"Steering" Regulations of the C.V.O.
(College of Veterinarians of Ontario)
C.V.O. "Steering" Regulations
The C.V.O. (The College of Veterinarians of Ontario) is responsible for "regulating the Ontario Veterinary Profession "to protect the public interest".
The Council (or Board of Directors) is the governing body for the C.V.O. and is composed of 13 veterinarians and 2-5 public (non-veterinarian) members. The composition and powers of the Council are established in the Veterinarian's Act. Council's stewardship role includes setting strategic directions, making policy decisions, and ensuring financial soundness of the C.V.O. Decisions focus on the public interests, not on member advocacy.
Herein lies the dilemma. "Public Interest", as defined by Wikipedia, refers to the "common well-being" or "general welfare". It is a normative concept, one that always takes its meaning from whoever happens to be speaking. At any point in time, the public interest will tend to be defined by those who have the self-interest to believe that it matters and to impose their views.
The C.V.O. has implemented "steering" regulations which directly affect the efforts of Animal Welfare Organizations to provide "low-cost" spay/neuter programs to members of the public. What these steering regulations stipulate is that veterinarians in Ontario cannot participate "directly or indirectly in a system in which another person steers or recommends clients to a member for a professional service or ancillary service". (O. Reg 1093, Section 38).
What does this mean exactly? Animal Welfare Organizations can no longer make arrangements with any one veterinarian to provide low-cost spay/neuters to members of the public. They can still avail any such arrangements to have their own animals fixed, but once the animal is adopted, the situation changes and becomes one of "steering". What is the C.V.O.'s solution to this problem? Coupons of a fixed amount redeemable at any veterinarian facility, can be provided through a spay/neuter program. The difference in cost is then either made up by the member of the public or by the Animal Welfare Organization itself.
What is the stated reasoning for this "steering" regulation by the C.V.O.? "The intent of (Sec.38) Ontario Regulation 1093 is to allow owners to freely choose the veterinarians who will care for their animal. It allows the new animal owner to develop a relationship and confidence in a veterinarian who they have personally chosen to care for their animal throughout its life." It also eliminates the potential conflict of interest for the veterinarians who participate in a steering situation".
What constitutes "Steering"? Veterinarians cannot participate in any system of steering where potential clients are directed to designated practitioners for veterinary services. There are three components to improper steering:
There must be a "system" (i.e. a structured program or ongoing activity:
The system results in a client being directed to particular member(s); and
The veterinarian must participate i the system in some way.
Initially the veterinarian involvement in the system may we with or without their knowledge. However, once a veterinarian becomes aware of their involvement in such a system (e.g. by a commercial enterprise that is used to endorse its own products and services), it is their professional responsibility to ensure that the practice is discontinued. (Note here that the example used for "steering" is a commercial enterprise, not an Animal Welfare Organization spay/neuter program for the benefit of the public).
Breaches of the regulations are extremely serious and may lead to investigation by order of the Executive Committee of Council, complaints and/or discipline procedures, restrictions on their licenses, and potentially the loss of licensure to practice veterinary medicine in Ontario.
One small consolation, Animal Welfare Organizations are allowed to compile a list of veterinarians who will provide low-cost sterilization services to members of the public with the following stipulations: all veterinarians in the area must be approached and allowed to participate; this list can only be provided to members of the public who specifically request it and it cannot be made public.
These "steering" regulations are purported to "protect the public interest". Follow the links provided below to view the actual C.V.O. documents on "Steering" and "Steering and Welfare Organizations" and judge for yourself. View the online petition requesting that these steering regulations of the C.V.O. be rescinded immediately and sign if you agree.
"Steering" Regulation for Animal Welfare Organizations
Online Petition