Submission Number: 560891-00229
Received: 8/31/2012 3:46:03 PM
Commenter: Eve Ryan
Organization: Beaver Lake Animal 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
I am appalled at the concept of the government dictating how professional doctors can practice medicine. The practice of medicine is under the jurisdiction of each state's practice act. Prescribing practices fall under the heading of the Practice of Medicine. The federal government has no place dictating what doctors can and cannot do in the practice of their profession so long as they are practicing legally under the laws of their state.
(1) The vast majority of practicing veterinarians, myself included, DO have the patient's safety and well-being as top priority. Most WILL provide a written Rx when asked. We WANT to be "fair to pet owners" because if clients are dissatisfied then they will not return. Success of a small private practice is built on good relations with clients. The use of generic drugs marketed for humans instead of animal drugs should be a decision made between the client and the doctor, after careful consideration of all the pros and cons, not a decision mandated by the government. Furthermore, there are many instances where it is unethical or just plain risky to prescribe a HUMAN generic equivalent (non-FDA approved for animal use) to an ANIMAL trade drug, but through this bill, the doctor would have to write the Rx anyway, despite the violation of the code of ethics, and would not even be allowed to have the client sign a liability waiver form. If I am going to accept liability for a patient's treatment, then I am going to have a say in what drugs I will and won't prescribe. The medical care of that patient is ultimately in my hands, and if treatment is delayed or altered while a pet owner is "shopping around" for the best price on a medication, then my patient's condition may suffer. After all, the VETERINARIAN is the ONE individual trained to understand the animal's physiology (which can vary greatly with age, breed, etc) and has the best knowledge of what drugs should be used.
(2) Pharmacists at retail stores do NOT have the appropriate training in animal physiology and pharmacology to appropriately advise pharmacy customers on their drug purchases. If there is an error in filling the Rx, or an adverse reaction, or multiple prescriptions being filled at multiple pharmacies, or questions on administering the drug, then there is an increased risk of harm to the patient when misinformation is received by the client. I would think, as a professional entity, pharmacists would be hesitant to accept the liability and risk of dispensing drugs with which they are NOT AT ALL familiar. If pharmacists are going to get into the market of dispensing pet medications, then training in animal pharmacology NEEDS to become part of their education system.
(3) Pet owners are looking for the cheapest possible way to provide for the needs of their pet, and the big-box retailers have found a way to not only capitalize on that demand with high-volume, cost-cutting bulk inventory, but then also use that same market demand to lure the customer into the store for additional purchases. Veterinarians are doctors, and these pet products are DRUGS. The retail market and the writers of this bill are treating this as a commodity, to be bought and sold. What is driving this bill is the shameless greed of the retail corporations who have discovered an untapped market. They do not have "fairness to pet owners" in mind, and they do not have safety to animal patients in mind.
(4) Individual veterinarians physically cannot obtain some of these drugs cheap enough to satisfy the consumer. It is a struggle to maintain a low markup to keep the cost to client down as low as possible while still earning enough to keep the business open. Once earnings from medication sales disappear, veterinary practices may be forced to increase the fees for basic exams or other services just to be able to meet overhead, and this wouldn't be fair to anyone. The only ones who will suffer are the pets, who won't come in for the care they need due to high costs.