Submission Number: 560891-00107
Received: 8/1/2012 11:59:20 PM
Commenter: Mary Kraeszig
Organization: Veterinary Relief Services
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I have always worked as a relief veterinarian, therefore I have no personal stake in legislation regarding prescription writing for pet medications. However, I do have strong opinions on the matter that I would like the FTC to take into account.
(1) One of my employers is a non-profit spay/neuter/vaccination clinic. Approximately 40% of its operating expenses are derived from the sales of heartworm, flea, and other anti-parasite medication. Since the organization is non-profit, their prices are lower than the consumer can obtain OTC or through a pharmacy. There is only enough "profit" added to pay salaries, rent, and all the various expenses involved in operating the clinic. It would be devastating to this organization and its mission if it were forced to give prescriptions to its clients. It would be "the end" of this organization, which has already spayed/neutered 80,000 cats and dogs in the greater Indianapolis area, and which performs approximately 70 such surgeries daily. Additionally, the vaccination clinic (including heartworm testing and parasite control) sees approximately 45-50 pets per 2-3 hour shift, and twice that number on Saturdays. We provide a desperately needed service to pet owners affected by the economic downturn, who would otherwise abandon their pets or leave them unvaccinated and subject to more parasitic diseases. The U.S. has already seen a dramatic rise in the number of cases of human and animal rabies over the last couple of years, most likely as domestic animals have been left unvaccinated and their immunity has faded. This is not just an economic issue, but one with serious human health consequences. Additionally, the only FDA licensed product to treat heartworm disease, Immiticide, has been unavailable due to manufacturing issues in the U.S., and the drug must be ordered through a tedious process to obtain it from Europe. This has forced the cost of treatment to increase, and left many owners resorting to "Plan B," which is less costly but kills heartworms very slowly over a period of a year or so, allowing them to continue to damage the heart and blood vessels around the heart. We need to be able to continue to provide low cost testing and heartworm preventatives to clients throughout the U.S.
(2) I also do relief work for private practices. Unlike human medicine, which has long relied on pharmacies to provide medications for people, veterinary practices have traditionally provided their clients with medications themselves. While a small fraction of practices have voluntarily gone to a prescription-only service to its clients, most private practices derive a portion of their income from providing medications to small and large animals to their clients. Veterinary practices have also suffered seriously during the long economic downturn, and the loss of income would be dramatic if all were forced to provide prescriptions, whether or not a client asked for it, increasing unemployment and/or causing increased fees for other services. Also, every practice I have worked for will price-match the online pet pharmacies if a client requests a prescription, thus retaining the relationship with the client while providing the client with the sense that they have saved money (usually the savings are small).
The overarching issue with veterinary drug dispensing by pharmacies is that pharmacists/technicians are NOT trained in the dosage or uses of veterinary drugs. Cats and dogs are not small humans, and cattle and horses are not large humans. Dose ranges vary enormously from species to species, and veterinarians are in the best position to ensure that proper doses and route of administration are used. Pharmacies would also face the additional costs of maintaining full veterinary pharmacies, which is costly because one size does not fit all animals. Veterinarians spend four years learning these differences, and I do not believe that pharmacists want to add time to their 6 year degrees.