HCCE Permits Are Arriving
Check Below To See If You Need to Renew

By BRENDA EGGERT BRADER,
Communications and Public Relations Director

The Health Care Clinic Establishment (HCCE) Permit renewals are now being received by Florida veterinarians. Because of those renewals, the Florida Veterinary Medical Association has been receiving an abundance of questions from veterinarians. In an attempt to help members evaluate their need for the HCCE Permit, the following information has been compiled.

The Health Care Clinic Establishment (HCCE) Permit was established (in 2008, effective Jan. 1, 2009) to bring practitioners into compliance and legislatively allows corporations to purchase and maintain prescription drugs in one corporate inventory to be dispensed by qualifying practitioners in their employ. However, a licensed veterinarian has, and continues to have, the legal authority to purchase and own prescription drugs under his/her own license even if he/she is incorporated, as long as his/her name and license number is on all invoices and records pertaining to prescription drugs.
Furthermore, the Drugs, Devices and Cosmetics Program of the Department of Health does not intend to enforce an interpretation of the law that would prohibit the use of Rx drugs by practitioners at an establishment in a group practice that were purchased by another member of the group practice at that establishment.

Briefly, the three main points each veterinarian needs to know for the HCCE permit are as follows:

• The HCCE Permit is required by any multi-veterinarian clinic or solo practitioner who orders his/her drugs through a corporation’s name. The permit covers all the practitioners in a group practice, but requires a “qualifying practitioner” be named on the permit and that practitioner is responsible for all record keeping, storage and handling of all prescription drugs ordered and dispensed under the HCCE.
• Individual practices where there is a sole practitioner operating under a fictitious name and ordering prescription drugs under the veterinarian’s own name and license, do not need the HCCE permit.
• Veterinarians who have previously been issued a permit, but who have now decided to purchase drugs under their individual license instead, should return the renewal notices to the Department of Health, Drugs, Devices and Cosmetics Program by fax. Written at the bottom of the faxed permit should be the statement: “We are not renewing this permit because we are going to be ordering drugs through the doctor’s name.”  Fax it to (850) 413-6982.

An HCCE Permit, unless suspended or revoked, automatically expires two years after the last day of the anniversary month in which the permit was originally issued. A permit issued under ss. 499.001-499.081 may be renewed by making application for renewal on forms furnished by the department and paying the appropriate fees. If a renewal application and fee are submitted and postmarked after the expiration date of the permit, the permit may be renewed only upon payment of a late renewal delinquent fee of $100, plus the required renewal fee, not later than 60 days after the expiration.

The renewal fee for the HCCE Permit is $255, good for two years and it covers all the practitioners in a group practice. The permit does require that a “qualifying practitioner” be named on the permit and that the practitioner is responsible for the record keeping, storage and handling of all prescription drugs ordered and dispensed under the HCCE.

According to Florida State Statute 456.001, “a qualifying practitioner is a licensed healthcare practitioner as defined in the state statute or a veterinarian licensed under Florida State Statue 474, who is authorized under the appropriate practice act to prescribe and administer a prescription drug.”

History

Originally, the Florida State Department of Health was of the opinion that each veterinarian in a multi-veterinarian corporation clinic would have to purchase his/her own supply of prescription drugs to be able to prescribe those drugs for his/her clients’ patients. The drug expense for each separate veterinarian in a multi-member clinic would have been prohibitive. In order for FVMA members to continue operating as they have for decades, the FVMA worked on language with the Department of Health that would allow corporations the ability to purchase and own prescription drugs under the name of the corporation. As a result of that compromise, the HCCE permit was created. Previous to the compromise, the DOH had been adamant that neither a corporation nor a veterinary Premises Permit was authorized by law to purchase and own prescription drugs and that the long-standing practice of doing so was illegal.

Further questions concerning HCCE Permits should be directed to Natasha Lafaille, of the Drugs, Devices and Cosmetics Program, DOH, who encourages questions on HCCE permits directly to her email at Natasha_Lafaille@doh.state.FL.US. Her direct telephone line is (850) 245-4444, extension 3862, 8 a.m. to 5 p.m. Monday through Friday.