Your Weekly Compliance Digest

What changed: OSHA has published a new compliance guidance for veterinary clinics handling hazardous drugs (chemotherapy agents, certain reproductive hormones, some anesthetics). The guidance clarifies that veterinary practices that administer, handle, or store hazardous drugs — including routine items like misoprostol for equine colic, cisplatin for cancer treatment, and isoflurane/sevoflurane anesthetic agents — must now maintain a written Hazardous Drug Exposure Control Plan (HDECP).

This is not just oncology clinics. The scope includes any practice that keeps any drug on OSHA's hazardous drug list in the clinic environment.

Why it matters: Without a written HDECP, your practice is out of compliance with OSHA's revised hazardous drug guidance. Fines for OSHA violations range $1,000–$15,000 per violation depending on severity. More critically: staff who handle these agents without proper controls have documented increased risk of reproductive harm, chromosomal damage, and respiratory sensitization. This is a real liability exposure, not bureaucratic theater.

What changed: Effective July 1, 2026, all California dental license renewals must include proof of completion of a 2-hour opioid-prescribing continuing education course (CA Business & Professions Code §1645.3). This is a new requirement — it was not required for renewals completed before July 1.

Why it matters: If your California dental license is due for renewal after July 1, 2026, and you don't have the opioid-prescribing CE on file, your renewal may be delayed or rejected. A delayed renewal means practicing with an expired license — a separate and more serious violation.

What changed: The CDC updated its Infection Control FAQ for dental healthcare settings (April 2026 revision). Surface disinfectants used in dental operatories must now list an EPA Registration Number AND an Emerging Viral Pathogens (EVP) claim on their label to be considered appropriate for semi-critical instrument pre-cleaning.

Several widely-used dental surface disinfectants — including some EPA-registered products without explicit EVP language — may no longer technically qualify under the updated guidance.

What's proposed: CMS has published a proposed rule to increase the reimbursement rate for D0191 (oral screening) from $22 → $31 in California, Texas, and New York, effective January 1, 2027. This is a ~41% rate increase for this code.

Why it matters (but not urgent): If you bill Medicare or treat Medicare patients, this would increase your per-visit revenue by $9 per screening. The rule is not final — no action required now, but worth flagging for your Q4 2026 fee schedule review.

What's new: The Texas State Board of Veterinary Medical Examiners has published explicit enforcement guidance clarifying that telemedicine encounters for Texas-licensed veterinarians require a documented VCPR before the telemedicine visit — not retroactively. If you are a Texas-licensed DVM conducting telemedicine consultations, you must now have the VCPR established through a prior in-person examination or through an eligible Virtual VCPR examination method approved under 22 TAC §573.27.

Why it matters (but not urgent): Texas is one of the top states by veterinary practice density. If you hold a Texas vet license or see Texas-based animal patients via telemedicine, this clarification specifically targets practices that were obtaining VCPRs via telemedicine-first workflows — which may no longer be compliant after April 1, 2026.