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The response, published jointly alongside the British Veterinary Association( BVA), British Small Animal Veterinary Association( BSAVA), Veterinary Management Group( VMG) and Society of Practising Veterinary Surgeons( SPVS), addresses the potential remedies and measures proposed by the CMA in its most recent working paper.

BVNA welcomed the opportunity to respond to each of these potential remedies, and is encouraged by the efforts made by the CMA to understand the veterinary sector and the contexts in which veterinary care is provided.

The working paper recognises the need for longoverdue reform of the outdated Veterinary Surgeons Act 1966, which BVNA has long been calling for. Proposed areas for reform crucially include statutory protection of the title‘ veterinary nurse’, expansion of the Registered Veterinary Nurse( RVN) role, and the regulation of veterinary businesses rather than solely individual vets and RVNs. In addition, the potential remedies reflected BVNA ' s calls for improved clarity within existing legislation, to enable vets and RVNs to feel more confident with delegation under Schedule 3 and therefore encourage far greater use of RVNs.

However, BVNA has raised a number of concerns in relation to the volume and proportionality of the measures, the subsequent impact on veterinary businesses, especially smaller independent practices, and the significant burden that would be placed on veterinary professionals while attempting to implement all of the suggested measures at once.

Overarching concerns outlined in the response include:

Proportionality

The package of remedies as set out in the CMA ' s working paper is too extensive and disproportionate to the CMA ' s concerns, leading to a significant and unacceptable administrative burden on practices.

Impact on small independent practices

The remedies would disproportionately negatively affect smaller independent businesses, which would likely have to increase fees to maintain financial viability.

Increased costs

Many of the proposed remedies necessitate the development of additional technologies, which would also disproportionately impact on smaller businesses and could also lead to increased costs for clients.

Wider impact on veterinary services

The current investigation is solely focused on veterinary services for household pets; however, mixed practices providing care for both companion animals and larger species would be affected by the proposed remedies.

Unintended consequences

The suggested remedies would lead to an increase in the cost of providing veterinary services, due to the significant additional burdens placed on veterinary businesses, which would inevitably lead to increased fees for clients. This could lead to a negative impact on animal welfare, with pet owners who are already struggling to afford veterinary care potentially delaying or avoiding seeking veterinary care for their pet.

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