Submission Number: 560891-00311
Received: 9/11/2012 3:08:06 PM
Commenter: Jerry Underbrink
Organization: Animal Medical Clinic
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
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I have been in the veterinary business since 1974. I have owned my own practice for the last 35 years. There are many veterinary businesses through out our country that have had slow & steady growth over the past 35 years. Both the client & the veterinary related businesses have benefited from this growth. Why has this growth occurred? Veterinarians have continuously met or exceeded their client’s expectations each time they have visited the practice. The value of the service & sales to each client exceeded their expectations; otherwise they would not have returned. How did all these veterinarians accomplish this? This was achieved through focus, dedication, caring, determination, maintaining current knowledge, while adjusting to the client’s ongoing request for change & increased quality of medicine. What was the driving force for this achievement? It was “supply & demand”! How was supply & demand achieved? Slow & steady adjustments were made per request of the customer.
All of this was accomplished with minimal “refereeing” by the federal government but with ongoing attentiveness of each individual state government and constant surveillance by both the state veterinary medical examiners & the state veterinary associations.
When evaluating whether a new law should be enacted it is essential to analyze the consequences of such a law. Does it solve the problem it intends to solve? Or does it just initiate a complex network of events which require time and tax money with no real benefit for the veterinary profession or its clients.
Technology changes have given the opportunity for corporations to offer a “new wave” of opportunity for veterinary clients. Now new companies have been formed such as Pet Med, Allivet, PetCare Rx, etc. I personally have no problem with any company taking advantage of a business opportunity. This is what our capitalistic society is all about. Competition is what breeds improved service, improved efficiency, new products, etc. It is what America is all about. It is the reason America has prospered all these years.
These new veterinary companies are changing the direction of in-house veterinary pharmacies and they are obviously successful. Why are they successful? The simple answer is because many veterinarians are eliminating their in-house pharmacies & writing outside prescriptions. Why are they writing these prescriptions? Many veterinarians have decided to focus more on providing primary veterinary services. Some have decided it is not valued to remain competitive with these new corporate pharmacies. While some have decided to keep an in-house pharmacy to help better serve their clients. There is nothing wrong with this. Again it is called supply & demand that is leading the change! Now, all of these new changes have occurred without intervention by the government. It has not cost the tax payers any money at this point. If this is the trend & supply & demand is leading the way, why since the birth of veterinary medicine does someone suddenly decide it is time for federal governmental intervention? This is the big question?
Left alone, this entire pharmacy prescription situation would continue to be lead by supply & demand until a balance has been reached. It would do all of this by slowly shifting the jobs in the needed direction instead of causing these changes to occur acutely & causing acute layoffs of veterinary pharmacy employees & veterinary reps for large pharmaceuticals. Acute changes lead to chaos & unemployment. They also commonly lead to unintentional negative ripple effects. Acute changes also have the potential to lead to a “rebound” of increased veterinary pharmacy prices once they are in the control of large corporations. Let supply & demand determine the speed.
There is no proven long term benefit to the veterinary client, there is a greater chance the cost benefit to the client will be neutralized by increased veterinary service fees if you enact this bill.