Submission Number: 560891-00391
Received: 9/13/2012 11:38:40 AM
Commenter: Jacqueline Reed
Organization: Teegarden Veterinary Clinic
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Dear Federal Trade Commission,
I am writing in opposition of HR 1406 – Fairness to Pet Owners Act. As a veterinarian at a small animal private practice, I prescribe and treat animals with various medications on a daily basis. I strive to practice quality medicine with the best interests of both my client and my patient in mind. I believe this bill would impede on my ability to do so. An unfortunate case of mine speaks volumes to this issue.
“Buddy,” a 6 year old Labrador retriever, was presented to me this summer for a history of dramatic weight loss, anorexia, and wounds that would not heal. I diagnosed “Buddy” with a fungal disease called Blastomycosis, which is caused by inhalation of the fungal spores into the lungs. Pulmonary disease develops and the organism can spread throughout the body to various other organs, such as the eyes, bones, skin, lymph nodes, and brain. Without proper treatment, the disease can be fatal. By the time I saw “Buddy,” he was in very bad shape and needed treatment instituted immediately.
Treatment consists of a long course of antifungals and supportive care. The best choices for antifungal treatment include two different drugs, Sporanox or Fluconazole. Sporanox is the brand-name of Itraconazole and is very costly. Unfortunately, the veterinary profession has seen too many treatment failures to recommend using the generic form of Itraconazole. Whenever writing a prescription for Sporanox, we as veterinarians must be very specific that it is not substituted with generic Itraconazole. This is a question that I have received repeatedly from pharmacists because they do not understand why I would not prescribe the less expensive alternative. If a mistake is made in filling the prescription, it could have a very negative impact on the outcome of the animal’s health.
Finances were a concern for “Buddy’s” owners, so I elected to treat him with generic Fluconazole, which is a less expensive alternative to Sporanox. My staff made phone calls to the local pharmacies to determine which pharmacy offered the best price for the medication. I wrote the prescription, gave it to the client, and instructed her to fill the medication at the local Wal-Mart Pharmacy and start “Buddy” on the medication that day. Much to my client’s surprise, the Wal-Mart Pharmacy staff misquoted the price of the medication by around ten times! What was supposed to have been $20 for a month’s worth of the medication, was now well over $200. She elected to take the prescription to Kroger to be filled since their pharmacy offered a better price. However, the Fluconazole had to be ordered by Kroger as it was not in stock and would not be in for five days. Whenever I called to check on “Buddy” later that week, I was very shocked to find out that he had not been started on the Fluconazole yet. His condition had further deteriorated without the medication and he was euthanized.
“Buddy” is a very sad example of lack of owner compliance and communication from the local pharmacy. It was imperative that “Buddy” was started on the medication immediately and ultimately that failure led to his demise. Fluconazole is not a medication that my clinic carries as it is only prescribed for this specific disease. For most prescriptions, my clients leave the clinic with their pet’s medication in hand and I believe this greatly helps with client compliance. My biggest concern is that “Buddy’s” case could become much more common if veterinarians are required to write prescriptions for all medications. Owner compliance and lack of knowledge of veterinary pharmacology by pharmacists is detrimental to my profession. I urge you to please consider these issues whenever making your decision on this bill.
Jacqueline L. Reed, DVM