Submission Number: 560891-00248
Received: 9/4/2012 2:10:08 PM
Commenter: Michaele Oberbroeckling
Organization: VitalPet Kings Crossing Animal Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
This is a letter I wrote to my congressman regarding H.R. 1406. I thought I would send the FTC a copy of the letter, since it addresses some of the issues you will be discussing at the workshop. Thank you.
I am writing to you regarding H.R. 1406, the Fairness to Pet Owners Act. As a veterinarian, I have many concerns about the unintended consequences should this bill be passed into law. First, when asked to do so by a client, veterinarians already have the ability to write a prescription or call in a prescription to a pharmacy of the client's choice, so the legislation is not necessary.
If veterinarians were required to write a prescription for each patient they see (and many patients require more than one medicine), it would add a burden and an indirect cost to each veterinary visit, which would ultimately need to be passed on to the client at some level.
Beyond the act and time of writing the prescriptions, there would be the additional burden of educating clients about using the prescriptions wisely, and making sure the medication is dispensed appropriately. For instance, obtaining thyroid medication through a human pharmacy for a dog presents several problems. First, the dose required for a dog is about 10 times the dose for a human (dogs, of course, are a different species than humans and thus metabolize this medication differently). When I have in the past written a prescription for a pet for this medication, invariably the pharmacist calls me up concerned that the pet will be overdosed on the medication. I then have to educate the pharmacist on the differences between dogs and humans with this medication. Meanwhile, the pet owner is caught in the middle and doesn't know quite whom to trust.
Secondly, there is one brand of thyroid medication supplied through a veterinary supplier that delivers consistently better results in dogs than any other thyroid medication on the human or veterinary side. We have researched the issue and have documented the results with our own patients, thus we stock our pharmacy with this medication. This is the best medical decision for our patients. With this medication, cost is not the primary factor to consider, rather it is the health of our patients. The average hypothyroid dog in our practice receiving thyroid medication from us would incur a cost of around $20 a month for the medication or even much less, depending on the size of the dog. Not being able to control the dog's thyroid level with the best medicine would likely cost the client much more in monitoring bloodwork, recheck exams and dosing adjustments, in addition to leaving the dog with unresolved symptoms due to a less than adequately regulated thyroid gland.
This is just one issue I have with the proposed legislation, but it highlights one of the main concerns of veterinarians, I believe. As much as I respect pharmacists professionally, they did not study animal medicine or pharmacology in their training, and thus would not be able to accurately or adequately guide consumers with respect to medication dosages, side effects or interactions between medications in their pets. Veterinarians understand that many of our clients are facing harsh economic realities and we are willing to work with them to provide cost-effective treatments for their pets, but not at the expense of their pet's health and well-being.
I urge you to vote against this legislation, as it is redundant, and would add an extra burden to veterinarians without providing additional benefit to veterinary clients and patients.