Submission Number: 560891-00064
Received: 7/27/2012 12:53:29 PM
Commenter: Morgan Everett
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
My primary concerns relative to the processing of prescriptions in companion animal veterinary medicine are as follows: 1) Pet owners do have an option of a valid written prescription on demand. I do object to a requirement to provide a written prescription in all cases. The time and education requirements attached to a written prescription adds uncompensated burden to the veterinary staff, delays acquiring the medication, sometimes by days as the owner searches for a local or online supplier of the correct medication and increases the risk of an undertrained or ignorant human pharmacist inadverantly proviving an incorrect prescription. Market place forces will correct the financial burden, as veterinarians will charge more for other services, making other aspects of veterinary care more expensive, not less expensive.
2) My second concern is that, if a precident to expand the use of written prescriptions ensues, a compression of the market or regulatory forces will shift the veterinary pharmacy to become a secondary business, forcing veterinarians to close their pharmacies completely or in effect, become pharmacies themselves with regulations and rules overseen by a different regulatory board.
3) In contrast, I would like to see a relaxation of the pharmacy rules in veterinary medicine to allow other veterinary clinics to fill paper prescriptions written by a veterinarian.