Submission Number: 560891-00046
Received: 7/26/2012 10:58:48 AM
Commenter: Cory Sims
Organization: Brentwood Veterinary Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Considerations for requiring veterinarians to write prescriptions regardless of whether the medication is sold on-site:
1) Issuing a written prescription in addition to dispensing medication from a veterinary hospital is redundant and potentially harmful in the case of controlled drugs and antibiotics where misuse can have serious negative consequences and social costs not only for the individual consumer but for society as a whole. Do we really intend to force veterinarians to issue a written prescription AND dispense a medication such as Fentanyl, Tramadol or Ciprofloxacin, potentially allowing the client to purchase twice as much drug as is intended for use by the patient? This forces veterinarians to choose between the most ethical alternative (just issue the written prescription) and the economic reality of lost income.
2) Some acknowledgement must be made of the time and expense involved in issuing written prescriptions. As a veterinarian, I currently issue between 4 and 8 written prescriptions daily. For each written prescription, I must accept the request from the client, review the patient record (a 1 to 2 minute process) and write out the prescription (another 2 minutes). 5 minutes per prescription at the end of the day easily amounts to 20 to 40 minutes of my day spent issuing prescriptions for which I receive no compensation. Considering that in a typical 10 minute client appointment I personally generate an average of $140 in income for my clinic, this is a potential loss of income of more than $500 per doctor per day. In my 5 doctor practice, this is a significant loss of potential income. Furthermore, I then have to pay a staff member to file each written prescription and contact the client to notify them that the prescription has been completed. This does not even take into account the cost of materials (properly printed prescription pads are not inexpensive.) If a client wishes to obtain my services (diagnosis, prescription and treatment of their pets' illness) then they have to expect that there will be some fee associated with that service. Traditionally, that fee has been partially absorbed by the sale of, and profit from, in-house pharmaceuticals. Under this scenario, veterinarians - particularly practice owners - are essentially being mandated to provide services not just without compensation, but at an actual loss. Why should I be required to pay my clients to shop elsewhere?
3) I do appreciate and understand the value of competition in the marketplace, and there is value in protecting the consumer. However I feel that this particular mandate is misguided. If the intent is to protect the consumer's money, then perhaps a better alternative would be to provide government subsidies for veterinary medicine. Veterinarians are already overworked and underpaid for their time relative to the cost of their education. Assuming that we as a profession are somehow gauging our clients is a narrowminded and ill-informed position. If the intent is to protect clients' and patients' health and ensure a safe and appropriate system for dispensing prescription medications, then perhaps some thought should be turned to the problem of illicit third-party sales of pharmaceuticals to the huge online pharmacies who stand to benefit tremendously from this bill. Such pharmacies have been shown to have significant quality control issues, they are not openly condoned or supported by the veterinary pharmaceutical industry, and they certainly do not have an established veterinary-client-patient relationship. Perhaps we should be considering whether this bill is truly motivated by concern for the general public's finances or simply the profits of large companies with small basis in the community, and no interest in promoting their client's best long-term interests.