Submission Number: 560891-00156
Received: 8/21/2012 8:39:57 PM
Commenter: Peter Lugten
Organization: Basic Pet Care Animal Hospital
State: New York
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
1) I believe that most veterinarians realize that clients can obtain medicines on- line and at drug stores, thus veterinary prices are necessarily competitive without need for legislation.
2) Maintaining a pharmacy in the vet. clinic is a service to clients that provides convenience, and, at times, availability of medicines that are needed immediately. There are expenses involved, including discarding expired drugs. Legislation that reduced the ability of the clinic to pass on these costs would curtail the ability of the clinc to provide the same level of service. (Especially in the case of smaller, 1 or 2 doctor clinics, which are already at a disadvantage in obtaining volume pricing from the manufacturers) This would be detrimental to the majority of clients, who like the service the way it is.
3) HR 1406 appears to contain provisions that would mandate that the veterinarian write out prescriptions to all clients, requested or not, with written disclosures, elctronic verifications, and obtaining signed consents for every prescription. This would be simply impossible to fit into the time available during busy morning or evening surgeries. This would result in everybody having to return 24hours later to complete the paperwork and pick up their medication. Which would be a huge, disastrous disservice to veterinary clients. Just imagine the chaos, frustration and anger this would generate in the waiting room, and the intolerable pressure it would put on the clinic staff that had to deal with it. And it would add hours of extra work after closing to get the paperwork ready.
4) As a profession veterinarians are known for their tendency to discount or even give away products abd services to clients of reduced means. HR 1406 would sharply reduce the ability to do that.
5) HR 1406 would sharply increase the cost of doing business for small animal clinics and hospitals. This cost would have to be recovered by increasing other prices. Therefore, it is easy to predict that the "Fairness to Pet Owners Act" would result in both higher veterinary costs and poorer service to pet owners. I believe pet owners would be best served by leaving alone the status quo.