Submission Number: 560891-00061
Received: 7/26/2012 10:33:20 PM
Commenter: Judy Little
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
If a client opts to fill the prescription at my clinic, it would make no sense to have to issue a written prescription (assuming no refills were allowed). It would only add to the paperwork & recordkeeping. There is potentially the problem that the client could fill the prescription more than once; ie: fax it to PetMeds, then fax it to another online pharmacy, then take the written rx to Wal-mart. Who/how will keep track of the number of times it is filled? Most of the time with my clients there is no insurance involvement and it is worrisome if this were to happen with a controlled substance.
When a client fills a prescription at our clinic, a label is made, the rx is noted in the record, it is filled, then the client pays. To give a client a written prescription will require all those steps plus writing a prescription and yet no payment for it unless an extra charge is added to the billing.
Requiring a written prescription for every medication will drive the cost of veterinary care higher (higher prices for exams/lab tests to compensate for extra time writing prescriptions & lost revenue from not filling prescriptions), so the client will not save any money in the end by purchasing "cheap" medications.
If something is done to inform clients that they may fill their prescriptions at any pharmacy, it would only be right to also detail how filling the prescription at their veterinary clinic is the better choice.