Submission Number: 560891-00223
Received: 8/30/2012 10:49:16 PM
Commenter: Gary Goldberg
Organization: MVMA Member
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I am licensed in 5 states including Massachusetts but work for the federal government in a regulatory capacity. This bill serves only to interfere with the veterinarian - client - patient relationship. The use of prescriptions should be an option not a mandate made to separate the veterinarian from her or his role in this relationship. If wholesale or online pharmacies want to assign a specific veterinarian hired by the company to share in this relationship and bear full or partial responsibility in potential litigation from the lack of affect of the drug prescribed when a client decides to have the prescription refilled vs. a re-examination or additional testing - then this would preserve the relationship. Even though my mother, father, one uncle, and 2 great uncles were pharmacists, they would all (except for mother who is alive today) would roll over in their graves if they were arware of a nonsense bill like this one. My uncle who was a former President of the N.Y.S. Pharmaceutical Society knew that there is a specific role for pharmacies and that for veterinarians. When commercial pharmacies destroy the veterinarian - client - patient relationship just because a client wants to bargain for discounts in prescription pricing this only encourages uninformed clients to practice practitioner hopping and put the animal at risk. The veterinarian must be able to have some leverage to demand that the patient be returned for re-evaluations, additional testing, and proper preventative care in addition to emergency care when the patient is not responding to prescribed treatment or in the case of an emergency. The awkward relationship resulting from this bill would put the animal at tremendous risk and interfere with the veterinarian's ability to fully be aware of all of the prescribed medications that the animal receives from client hopping activities. This bill does not place any responsibility on commercial or online pharmacies for mistakes in filling prescriptions as well as refilling problems that may occur. Coming from a family with a long line of pharmacists and having worked in my parent's pharmacy since a very young age, I know that pharmacists have a great deal of difficulty with bills that provide the client more flexibility to avoid maintaing a Doctor Patient relationship let enough a Veterinarian - Client - Patient relationship. I have no vested interest in this issue other than to support more colleagues in providing the best service to the animals.