BVA Raises concerns of unintended consequences as it publishes joint responses to CMA’s Issues Statement.

Press Release | British Veterinary Association | 1 August 2024.

The Competition and Markets Authority (CMA) has concluded its consultation on the issues it proposes to explore during its Market Investigation into UK veterinary services for household pets.

The British Veterinary Association (BVA), which represents more than 19,000 vets across the UK, has submitted a joint response raising concerns around potential unintended consequences of some of the CMA’s ideas. These consequences could include reduced client choice and competition; compromised animal welfare; damage to the vet-client-patient relationship; and in some circumstances increased costs for clients.

The consultation response, submitted jointly with the British Small Animal Veterinary Association (BSAVA), the Society of Practising Veterinary Surgeons (SPVS) and the Veterinary Management Group (VMG), also acknowledged the action being taken by the profession to increase client choice, particularly improving transparency of fees and practice ownership.

Specific areas of concern identified in the joint response include:

• Mandated information for clients around quality / outcome-related measures when selecting a first opinion practice. This data is rarely available from clinical practice and where it is, it is unlikely to be statistically significant enough to be meaningful. This could result in misleading comparisons and potentially misinform and confuse pet owners rather than helping them make informed decisions.
• Annual ‘wake-up’ letters from vet practices to registered pet owners prompting them to reconsider their choice of first opinion practice. This has the potential to seriously undermine the vet-client-patient relationship (VCPR) which is key to achieving good long-term animal welfare. Encouraging clients to frequently reconsider and possibly switch their veterinary practice could lead to fragmented care, miscommunication, and a lack of comprehensive medical records, which risks compromising animal welfare.
• Prescription lengths. Mandating longer prescription periods without allowing vets to use their clinical judgement could seriously threaten animal welfare. Vets choose prescription durations based on the animal's specific medical needs. Extended periods could lead to antimicrobial resistance, unmonitored side effects, or worsening conditions without timely check-ups.
• Use of generic medicines. Veterinary surgeons must abide by the Veterinary Medicines Regulations and prescribe medication according to the Cascade. This is a framework that ensures vets prescribe the most appropriate medications for animals, prioritising licensed veterinary products that have been tested and evaluated to maintain high standards of medicines safety which is essential for animal health and welfare. It would be irresponsible to suggest that unlicensed generic medication is equivalent, especially where that unlicensed product may not have the same absorption rate or efficacy.

British Veterinary Association President Dr. Anna Judson, said:

“Whilst we continue to welcome the scrutiny of the Competition and Markets Authority’s investigation, some of its proposed areas of concern and specifically some of the potential ‘remedies’ outlined in the CMA’s issues statement are worrying. Rather than ensuring clients and their pets receive the best care at a fair price, they could in fact inadvertently harm the veterinary profession’s ability to serve its clients and patients effectively, reduce client choice, and in some cases increase costs.

“As a profession dedicated to animal health and welfare, what is perhaps most alarming is that some of the CMA’s potential ‘remedies’ could actually harm animal welfare. Cleary these are unintended consequences, but they do highlight the importance of continued engagement between the CMA and the profession as the investigation progresses to ensure the veterinary voice is heard and unintended consequences are avoided.”

2nd August 2024