Submission Number: 560891-00410
Received: 9/13/2012 2:44:59 PM
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I have several concerns regarding HR 1406- Fairness to Pets Act. I beleive that ultimately it will be the veterinarian/animal connection that will suffer the most. Most of my day is spent diagnosing, discussing, treating and prescribing for the animal population. Vets do a tremendous amount of client education with medicine in hand. We know our suppliers, know the medication's effect on animals, know the dosage, the side effects,complications, how to give it when the animal won't take it, and how to communicate/recognize some of the very often subtle signs of trouble with the medicine. We don't just have the owner's check a box on a form that shows them declining or accepting counseling, nor do we just staple a prefabbed generic product insert onto the medicine. We, as veterinarians, are in the unique and very important position of helping clients understand what their pets may do in response to or problems with medicines. Do you think a big chain drug store employee even knows anything about dog, cat, horse, bird, reptile, ruminant, etc. physiopharmacology? Do you think they are able or willing to step out from behind the counter and verbally discuss all the intricacies of these meds for their pet who can't speak and is relying on the veterinarian to guide the consumer/pet owner? I don't think they will.
I would prefer to spend this vital time educating clients and not writing out a prescription, having the owner sign a document saying that I have written said document and then provide an electronic confirmation of such. It is unneccesary, way to time consuming and burdensome on the practice of medicine. It is also redundant in that the American and State Veterinary Medical Associations already have very specific language that requires vets to write prescriptions when asked. Indeed, the American public is inundately daily by ads on tv, internet and radio about filling pet med prescriptions. There is not a day that goes by that I dont send in a fax to an internet company or drug chain for a prescription. People know. Consumers utilize these sources all of the time. It often takes them days to get a prescription that I have stocked on my shelf. We have had to stay competitive with our prices for all of our services and products not only with other vets but these fly by night pharmacies for years. Many times we've had people get medicines from pharmacies for which we never wrote prescriptions. Occassionally you hear stories of fraudulent/conterfeit meds as well. I do think it is inappropriate to charge for writing a prescription. And I don't know of any place that does that. Market forces, over a very short period of time, would and does certainly shift business away from businesses such as these as consumers are very knowledgeable. I believe that the current proposal is more a push by large pharmacy stores to simply increase foot traffic with no regard to pet health,the human-animal bond or the importance of the veterinary-client-patient relationship. As you can see, it is very hard to explain the intricacies of the science, reliance and communication dynamic that is, daily, an integral part of veterinary medicine. I don't want that communication and relationship to suffer or to be stiffled by these unneccesary proposals.