A common query received at the VDS is whether as a veterinary surgeon we should sign a form authorising a physiotherapist to work with a patient. These days, such forms are typically sent via email into the practice. On the face of it, the question is a simple binary one: to sign or not to sign; however, the question is often not as simple.
An informed decision as to whether one should sign or not is ideally made with an understanding of the relevant legal framework, the RCVS Guidance and the potential adverse consequences from signing the form. The adverse consequences of not signing the form would be to irritate the client and physiotherapist. Whilst undesirable, not signing the form would, at least on the face of it, appear to pose less serious potential consequences for the veterinary surgeon.
UK law permits the practice of physiotherapy on animals by non-veterinary surgeons where such treatment is directed by a vet who has examined the animal and prescribed physiotherapy. So, there is a convincing argument you should only sign the form if you believe these conditions are met. When endorsing the referral of a patient to a therapist, difficulties can follow if the conditions are not met.
Except for specific exemptions in the law, the Veterinary Surgeons Act 1966 (VSA) makes it illegal for non-veterinary surgeons to practise veterinary surgery. The Veterinary Surgeons (Exemptions) Order 2015 provides an exemption to the VSA to allow the treatment of an animal by physiotherapy if the following conditions are satisfied: (i) the person providing the physiotherapy is aged 18 or over; (ii) the person is acting under the direction of a qualified person (a registered veterinary surgeon) who (a) has examined the animal, and (b) has prescribed the treatment of the animal by physiotherapy.
The Order pointedly does not define physiotherapy and neither does it provide a definitive list of permitted activities.
The RCVS provides relevant guidance on the treatment of animals by physiotherapy in Section 19 of the Code of Professional Conduct for Veterinary Surgeons. Physiotherapy is interpreted by the RCVS as including all kinds of manipulative therapy. It includes osteopathy and chiropractic but would not, for example, include acupuncture or aromatherapy. There is further helpful clarification from the RCVS in Section 19.22: It is illegal, in terms of the Veterinary Surgeons Act 1966, for non-veterinary surgeons, however qualified in the human field, to treat animals.
So the legal requirement would appear straightforward enough: animal physiotherapy must be directed by a vet who has examined the animal and prescribed physiotherapy. The RCVS provides guidance on referring responsibly, albeit that guidance relates to referrals made between veterinary surgeons. However, it would seem reasonable to assume that this should also apply to referrals made by veterinary surgeons to physiotherapists. Where the involvement of a physiotherapist in an animal’s treatment is driven by the veterinary surgeon, these requirements are readily satisfied by the referral process.
Difficulties are more likely to arise when the involvement of a physiotherapist is driven not by the vet but by the client who may wish to take their animal to a physiotherapist of whom the veterinary surgeon has no knowledge.
Considerations incumbent on the vet are: (i) is it possible that physiotherapy might benefit this case?; (ii) if I cannot be certain that physiotherapy will benefit the patient, can I be certain that it will cause no harm?; and (iii) is the proposed physiotherapist competent to provide appropriate care?The answers to the first two questions are matters for professional judgement. Answering the third can be challenging where the veterinary surgeon has no personal knowledge of the physiotherapist. There is no overarching regulatory body for veterinary physiotherapists. This makes it difficult to objectively assess the individual’s particular qualifications and make an informed decision.
It is usually said to be a demonstration of their compliance with the legislation that the physiotherapist requires some form of evidence that their client has sought their veterinary surgeon’s approval of the proposed treatment. Typically a pro-form questionnaire is sent through requesting the vet signs the document. It would seem that such approval cannot be given unless the patient and its condition in question are known to the veterinary surgeon, meaning there must have been some relevant veterinary attendance.
As with any statement to which you put your signature, you must be entirely comfortable with the content (see the 10 Principles of Certification) and you should feel free to amend or strike through as necessary.
Some practices find it helpful to produce a client information sheet explaining their considerations when approached by a client to endorse a referral for physiotherapy. Hopefully this article, which is based on a VDS Advice Note on the topic, will prove useful in drawing up such an information sheet.