Submission Number: 560891-00187
Received: 8/28/2012 1:18:33 PM
Commenter: Kimberly Kahn
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
I am writing to express my concerns regarding H.R. 1406, the “Fairness to Pet Owners Act of 2011”. This bill would require veterinarians to provide a written copy of a prescription to a pet owner, whether or not the pet owner was going to get the prescription filled by the veterinarian him/herself. It would also require veterinarians to provide written notification that pet owners can fill prescriptions at a veterinary clinic or an off-site pharmacy.
As a veterinarian, I am concerned that this bill would not provide a benefit to pet owners, while it would place a burden on veterinarians. Currently, standards of practice (as set forth by the American Veterinary Medical Association) include providing written prescriptions (or approving prescription requests made online) for pet owners who prefer to fill prescriptions at off-site pharmacies.
Requiring that a written prescription be provided in all cases, whether or not an owner wishes to use a written prescription, places a burden on already-busy veterinarians. It would take a considerable amount of time (and create the opportunity for error) for me to provide written prescriptions for all of the prescriptions that I dispense each day. In addition, it would be a waste of paper to write unnecessary paper prescriptions for each prescription filled.
I always honor pet owners' requests to have written prescriptions, phoned-in prescriptions, or approval of online prescription requests. I hope that most other veterinarians adhere to this standard of care. I don't believe that it is appropriate or helpful to legislate mandatory written prescriptions, when many if not most of those written prescriptions would end up discarded (or, worse, filled inappropriately by a pharmacy after the prescription was already filled by the veterinarian him/herself).
Most pet owners are aware already that they can get prescriptions filled at pharmacies or online, thanks in part to widespread advertising by online pet pharmacies. Requiring that veterinarians provide written notification of this fact is redundant and wasteful.