Submission Number: 560891-00420
Received: 9/14/2012 12:59:00 PM
Commenter: Paul Clemente, DVM
Organization: Indiana Veterinary Medical Association
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
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The Indiana Veterinary Medical Association (IVMA) is pleased to provide our comments and thoughts in connection with the workshop scheduled to examine competition and consumer protection issues in the pet medications industry. The IVMA has been a member-driven organization for almost 129 years in Indiana.
It is current law in Indiana that if a client requests a written copy of a prescription from a veterinarian, they must comply (IC 25-38.1-4-5(d)). Thus, we believe that federally mandating a veterinarian to write every prescription request is onerous and not in the best interest of our patients and our clients. The treating veterinarian’s relationship with the pet owner is the most important component of the trusted veterinary-client-patient relationship. We know our clients trust our professional judgment and understand their pets’ well-being is our highest priority. For us, patient care always comes first.
Because of this potential change, leaving the client to fill their prescription adds inconvenience and exposure to incorrect filling/dosing of the prescription. By allowing this to happen, it moves the veterinarian further away from the care of the animal. Many clients currently use the veterinarian’s pharmacy saving them extra travel and time needed to obtain their medications at an off-site pharmacy, especially when they have their pets already with them!
Additionally, not all pharmacies, pharmacists, and online sites providing pet medications are created equal. In actuality, moving this service away from a veterinary practice could prove calamitous for the consumer, and our animal friends. This is because we are unsure how pharmacy stakeholders would understand their roles and responsibilities for counseling and educating clients when filling the veterinary prescription.
We firmly believe that clients have a right to choose where they obtain their pets’ medications. Our current state veterinary practice act and the Principles of Veter