Submission Number: 560891-00115
Received: 8/3/2012 5:06:41 PM
Commenter: Elizabeth Templeman
Organization: Garden Ridge Animal Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I am a small animal practitioner. I have no problem writing prescriptions if a client requests one or if I want to prescribe a drug that I don't stock. I am concerned, though, that a law that forces me to give a written prescription may not be in the best interest of my patients or may waste my time, my clients' time, and pharmacists' time.
In several cases when I have written prescriptions, the pharmacy or client will call me to tell me that they don't carry that drug, so I have to either find a substitution or have the client come back here where I do stock the appropriate drugs and sizes. I really don't feel that a pharmacy should dictate which drugs I prescribe.
I also have concerns that pharmacists have not been trained in animal-specific pharmacology. I once had a pharmacy try to dispense hydrocodone in combination with a drug that could have been deadly to my canine patient, and the pharmacist did not know that. When I dispense a drug from my clinic, I provide my client with written animal-specific drug safety information, and I tell them about side effects, specific administration concerns, and drug interactions. What will the human pharmacy be giving my clients for support?
I think it is a waste of time and resources to require us to write a prescription when we are filling a prescription through our hospital. I keep my prescription pads closely guarded, and I worry that having more written prescriptions floating around will lead to tempting either employees or clients to falsify or alter prescriptions (especially of controlled substances.) Potentially, I shall have to order another printer and more software to handle them electronically, as we try to be a paperless business. I shall have to otherwise take the extra time to write the prescription, fill the prescription, and type into my medical notes that a written prescription was provided. This all seems very redundant when I could offer the client the choice of medication or a written prescription.
Thank you for taking the time to consider my opinions.