Submission Number: 560891-00273
Received: 9/7/2012 9:43:56 AM
Commenter: Matt Nelson
Organization: Maple Ridge Veterinary Clinic
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
As far as online pharmacies that offer veterinary medicines at a discount price, they are able to do that because they either buy the product for cheaper (which most manufacturers say is not happening) or they get it from questionable sources. Why would I want to write a prescription to a questionable pharmacy that can sell it for LESS than what I can buy it for? That raises serious quality concerns for me! If I am to be the advocate for the pet, then I always encourage the pet owner to either look elsewhere for the medicine (and sometimes veterinary services if they persist in getting it from an unreliable source) or I will match the price even if it is what I buy it for (I won't match it if it's less than I can buy it), letting the client know I value our relationship more than anything. Having worked at a couple of clinics and being on the board of our local emergency clinic where other vets are shareholders/board members, I know my pricing markup is very standard for the industry, so I'm not any more expensive than any other vet.
Regarding the Fairness to Pet Owner's Act, I have no problem whatsoever informing the client that they can fill prescriptions anywhere, but I will then go on to tell them that these brick and mortar, as well as internet, pharmacies are just that, pharmacies. Most of these pharmacies do not have a veterinary pharmacist on staff. The differences between human and veterinary patients are immense, and human pharmacists are not trained whatsoever in the differences between humans and animals, let alone the difference between animal species! In discussing different medicines with our local pharmacists, I often times find myself explaining why there is such a difference in dosages, or even the fact that certain medications were able to be used in animals. The pharmacists' surprise at these conversations leads me to worry that if there was a medication issue, and the pet owner contacts the pharmacist instead of us, that pet owner would get a much different interaction than if they had contacted the veterinarian. With this leading to potential liability issues for me as a veterinarian, I do not feel comfortable leaving a human pharmacist as a player in the veterinarian-client-patient-relationship because their lack of veterinary knowledge is blatantly obvious. As pet's legal status changes in this country, the liablitiy issue will be huge, and I would hope that if a pharmacy were to fill veterinary prescriptions, they would be required to have a veterinary pharmacist on staff at that location!
I think the requirement to write a prescription for every drug even if you fill it in house is very excessive. The time required to do so would be very detrimental in a busy practice! Time wasted equates to revenues lost, or not realized. That is also very detrimental for most veterinary practices where the revenues are not that great to begin with. I do not have a problem posting this information in a very visible location, and let the client initiate the conversation if they so choose.