a licensee's practice shall conform to currently-accepted professional and scientific standards in the profession of veterinary medicine such as but not limited to the AVMA Principles. It is a currently-accepted professional and scientific standard that the proper use of vaccination is essential to the health of veterinary patients as well as the general public. It is also a currently-accepted professional and scientific standard that animals must be physiologically healthy and immunologically competent to respond to the vaccine.

Vaccination and revaccination programs, for preventive health care, should maintain the health of the animals and public health while minimizing adverse effects. Appropriate decisions concerning individual vaccine selection and vaccination choices are best made under a valid VCPR (veterinarian-client-patient relationship), wherein the practitioner and client determine the best patient care program.

It is a currently-accepted professional and scientific standard that a VCPR is established only when the veterinarian actually physically examines the animal in person. A VCPR is maintained by regular veterinary visits as needed to monitor the animal's health. If a VCPR is established, but the veterinarian does not regularly see the animal afterward, the VCPR is no longer valid.

The Board considers vaccinations of all kinds to be included in this requirement, and therefore veterinarians are prohibited from administering vaccinations unless a valid VCPR has been established and documented. This means that no vaccinations should be given to animals without a valid VCPR, which is established by conducting an appropriate physical examination and assessment of the animal.

The Board acknowledges that Chapter 140 Section 145 B (a) states that:

Each owner or keeper of a dog, cat or ferret that is 6 months of age or older shall cause such dog, cat or ferret to be vaccinated against rabies by a licensed veterinarian using a licensed vaccine according to the manufacturer's directions and shall cause such dog, cat or ferret to be revaccinated at intervals recommended by the manufacturer.

The Board also acknowledges that rabies is a extremely serious infectious disease that almost always causes death, and can be transmitted from animals to humans. Therefore, the Board recognizes the public health benefits of conducting rabies vaccination clinics. For this reason, the Board allows veterinarians to administer rabies vaccines at rabies vaccination clinics without first establishing the usual and customary VCPR. However, this is considered an exception only for rabies vaccinations at rabies vaccination clinics, and does not apply to the administration of other vaccinations, such as distemper, etc., which always require a valid VCPR.

Under 256 CMR 7.01: Code of Professional Conduct (2) A licensee shall

(c) Conduct all professional activities in accordance with federal, state, local and Board statutes and regulations.

Rabies vaccination clinics should follow rabies vaccine label indications/recommendations in compliance with all governmental regulations that may apply. It should also be noted that all rabies vaccinations shall be administered only by a licensed veterinarian.

The licensed veterinarian remains directly accountable for the safe and effective administration of rabies vaccine, including the information to be elicited from the client or legal representative before vaccination.

At minimum, prior to administering a rabies vaccine, it is recommended that  the veterinarian  obtain information regarding vaccines previously received, wounds and exposure to wildlife or domestic animals, preexisting quarantine and health conditions, allergies, and adverse events that occurred after previous vaccinations. Assessment of patient’s physical condition can usually be based exclusively on information elicited from the client or legal representative, and on the veterinarian’s observations of the animal’s condition. Physical examination and vital signs (i.e., temperature, pulse, respirations) measurement are usually not necessary before or after administration of rabies vaccines, unless specifically indicated.

While there is no Massachusetts requirement for a signature to be obtained prior to vaccination, state policy and regulation generally expects the consent of a client or legal representative regarding the vaccination of animals.

The licensed veterinarian must ensure that the permanent record contains all the required documentation. This documentation may simply consist of the use of a uniform rabies vaccination certificate, National Association of State Public Health Veterinarians (NASPHV) form #51, and a rabies tag provided by the vaccinating veterinarian.

Computer-generated vaccination certificates are sufficient, provided they contain the same information required in the NASPHV form #51.

According to 105 CMR 330, vaccination certificates for dogs must be filed by the vaccinating veterinarian within 30 days with the clerk of the city or town where the dog owner resides. One copy shall be provided to the dog owner, and one copy shall be retained by the vaccinating veterinarian. 256 CMR 5.01 requires a licensed veterinarian to keep medical records (i.e., vaccination certificates) readily available for four years after the last contact with the animal.

If you have any questions or concerns about this Policy Guideline, please contact the Board at  617-727-3080.