Submission Number: 560891-00159
Received: 8/23/2012 12:23:26 PM
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I strongly oppose HR 1406. I have no problem with the idea of Veterinarians being prohibited from requiring the purchase of a drug at their clinic (and clients therefore being able to take a written prescription elsewhere). However, the advent of online pharmacies has significantly diminished the ability of veterinary practices to gain much needed income from the sale of medicines. While in itself this is no completely bad thing, as it forces the profession to make competitive prices, WE MUST ALSO RECOGNIZE that a veterinarian taking the time to choose appropriate medications/treatments, doses, dosing frequency, etc. is something veterinarians SHOULD be able to charge for (i.e. their time). HENCE THE WRITTEN PRESCRIPTION FEE. Otherwise we end up spending a lot of time filling out paperwork (our time) so that clients can go elsewhere, to the eroding detriment of the small veterinary business. Furthermore, absolving external pharmacies of any liability associated with failing to appropriately fill a prescription (putting liability back onto the prescribing veterinarian) is RIDICULOUS! How can a prescribing vet, having been made to forcibly write (lose their own chargeable time) a prescription and hand it over to a lay client to hand to a 3rd party for filling be responsible for a mistake in filling made at another facility? I implore lawmakers to see sense and hope that the veterinary profession will take a stand at such a gross attempt to infringe on the rights and privileges of the veterinary profession while trying to hold veterinarians responsible for the mistakes of others. Pricing competition is a good thing but NOT LIKE THIS!