Submission Number: 560891-00193
Received: 8/28/2012 3:00:17 PM
Commenter: Keith Niesenbaum
Organization: Crawford Dog and Cat 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
As a veterinarian licensed to practice in NY state, I am already required to provide a written prescription to a client wishing to obtain their medication from a source other than my dispensing pharmacy. We do so on a regular basis. Requiring us to write a prescription for a client, even if they are purchasing the drug from us directly will actually increase my cost of doing business and that is something that will be passed on to the consumer. We will need to take time to write the prescription, log the prescription, take the prescription back from the client if they purchase the drug from us, and I suspect, hold onto the physical prescription to prove that it was written. In addition, clients loose prescriptions and then we need to write duplicates. I also find that the pharmacists are ill trained to fill veterinary prescriptions and we often see inappropriate and even dangerous substitutions based on human medicine.
While I believe that consumers should be able to purchase their drugs from whatever approved and supervised pharmacy source that they wish, this particular bill does not appear to confer any advantage over the current New York State Law as far as consumer choices. I do believe that it is designed to decrease the ability of small practices to provide affordable care to our clients and will actually result in increased veterinary fees. In addition, once big pharmacy companies have put our pharmacies out of business, any savings that the clients have seen in the drug portion of their medical expenses will vanish and they well have higher medical/surgical costs as well as higher medicine costs.