CMA Market Investigation: BSAVA and veterinary associations respond to CMA’s Issues Statement

2 August 2024

In March this year, the Competition and Markets Authority (CMA) published an update report and consulted on whether to launch a market investigation into veterinary services for household pets in the UK. Having considered responses to the consultation, including that submitted jointly by BSAVA with other veterinary associations, the CMA decided to make a market investigation reference (MIR) into the supply of veterinary services for household pets in the UK.

In July, the CMA published an Issues Statement setting out their initial theories on what might be affecting competition, their potential remedies and how they intend to approach the MIR. The CMA grouped their remedies into three broad categories – improving transparency and helping people make good choices; price/charging remedies; and market opening remedies. They invited interested parties to comment on the issues and possible remedies, to which BSAVA along with BVA, SPVS and VMG, submitted a joint response.

Our joint response acknowledged some of the actions being taken by the profession to increase client choice and improving transparency of both fees and practice ownership. The response also commented on remedies that raised concerns, including potential unintended consequences in the following areas:

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. 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 compromise 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. Unlicensed generic medication cannot always be considered to be equivalent, especially where that unlicensed product may not have the same absorption rate or efficacy.

While the scrutiny of the CMA’s MIR is to be expected, some of the potential remedies need careful consideration to ensure outcomes from the investigation are pragmatic. Continued engagement between the CMA and the profession as the investigation progresses will endeavor to ensure veterinary views are represented and that any unintended consequences are minimized.

Access the joint response here.

Specific information on the CMA’s Issue Statement is available here https://www.gov.uk/cma-cases/veterinary-services-market-for-pets-review#issues-statement.

Previous information on the CMA MIR is available here https://bsava.com/article/cma-launches-a-market-investigation-into-the-veterinary-sector/.