Washington Governor Bob Ferguson signed House Bill 2247 into law on March 24, 2026. The legislation expands access to Veterinary telemedicine by allowing telehealth relationships under certain circumstances. Electronic VCPR (e-VCPR) is now allowed in Washington when an animal cannot access clinical Veterinary care due to substantial challenges. So, what happens next?
The Washington Veterinary Board of Governors has embarked on a journey to take HB2247 and create rules that are able to be implemented across the state. Washington’s “substantial challenges” language is novel and could dramatically expand access but also leaves a lot of room for interpretation. Naysayers of e-VCPR could use this as an opportunity to micromanage the language of the bill down to the last letter, creating a “substantial challenge” world practically no one could ever reach. Proponents of e-VCPR wait in the wings, cautiously optimistic the Board will acknowledge the true intention of the legislation—that the voters of Washington need and value access to Veterinary telemedicine.
Washington’s framework is a unique regulation that stands alone compared to other states. There are no comparisons Washington can use to help structure their rulemaking process. As a result, Washington’s leaders have a great weight on their shoulders to ensure the bill is applied appropriately and in line with the spirit of the bill. To experienced observers, it is apparent that the WA legislature accommodated a variety of viewpoints, resulting in a hodgepodge that neither greenlights the unbridled use of an e-VCPR, nor completely restricts it. Everyone has a piece of the pie so to speak, but only if the Board refrains from dissecting the legislation to an unrecognizable state.
Multiple areas of the bill leave room for interpretation. Several provisions of allowing e-VCPR are contingent on the pet owner experiencing hardship. But who can quantify or qualify hardship down to an exact science? One person’s transportation challenge could be completely different from the next pet owner, but each deserves access to telemedicine care for their beloved pet.
Unavailability of in-person appointments is another allowable reason for the usage of an e-VCPR, a term that could be analyzed and defined by the Board. Is there a blanket “acceptable” wait time before an e-VCPR should be triggered? Is a month too long to wait, what about a week? Does it matter what the underlying cause of concern is? A month might not be too long of a wait for certain conditions, while for other conditions, a week-long wait is pushing it. If the Board elects to define when the wait for an in-person appointment becomes “significant” it may miss a critical swath of grey area.
Aside from the concern that micromanaging definitions could lead to a useless bill, it could also lead to an increased burden on the veterinarians who see would-be patients with an e-VCPR. If the Board requires strict definitions, who polices these rules? Does a veterinarian now require a patient to provide some proof of a substantial transportation challenge? Does a three-stop transfer bus schedule suffice? Receipt from the car repair shop to show it is inoperable? And does a veterinarian need to store this “proof” to somehow defend against scrutiny from a Board inquiry?
The logical answer is clear. Allow veterinarians to exercise their judgement when determining if a substantial challenge exists. Allow the veterinarian to determine whether or not the underlying condition can wait for the next in-person appointment, or whether it is so severe that even a one-week wait for an in-person appointment is unacceptable for necessary care. Ultimately, allow the veterinarian to exercise his or her expert and learned opinion as to whether telemedicine is an appropriate avenue of care in the first place. It is interesting that the most rational, logical answer sounds eerily similar to the counterargument to those vehemently against the allowance of an e-VCPR. Allow the veterinarian to exercise their judgment – don’t remove their ability to have autonomy and discretion.
This legislation is unique in its extremely long on-ramp. The bill does not take effect until July of 2027, leaving the Board ample time to structure the rules. All industry eyes are on Washington and how they will implement the intent of the legislature. Let’s hope that they remain dedicated to the underlying premise—access to care for those who do not have the same privileges as the rest.