Effective Date: October 15, 2026 Version: 1.0 Applies to: All Veterinarians who prescribe through the Platform.
Article 1: Introduction and Scope
1.1 This Policy governs extralabel use of drugs and the compounding of medications in connection with prescribing through the Platform. It states the federal regime that governs both subjects, the two conditions that shall each be satisfied before an extralabel or compounded Prescription may issue through the Platform, and the clinical and documentation duties that apply where both conditions are satisfied.
1.2 Licensure, the VCPR, and prescribing are governed by the law of the state in which the Patient is located, and extralabel use and compounding are also governed by federal law. This Policy does not authorize any practice that federal law or the law of that state forbids, and where this Policy and applicable law differ on a clinical matter, the stricter rule prevails. No state permission displaces a federal requirement.
1.3 No provision of this Policy promises a clinical outcome. If a provision of this Policy conflicts with the Terms of Use, this Policy controls for the subject it governs. If a provision of this Policy conflicts with the terms of a program in which the Veterinarian participates, the program terms control for that program.
Article 2: Definitions
2.1 Account: the account a person or business establishes with the Company to use the Platform.
2.2 Client: the person who holds authority over the Patient.
2.3 Company: All About Pawz, LLC, a Tennessee limited liability company.
2.4 Compounded Medication: a medication prepared for an individual Patient, rather than dispensed as manufactured.
2.5 Consultation: a veterinary telemedicine encounter between a Veterinarian and a Client conducted through the Platform.
2.6 Extralabel Use: any use of an approved animal drug, or of an approved human drug in an animal, that differs from the approved labeling in species, indication, dose, route, interval, or duration.
2.7 Patient: the animal that is the subject of a Consultation or a Prescription.
2.8 Platform: the websites, applications, and services the Company operates under the name All About Pawz, including aapawz.com.
2.9 Prescription: an order by a Veterinarian for a medication for a Patient, recorded and transmitted through the Platform.
2.10 VCPR: a veterinarian-client-patient relationship, as defined by the law of the state in which the Patient is located.
2.11 Veterinarian: a veterinarian licensed in the state in which the Patient is located whom the Company has accepted to provide veterinary services through the Platform.
Article 3: The Federal Regime
3.1 Extralabel Use is permitted under the federal regime established by the Animal Medicinal Drug Use Clarification Act and its implementing regulations at 21 CFR Part 530, only within the conditions that regime imposes. The first condition is the one that governs Platform practice: under 21 CFR 530.3(i), Extralabel Use requires a VCPR based on an in-person examination of the animal or on timely visits to the premises where the animal is kept. A remote examination does not satisfy that condition, and a VCPR established by telemedicine: however lawfully established under state law: does not satisfy it.
3.2 The federal in-person requirement in Article 3.1 sits on top of every state position. In a state whose law permits a VCPR to be established by telemedicine generally, extralabel prescribing still requires the in-person element. A state permission for Extralabel Use in the State Telemedicine Matrix means only that the category is allowed where federal law also allows it, and the prescribing process applies the federal rule independently in every case.
3.3 The same federal in-person requirement covers veterinary feed directives, compounding from bulk substances, and biologics.
3.4 Applied to Platform practice: in Tennessee and in every state where a VCPR cannot be established by electronic means, extralabel prescribing through the Platform requires the attested in-person VCPR under the VCPR Establishment Rules: the in-person examination that authorizes the Consultation also satisfies the federal extralabel predicate, provided the examination is within the applicable window. In a state that permits a VCPR to be established by telemedicine, extralabel prescribing requires an in-person examination in addition to the VCPR the remote encounter supports. The remote VCPR supports on-label prescribing; the in-person examination supports extralabel prescribing.
Article 4: The Two Conditions
4.1 A Prescription flagged for Extralabel Use or for compounding is permitted through the Platform only when both of the following are satisfied (a) the underlying VCPR satisfies the federal in-person predicate in Article 3.1: a VCPR of the in-person type, founded on a verified in-person examination within the applicable window; and
(b) the entry for the Patient's state in the State Telemedicine Matrix permits the category, on a legally reviewed basis.
4.2 Each condition is necessary and neither is sufficient. The federal predicate without state permission fails. State permission without the federal predicate fails.
4.3 The default position is closed. State entries carry the extralabel and compounding permissions as not permitted until an entry is legally reviewed and made affirmatively permissive. The prescribing process shall reject an extralabel or compounded Prescription until the entry for the Patient's state satisfies Article 4.1(b). Opening a state is a deliberate, reviewed act for that state, not a general change.
4.4 Compounding from bulk substances carries the federal in-person predicate expressly under 21 CFR 530.3(i). The prescribing process shall enforce that predicate as a separate check for a Compounded Medication prepared from bulk substances, and shall not rely on the general extralabel condition alone.
Article 5: Clinical and Documentation Duties Where Both Conditions Are Satisfied
5.1 Where Articles 4.1(a) and 4.1(b) are both satisfied, the Veterinarian shall (a) document the clinical justification for the Extralabel Use in the clinical note under the Clinical Documentation Policy: why the labeled use is unsuitable, the basis for the extralabel regimen, the extralabel regimen itself, and the monitoring that follows;
(b) counsel the Client on the extralabel nature of the Prescription: that the use differs from the approved labeling, what that difference means for expected effects and risks, and the signs the Client is to watch for: and document the counseling, including the substance of what was communicated; and
(c) set a defined endpoint for the course: a stop date and a recheck. The days supply shall reflect the planned course, and refills allowed default to zero unless the recheck plan justifies a refill, as provided in the Prescription Duration and Refill Limits.
5.2 Illustrative application. A cat requires a medication whose labeled dose is for dogs; the feline dose is established in the professional literature but is extralabel. The Veterinarian's note documents the labeled product and why the labeled use is unsuitable, the literature basis for the feline dose, the in-person VCPR predicate (an attested examination three months earlier), the Client counseling on extralabel status, and a 21-day course with a recheck at day 14. The Prescription is flagged for Extralabel Use, the VCPR type is in-person, and the Prescription transmits because each condition in Article 4.1 is satisfied and the record shows it.
Article 6: Compounding Sourcing
6.1 Where compounding is permitted under Article 4, a Compounded Medication shall be sourced only from a licensed pharmacy that satisfies the Pharmacy Partner Standards. A Compounded Medication shall not be sourced from the prescribing Veterinarian's own preparation in a telemedicine encounter, from an unlicensed facility, or from a pharmacy that lacks the licensing the compounding requires.
6.2 The compounding provision in this Policy is a condition, not a prohibition. Where the conditions in Article 4 are met, the medication is prepared. Where the conditions are not met, the Veterinarian shall refer the Client to in-person care and shall not substitute a workaround.
Article 7: Liability
7.1 Prescribing responsibility. The Veterinarian bears responsibility for each extralabel and compounding decision, including the clinical justification the record is required to show. The Company does not practice veterinary medicine and does not direct the Veterinarian's clinical judgment. Nothing in this Article limits liability for personal injury or injury to an animal caused by negligence, where applicable law does not permit the limitation. No provision of this Policy is a promise of a clinical outcome.
7.2 Exclusion of certain damages. To the fullest extent permitted by law, neither party is liable to the other for indirect, incidental, special, punitive, or consequential damages, or for lost profits, lost revenue, or loss of goodwill, arising out of or relating to this Policy, even if the party has been advised of the possibility of those damages.
7.3 Cap. To the fullest extent permitted by law, the Company's total liability arising out of or relating to this Policy shall not exceed the greater of (a) the amounts the Veterinarian paid to the Company under this Policy in the twelve months before the event giving rise to the claim, or (b) one hundred dollars ($100).
7.4 Carve-outs. This Article does not limit (a) a party's indemnification obligations under this Policy; (b) liability for fraud or willful misconduct; (c) amounts the Veterinarian owes for fees, refunds, or other amounts under the Company's documents; or (d) liability that cannot be limited under applicable law.
7.5 Essential purpose. The parties agree that this Article allocates risk between them, that it is an essential part of the basis of their bargain, and that it applies even if a limited remedy fails of its essential purpose.
Article 8: Indemnification
8.1 Duty. The Veterinarian shall indemnify, defend, and hold harmless the Company and its members, managers, employees, and agents from and against every claim, demand, action, loss, liability, judgment, settlement, cost, and expense (including reasonable attorneys' fees) arising out of or relating to: (a) the Veterinarian's breach of this Policy; (b) the Veterinarian's Services, Prescriptions, or content, including a Compounded Medication the Veterinarian ordered; (c) the Veterinarian's violation of any law or of the rights of any person; and (d) taxes for which the Veterinarian is responsible under the Company's documents.
8.2 Procedure. The Company shall give prompt written notice of a claim under this Article. The Veterinarian shall control the defense with counsel reasonably acceptable to the Company. The Company may participate in the defense at its own expense. The Veterinarian shall not settle a claim in a manner that imposes any obligation or restriction on the Company, or that does not release the Company fully, without the Company's prior written consent.
8.3 Survival. This Article survives the termination of this Policy.
Article 9: Enforcement and Appeals
9.1 Investigation. The Company may investigate any suspected violation of this Policy. The Veterinarian shall cooperate with an investigation and shall produce the records this Policy requires the Veterinarian to keep.
9.2 Notice. If the Company determines that the Veterinarian has violated this Policy, the Company shall give written notice stating the provision violated and the facts relied on, except where notice would compromise an investigation of fraud, a safety risk, or a legal obligation. The Company may suspend the Veterinarian's prescribing and participation immediately where a license has lapsed or a safety risk arises.
9.3 Opportunity to cure. Where a violation is capable of cure, the Veterinarian has ten (10) business days from notice to cure it and to confirm the cure in writing. No cure period applies to fraud, a risk to the safety of a person or an animal, unlawful conduct, or a violation that by its nature cannot be cured.
9.4 Measures. If a violation is established and is not cured within the period allowed, the Company may, proportionate to the violation: (a) issue a written warning; (b) suspend prescribing authority through the Platform; (c) suspend the Account or program participation, in whole or in part; (d) terminate this Policy and the Account; and (e) exercise any other right or remedy available under the Company's documents or at law.
9.5 Appeal. The Veterinarian may appeal a measure under this Article by written notice to legal@aapawz.com within thirty (30) days of the measure, stating the grounds and attaching the records relied on. The appeal is decided by a person who did not make the original decision. The Company's decision on appeal is final. A measure remains in effect during an appeal unless the Company directs otherwise in writing.
9.6 No waiver by delay. The Company's delay in acting on a violation is not a waiver of the violation or of any later violation of the same kind.
Article 10: Term and Termination
10.1 Term. This Policy takes effect when the Veterinarian is accepted to provide veterinary services through the Platform and continues until terminated under this Article.
10.2 Termination by the Company. The Company may terminate this Policy and the Account on thirty (30) days' written notice for any reason, and immediately on written notice if the Veterinarian materially breaches this Policy, engages in fraud, or becomes ineligible to participate.
10.3 Termination by the Veterinarian. The Veterinarian may terminate this Policy on thirty (30) days' written notice to support@aapawz.com, provided the Veterinarian has no booking or investigation outstanding.
10.4 Effect of termination. On termination: (a) the rights granted under this Policy end; (b) obligations that arose before termination: including payment, refund, record-keeping, and indemnification obligations: survive until satisfied; and (c) the Company shall disburse amounts owed, less amounts the Company may set off under the Company's documents, within thirty (30) days, except amounts held in connection with an open investigation or dispute.
10.5 Survival. The Definitions, Liability, Indemnification, Enforcement and Appeals (for measures taken before termination), Dispute Resolution, and General Provisions Articles survive termination.
Article 11: Dispute Resolution
11.1 Any dispute arising out of or relating to this Policy, or to the relationship it governs, is governed by the Dispute Resolution Policy, which is incorporated into this Policy by reference.
Article 12: General Provisions
12.1 Amendments. The Company may amend this Policy by posting the amended Policy in the Document Center and giving notice to the Veterinarian at the email address in the Account. An amendment that materially increases the Veterinarian's fees or obligations takes effect thirty (30) days after notice; other amendments take effect on posting. Continued use of the Platform after the effective date of an amendment is acceptance of it. If the Veterinarian does not accept an amendment, the Veterinarian's remedy is to terminate under Article 10 before the amendment takes effect.
12.2 Notices. Legal notices under this Policy shall be sent to legal@aapawz.com. Operational notices and all other communications shall be sent to support@aapawz.com. A notice to the Company is effective when the Company acknowledges receipt or, for email, one business day after sending, whichever is earlier. Notices to the Veterinarian are effective when sent to the email address in the Account or posted to the Account's notice facility in the portal, whichever occurs first. The Veterinarian shall keep the email address in the Account current.
12.3 Governing law. This Policy is governed by the laws of the State of Tennessee, without regard to its conflict-of-laws rules. Subject to the Dispute Resolution Policy, any proceeding arising out of this Policy shall be brought in the state or federal courts located in Shelby County, Tennessee, and the parties consent to personal jurisdiction there. The practice of veterinary medicine under this Policy is governed by the law of the state in which the patient is located.
12.4 Severability. If any provision of this Policy is held unenforceable, the provision shall be enforced to the fullest extent permitted, and the remaining provisions continue in full effect.
12.5 Entire agreement. This Policy, together with the documents it incorporates by reference, is the entire agreement between the Company and the Veterinarian for the subject it governs and supersedes every prior or contemporaneous statement, communication, or agreement on that subject, whether written or oral.
12.6 Assignment. The Veterinarian shall not assign this Policy or any right or obligation under it without the Company's prior written consent, and an assignment without consent is void. The Company may assign this Policy to an affiliate or in connection with a sale of all or part of its business, on notice to the Veterinarian.
12.7 Waiver. A waiver of any provision of this Policy is effective only in writing and only for the instance stated. No waiver is a waiver of any other provision or instance.
12.8 Interpretation. Headings are for convenience only. "Including" means "including without limitation." This Policy shall not be construed against a party as its drafter. The English-language text controls over any translation.
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