Submission Number: 560891-00563
Received: 9/28/2012 5:52:55 PM
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
This bill is a very bad idea for the American public for three reasons. Reason number one: qualification. Veterinarians are trained and licensed to diagnose and treat animal illnesses. This is what they do every day. They know best what their patient needs and they know best what their client will actually do (treatment compliance). They are doing their best job when they know their patient will receive a quality medication - one that has been manufactured, shipped, received, prescribed and administered appropriately - from an educated, instructed and accurately warned client. This bill is bad for the American public because gaps in care will develop, owner compliance will drop, patient suffering will rise, and client unhappiness will abound with confusion on whom to blame.
Reason number two: community support. These bills are always about money - who gets it now and who wants it instead. So let's chase that dollar. Beyond being the American public's best resource for consistent, compassionate, informed and accurate pet care, veterinarians are local. More importantly for this discussion, private practice veterinarians are local businesses. Economic studies performed in 2002(Austin), 2004(Chicago), 2007(San Francisco), and 2008(Grand Rapids) by Civic Economics have found that for every $100 spent locally (e.g. your private practice veterinarian), as high as $68 remains local. Spend that same $100 in a chain or national retailer (e.g. Petmeds, DrsFosterSmith, Wal-Mart) and only $43 remains local. Said another way, the latter spending habit results in 37% less revenue for our local communities. According to this FTC workshop, that would be a loss of up to 2.5 billion local dollars. This would hurt employment, education, roads, parks, hospitals, and I would imagine ultimately elected officials if we believe the system works. This bill is bad for the American public because it will directly and materially harm local communities.
Reason number three: the American consumer's pocketbook. The veterinarian's cost to provide quality pet care has increased astronomically in the past 10 years. Veterinarians are complaining, the American public is complaining, no one is winning. In order to keep pet care costs "down" for the American public, private practice veterinarians must have diverse revenue streams and varied profit centers. Revenue largely stems from performing professional services and reselling manufacturer products. Over the years, as the American consumer has sought alternative vendors for their pet care products, they have seen their professional service pet care costs skyrocket. The veterinarian's hands are tied here. You can't get a $400 knee surgery and a $4 script from the same store for too long before it's a written script to go somewhere else and a $2500 knee surgery. I don't know if they will be offering knee surgeries online anytime soon, but until they do this bill is bad for the American public because it hurts their pocketbook.
In closing, most veterinarians support choice. Most veterinarians support their client's access to pet care products that are priced attractively. Most veterinarians do not support legislature that will tie the hands of the American public unknowingly and inappropriately. I believe this bill attempts to solve the wrong problem and do not support U.S. HR 1406.