Get ahead of the Competition and Martket Authority’s final decision – practical changes you can make today

Thanks to our influence, the CMA’s Provisional Decision last autumn was more measured and proportionate than their earlier proposals and we’ve continued to engage to support further refinement of the draft remedies.

Although we don’t yet know for sure what the final package of remedies will look like, we are well-placed to suggest where it might make sense for you, your team, and your practice to be thinking about ways of working, particularly in relation to your interactions with clients and the information made available to pet owners.

Recognising that much of this is best practice, and will be in place to a greater or lesser or extent in many small animal practices already, here are some of the things you might want to think about ahead of the CMA’s final decision:

• Information about practice ownership – if you operate more than one small animal practice, including related services such as referral centres, you should be communicating this clearly to clients, so they understand that there is a common ownership.
  
  
• Information about services – all small animal practices and referral centres should be publishing clear, accessible information about services provided, such as out-of-hours care, qualifications held by the practice team, and any RCVS accreditations or awards.
  
  
• Information about prices - all small animal practices and referral centres, including crematoria, should be publishing clear, accessible information showing prices for the services provided. The standardised requirement from the CMA is yet to be set, but is likely to include:
  • Consultations
  • Vaccines
  • Neutering
  • Microchipping
  • Nail clipping and anal gland express
  • Prescription charges
  • Euthanasia and cremation charges

• Written estimates – you should be providing clients with a written estimate of the total cost of any treatment. The CMA may set a minimum threshold, which is likely to be £500 (including VAT).

• Itemised bills - you should be providing clients with itemised bills so they can understand exactly what they are paying for.

• Pet care plans – if you offer pet care plans, you should be publishing clear, accessible information about all included services, the standalone price of each, and details about parasiticides. You will need to be able to explain how claimed savings are calculated.

• Prescriptions – you should be making it clear to clients that they can request a written prescription, where clinically appropriate.

• Cremations – you should be offering the option of a basic communal cremation, and publishing the prices of all cremation services offered, including add-ons. 

• Complaints procedure – you should have a complaints procedure in place, which is communicated to clients 

What can we expect next from the CMA?

The CMA’s final decision is expected by the end of the month, but that’s not the end of the story. Any remedies that the CMA decides to progress will need to be included in CMA ‘Orders’, which are legally binding directives, and will contain the detail of the practical implementation of any remedies. The CMA will consult on these draft Orders, and we don’t expect them to come into force until the end of the year. There will then be an implementation period and, depending on the remedy and whether or not your practice is categorised as independent or part of a large group, you may have up to six months to make the changes necessary to comply with the requirements, although the exact time period is yet to be confirmed

Shared decision-making and contextualised care

Communicating with pet owners about the CMA investigation, and the potential remedies that may be enforced, can be a difficult path to navigate with the current uncertainty. Even when clarity emerges about the final remedies, navigating conversations with clients about the impact on vet costs and the care we provide will be challenging.

Many of the remedies are likely to focus on communicating pet owners’ options clearly and effectively, something most vets already do very well. By adopting a shared decision-making approach as utilised increasingly in human healthcare, we as vets can help our clients take ownership of decisions around the care of their pets. While we as vets have a duty of care to the animals we treat, pet owners are also responsible for their animals and have a role to play in the decision-making process. This ensures that veterinary expertise and advocacy of animal welfare is combined with owner needs, personal circumstances and expectations in a way that allows care to be delivered in a contextualised way. We can and should be having these conversations with our clients now, giving them agency and ownership of treatment decisions and therefore reducing the perception that they have no choice in the costs or outcomes of veterinary treatment.

To achieve shared decision-making:

• Understand the owner’s perspective and priorities
• Check the owner has understood what you as vet have identified as the issue and how this might be investigated and treated
• Accept the owners’ preferred way forward without being judgemental

Combined with information and clarity around prices and choices, this should help vets and pet owners work together in a way that improves the relationship and ultimately makes vet-client interactions more rewarding. This will prepare us well as a profession for the eventual implementation of whatever remedies the CMA decide to impose.