Submission Number: 560891-00345
Received: 9/12/2012 1:15:33 PM
Commenter: Amy Johnstone
Organization: Liberty Veterinary Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Pet Medications Workshop, Project No. P12-1201
I have been a veterinarian for over 20 years and a practice owner for over 14 years.Over the past 2 decades pet medication distribution has changed radically. To the clients' detriment, prescription medications have been largely removed from our hands. So many drugs are available through other sources that the consumer loses the benefit of the doctor's counsel for their pet. In my experience many prescription medications are filled through online pharmacies without receiving a prescription from my office. In essence, this allows the client to prescribe for their own pet. The average client does not have the knowledge or training to wade through all the products and their ingredients to understand what is best for their pet. In many instances, clients purchase flea and tick preventatives and do not understand that they have not purchased nor are protecting their pet against heartworm disease. This is a grave disservice to our clients and pets.
When ordered from online pharmacies, clients also may receive products that have been repackaged, mislabelled and sold through third parties which negates any pharmaceutical company guarantees. Often the client will search an online pharmacy for a recommended product and be redirected to a cheaper and /or inferior product that I would not recommend.Consumer protection is a huge issue in these situations.
A completely separate issue is the effect on American small businesses, such as most veterinary practices. I employ about 30 employees, a mixture of full and part time people. My practice is slightly larger than average for a 1-2 doctor practice. I cannot compete with the drug warehouses that exist now. Many drug warehouses sell products I stock for less than or slightly above what I can purchase them for because they can buy in such huge bulk and manipulate pricing based on demand and popularity of a product. My clients who currently buy drugs from my office do so either out of loyalty or convenience at the time. Fewer and fewer purchases are made through my practice yearly. Each time I lose a sale my practice loses income and prices for my professional services have to be increased to balance out the loss. My employees have currently been on a wage freeze for over 2 years as a direct result of lost income, and decreasing veterinary visits per client per year. This may eventually drive individual veterinary practices out of business as corporate national chain veterinary practices benefit from the ability to make bulk sales.
The requirement for me to hand every client a written prescription merely exacerbates these problems. We are always happy to write prescription if a client requests one. But requiring us to do that may prompt the client to fill their medication needs elsewhere when they would have purchased them from my practice. Also prescriptions given to clients to fill elsewhere are often never filled reducing client compliance further. Clients are much more likely to give medications properly if they walk out of my door with product in hand accompanied by proper instruction.
With all due respect I hope someone actually reads these comments and considers the veterinarians viewpoint.