Submission Number: 560891-00088
Received: 8/1/2012 10:43:27 AM
Commenter: Catherine Webb
Organization: Lindquist Veterinary Care Center
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
As a veterinarian in a remote rural area, serving already one of the poorest counties in the state, I agree with many of my colleague's prior submissions on the "Fairness to consumers" act. Firstly, many of the products sold by online pharmacies, large chain store pharmacies, etc. are not sold to those companies by the producers/manufacturers. With unknown conditions in these warehouses, a known history of counterfeit products sold on the market, and a loss of the product's guaranteed efficacy; these products should be labeled 'inferior' instead of 'fair'. Knowledge of multi-species pharmacology, drug interactions, and metabolism is vital to the production of safe veterinary pharmacy practices. This is not something that can be picked up from a weekend continuing education pharmacology course.
Importantly, practitioners in rural areas have a very small mark-up on these same products, sometimes charging less with manufacturer rebate (only available from a veterinarian, just as in the contact lens industry). Should this market move from the veterinary clinic and into the hands of these large middle-man companies, we will be forced to raise costs of all other services, making it even less affordable to our clientele. A substantial percentage of our rural clientele are having an increasingly difficult time affording veterinary care. When the examination fee in rural Missouri is already 33% of what one may find in a large city in California, or 50% of what one may find in a large city in Missouri, this is a substantial change to the area's economy, making pet ownership more of a 'luxury' and less 'fair' to pet owners in our area. I see enough patients already who prefer to euthanize an animal because they cannot afford to treat it or worse, have not prevented diseases because they cannot afford inexpensive vaccinations.
As a 2011 graduate of the University of Missouri College of Veterinary Medicine, I am entering the world of veterinary medical practice in a very precarious time, one in which debt to salary ratio is already approaching 2.5:1. Should these trends continue, and clientele and clinic visits drop off more, I may be forced to move to an area where clients have more expendable income for their veterinary medical care. This would leave an area already labeled by the Federal Government as an area of "great need" for veterinary care into an area of severe hardship for small and large animal owners.
I ask the FTC to consider both the livelyhood of rural American veterinary practitioners, as well as their clientele in this important decision making process and consider what an important effect the small town veterinary clinic has upon small town and rural economies.