Submission Number: 560891-00197
Received: 8/28/2012 10:15:39 PM
Commenter: Douglas Humphrey
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
My comments are based on 12 years of experience as a small animal veterinarian and having been a recent president of the Harris County Veterinary Medical Association which represents the Houston area. My answers to several questions asked by the FTC are:
Some of my clients do ask for written prescriptions and I think many more are aware that they can get medications filled elsewhere. The majority fill their prescriptions at our office due to convenience.
Since most pet owners are not charged a prescription fee by their physcians, I think most veterinarians would not charge a prescription fee. I don’t think this denial would cause a problem. However, due to a lack of training and experience among pharmacists on pet medications, I believe there will be a number of mistakes made by pharmacies. I would like to be protected from liability for this and would like to have the right to ask clients to sign a waiver of liability. I also believe that we have a right and a duty to inform our clients about this risk because they may mistakenly believe that their human pharmacists receive training in pet medications and that they can expect the same level of expertise from a human pharmacy as they would get form a veterinary office.
More than just simply filling a medication, veterinary staff help counsel owners HOW to give the medications, what to do when a pet spits a pill out or won't sit still, what the most important medications are (if several are given), etc. No pharmacist or pharmacy technician will have that kind of knowledge or experience to help a pet owner with and so veterinary offices are best suited to dispense pet medications.
Increased competition would initially result in lower prices and more widespread availability of these medications. In the long run, however, I think it will not be as profitable as expected for pharmacies to carry a wide variety of medications. This will lead to human pharmacies only carrying the most common and profitable medications. This will lead to confusion among pet owners and veterinarians as to what medications are available at which pharmacies. It will also lead to veterinary hospitals carrying only the most expensive and least profitable medications which will reduce the income of important small businesses but allow national retail chains to reap the benefits of the law.
If 1406 is enacted, veterinarians will face the prospect of providing a written prescription and written disclosure about where they can fill the medications to each and every client which will require a huge increase in the paperwork. If we are required to write a prescription but a client chooses to have the medication filled at the veterinary office, then either we will have needlessly generated a written rx or the client will have access to extra medications (one Rx filled at the office and one written Rx the owner can fill). A problem I am already encountering with online pharmacies is that many pets have more than one owner or spouses or significant who do not share a common last name. This leads to confusion when a pet is under one name at our office but we receive a prescription request for a pet under the spouse's different last name.
I am not aware of any evidence of a need for HR 1406. Many of my clients would rather get their medications from us (a trusted source) and if not they have asked us for a written Rx.