In June 2015, the Food & Drug Administration (“FDA”) promulgated the second Veterinary Feed Directive (“VFD”) affecting livestock producers that use medicated feed and water. The final rule became effective in October 2015 transitioning Over-the-Counter (“OTC”) drugs to be VFD through January 1, 2017. This requires veterinarians to have a Veterinary-Client-Patient Relationship (“VCPR”) and use a VFD to prescribe the …