Submission Number: 560891-00087
Received: 8/1/2012 10:06:59 AM
Commenter: Owen McFadden
Organization: Midlothian Animal Clinic
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Regarding the Pet Medication Workshop, Project No. P12-1201, 10/2/12, the recent bill, HB 1406,introduced to congress is misleading,reduntant,unnecessary and an attempt by Walmart to drive consumers to their business by altering federal and state prescription writing laws.
Concerning the portability of prescriptions,this bill is unnecessary:
- any and all prescriptions regarding a pet's care should be the result of a relationship between a veterinarian, the pet and the owner/client.
- clients have always had the choice to ask for a written prescription from a veterinarian and frequently do. The AVMA has encouraged this.
- veterinary hospitals have traditionally stocked medication both OTC and prescription specifically for animals, most not approved for humans. Certainly the convenience of obtaining medication at the time of the visit is much better than going to an outside sourse. Web based pharmacies take days to deliever which could be critical. Clients would find it hard to fill pet prescriptions in rural areas. Human pharmacist are not trained in many of the differences in animal drug reactions and usages. Most pharmacies do not carry any medications for pet horses, pocket pets, birds or reptiles.
This bill is reduntant as as all State Boards of Pharmacy and Veterinary Medicine already govern prescription writing for all professions.
This bill is unfair and onerous:
- verification of prescriptions by provider, DVM,MD,DDS, etc has never existed and would increase time and cost unnecessarily. This would have to equally effect human MDs. This is the responsibility of the pharmacist.
- by requiring redundant written prescriptions [the inital one is part of the pet's record] and disallowing any payment for professional time and services. The veterinary professional license, both federla and state, allows him to write prescriptions and all cost [time,materal educatio and expenditures] should be passed on if so desired to the user.
- regarding the cost to the consummer of medication, veterinary hospitals can not buy in bulk as large pharmacies nor obtain "black market" or other countries items, but do compete with lower priced items. Price setting is against the law. Let the MarketPlace decide this issue.
Owen C McFadden DVM