Submission Number: 560891-00293
Received: 9/10/2012 9:28:13 AM
Commenter: Mary Sheridan
Organization: Maine Veterinary Medical Association
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I am in opposition of mandating written Veterinary Prescriptions for the following reasons.
1. It is unnecessary. Written prescriptions are already freely provided to clients.
2. The Client compliance of filling prescriptions is exceedingly low.
Here are a few scenarios…
I had a canine patient named Rex with polyarthritis due to Lyme disease. Rex couldn’t walk or eat; he lay around shivering with a fever. I assured the client that within 24 hours of starting the medication Rex will be back to normal with no visible stiffness, pain, nor fever. I was out of the particular medication I wished to send home with Rex’s owner. To encourage compliance, instead of handing him a written prescription, I called in the prescription into the pharmacy of the client choosing.
Two days late I gave my client a call. I asked him, “How is Rex?”
He tells me, “Well Doc he’s no better but I suppose once I start the drug he’ll turn around. I figure I’ll pick it up on Thursday so he’ll be alright by the weekend, for hunting.”
Several weeks ago I had a patient, a cat with heart disease and fluid in her lungs. I treated her in the hospital and by the end of the day she was breathing easier and able to go home. Heart disease is a complex illness. This one required three different drugs. I sent the owner home with one medication and called in a prescription for another. The third medication was an Over-The-Counter drug. Two days later I called the client. The cat was still only receiving one medication. The one I sent home with her owner. That cat was receiving sub-standard care.
In the past I sent out a staff member to pick up a prescription for me so the client can go home with a complete medical protocol. I regret I didn’t do this for this case. The owner found the cat dead on her bed a week later. Most likely the cat’s arrhythmia was the cause of death. I now carry that medication at my hospital.
3. Written prescriptions will encourage pharmaceutical internet sales. This would further the lack of client compliance. Ordering medication over the web is an obvious, considerable delay in treatment.
4. Other health care professionals are not mandated by law to write prescriptions. This proposal is discrimination against the Veterinarian.
For example: There is no legislation demanding that Optometrists must provide written prescriptions with every eye exam.
Mary Sheridan, DVM