Submission Number: 560891-00362
Received: 9/12/2012 3:47:51 PM
Commenter: Karen Aultman
Organization: Inverness Animal Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
In the State of Florida, the Pharmacy Dispensing Rules require the veterinarian to provide a written script to the client upon request. As the State has already taken the lead and created its own legislation, it would be unnecessary for the Federal Govt to intervene. We have no problem writing the script if it is requested. But contrary to what many may think, we are also quite price sensitive and are cautious about what we charge for the medications that can be shopped(i.e. those that are available from human markets and internet stores). Most clients would prefer to get their medications at the time of visit and go home to care for their loved ones. They would also like to be able to call the dispenser(being their vet)when things are not turning out as planned to discuss the situation at hand and get a proper response. The pharmacist will not be able to do that. Our recent encounters with Big Box pharmacies have been filled with problems when prescriptions were modified without communication with us, not filled properly, or the refills were not posted to the script and the client was left without medication for their pet when it was needed. In an effort to capture more market share, Big Box is stretching the pharmacist in too many directions - be it giving injections, prescribing/dispensing of medication or,now, veterinary care. The issues of safety, fairness and competition are not an issue if left in the arena from where they came. We are concerned first and foremost with the safe and proper use of the medication we dispense and hold ourselves to that standard, as do our clients. Most of us will stay competitive and will charge accordingly because we are not all looking to get the most we can get for ourselves, but what we can do the most for our patients. Some things are just not broken. The veterinarian is still held in high regard because we hold ourselves to a higher standard. Those that have diverted have lost their way. The internet is not going away and the best way to straighten that out is to set and enforce stronger standards for them with regard to what they can or should sell, where they can purchase what they sell, and how they are held accountable. The same can be said for human medication. It is also important to remember that advancement in R&D for better medicine costs. That cost will have to be passed on, just as the cost for safety and control regulations are passed on to the end user. It is the cost of enterprise. If I have to suggest any change to our dispensing law in regard to prescriptions, it would be to allow for better portability within our State, Interstate, and among veterinarian practices themselves.