Submission Number: 560891-00536
Received: 9/22/2012 11:07:15 PM
Commenter: Jim DeBell
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
The Veterinary profession has historically provided the most affordable and efficient health care system available. Where else can a patient be assessed, diagnosed and treated all within one day at one facility. Typically, one veterinarian provides all the diagnostics and procedures (surgical or otherwise) which would involve multiple referrals on multiple days in the human health care system. At the risk of sounding a braggart, vets and vet techs are pharmacologists, cardiologists, anesthesiologists, pediatricians, surgeons... follow with every human specialty... for every species but one, under one roof. The following discussions will show how any imposed legislation will jeopardize efficiency and affordablity for our clients and the safety of our patients
Financailly the costs incurred by mandating an already existant prescription portability will involve dedicating staff to oversee the legitimacy of the pharmacy, the documentation of the requests, and the time of the prescriber. Imagine the solo practitioner always attending to the walk in client, the phone and faxed requests all at the expense of the patient in the exam room or on the surgery table (scrub out to write an rx for the client who would already like to purchase the product from your office?) Want to kill rural vet practice - implement this legislation. Any proceeds generated from these sales provide local jobs. Those employees now dedicated for the paper trail of mandated prescriptions will now have their jobs in jeopardy due to the corresponding lack of income. In order to keep these employees the cost of services will undoubtedly rise. Veterinarians provide local employment and answer to the clients that make up that community. On line, catalog and gigantic mart stores answer to their stockholders.
Traditionally, veterinarians have never charged for a prescription. However, as any other service, to mandate that a charge never be allowed for this is unjustifiable. Just as a lawyer is allowed to charge for their time it would be unfair to disallow our profession to do the same with what is essentially a signed or verbal contract.