Submission Number: 560891-00038
Received: 7/25/2012 4:56:17 PM
Commenter: Deborah Wiest
Organization: Paso Robles Vet
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
As a veterinary practice owner, I have usually found that pet owners are intelligent beings and are able to make their own decisions regarding their pet's care. Pet online pharmacy advertisements abound on television and the internet, informing people of their presence and people's ability to have any prescription medications, whether human prescription or pet prescriptions, filled at a pharmacy of their choice. I think the public is already well-informed and knowledgeable about the choices regarding where pet medications can be filled, either at the veterinary office, a local pharmacy or an online pharmacy. I feel that having the government step in and dictate to a veterinary practice that they have to advertise for any off-site pharmacy is a ridiculous waste of tax-payer's money and is redundant. The public is already informed! I don't know of any veterinarian who would not provide a written prescription to a client if asked to do so.
Additionally, I feel that there are online pharmacies, especially those that fill pet medications, that are unethical in their practices, regarding the quality of the products that they stock and dispense to consumers as well as their practices regarding specific prescription instructions and refills allowed. Additionally, while many pet online pharmacies have offered reduced pricing on prescription medications in recent years, basically offering 'loss-leader' pricing on popular medications in order to secure a customer's business, I have seen many recent prices on these medications being sold to consumers at the same price if not a higher price than would be dispensed at the veterinary office pharmacy. Consumers just assume the online pharmacies are less expensive because they claim to be.
As far as federal bill H.R 1406, to force veterinarians to provide written prescriptions and notification of other pharmacies available, I think this is redundant in our modern world and puts undue burden on already struggling veterinary practices. As far as I understand, it is already illegal for veterinarians to refuse to respond to a prescription refill request from another pharmacy. My clinic requires a faxed copy of a prescription request, as we need a paper trail to track them. These paper fax copies are kept in our individual client's pet medical files for reference. Verbal phone refill requests are too easy to be subject to forgery or dishonesty and are difficult to track on the veterinarian's end.
As a reminder, the internet is world-wide, as well as the pharmacies that are represented on it. Internet product regulation is near to impossible. Many pharmacies that operate outside of the United States are not subject to the regulations of our own Food and Drug Administration, and may procure their medications from unreliable sources such as China, India, etc. These medications may appear to be packaged to represent the product ordered, but, in fact, may be something else altogether. Topical flea preventatives are a popular item to be mis-represented in this manner. One of our clients recently ordered a chewable Baytril antibiotic tablet online, where no prescription was needed, and upon chemical analysis, the product did not contain the antibiotic that was claimed. This is a serious problem for the consumer and their pet.
Finally, veterinary care costs have indeed risen in the past decade. This is in part due to the loss of pet vaccination revenue to veterinarians caused by the switch to the three-year vaccination protocol as well as pet vaccines being readily available at most human pharmacies and low-cost vaccination clinics. Loss of vaccine-driven and pharmacy-driven revenues in veterinary clinics will only force veterinarians to charge more for exams, hospitalzation and surgical services. This will further limit the number of pets that receive proper veterinary care, and will contribute to more problems in the public health arena as well as overpopulation of animal shelters.