Submission Number: 560891-00158
Received: 8/23/2012 10:38:11 AM
Commenter: Kevin 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 veterinarian licensed in the state of Texas. I, too am concerned with product safety, availability, and cost for pet owners. In the past few years, we have seen a very high number of medications removed from the marketplace for pets--including most forms of insulin, some pain and infection medications, and more. Further dilution of the sources of products will exacerbate this effect and I can foresee further loss of useful medications in my industry.
Human pharmacies (whether CVS, Walmart, or grocery store related) do not have veterinary trained pharmacists with proper safety and dosing guidelines for pet patients. Approximately half of the prescriptions I write to be taken to another pharmacy (for heartworm prevention or other medications) are returned due to the pharmacy not having the product on hand, being able to order the product at a significantly higher cost than I can provide it for, and they will not consider filling a prescription that does not match exactly as written. I personally do not know all about their products (like the WalMart brand of heartworm prevention) and cannot in good faith write a prescription for a product I am not comfortable with: when there is another product that has a proven history, proper efficacy and safety testing on file, then I feel this medication is the better choice for the patient.
The Walmart heartworm prevention, for example, refers the owner and pharmacist to the veterinarian if problems occur. Again, this is not a product that I sell/ use and am a little uncomfortable being 'in charge' of an outside pharmacy's products. The pharmacists are required to go through safety and proper medication usage with human prescriptions. Will this same training be provided to them to cover pet medications with owners as will. If not, then I will be providing that service as well--for a product I did not provide.
There are pharmacies that I work with that take pet care into consideration and will call/ discuss medications with me--overall I do trust pharmacists, but have reservations about their pet/ animal training.
If I am required to write a prescription for every medication, this will greatly slow down my daily routine of seeing patients and reduce proper treatment of these patients. For example, if I see a dog with an ear infection, there are often 4-5 medications that go home with the patient today. I can have these filled to go home with the patient and owner within a few minutes. Should I have to provide a written prescription for each of these as well? Should the owner have to take these to multiple pharmacies to have them filled? How many pharmacies will stock these animal specific medications? Most of these routine ones do not have a human equivalent (such as some eye drops and ear medications we use routinely.)
In closing, I will write a prescription for any client who asks--as long as they are a current patient, it is an appropriate medication for the patient, etc. Having to provide a written prescription for every patient and every medication would be a serious burden on my everyday work life. Without this in-clinic pharmacy, our business would suffer, which would cause an increase in pricing for other services.
Thank you for your consideration.