Submission Number: 560891-00573
Received: 10/3/2012 5:36:10 PM
Commenter: Scott McCall
Organization: Animal Care Centers
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I am a companion animal veterinarian with 14 years practice experience. I understand the concern of the public for the availability of affordable prescriptions for their pets. The aggressive advertising by companies such as 1800petmeds has raised awareness on this matter.
I also know that some veterinary practices have had policies of refusing outside prescriptions when requested by a client. Our practice has actively opposed and avoided such practices.
I strongly disagree that there is a need for regulations requiring veterinarians to provide written prescriptions to clients for medications, even if the client chooses to purchase the prescription from that veterinarian. This type of needless regulation will only increase the overall time it takes to serve each individual client and ultimately, lead to higher costs for all pet owners in 3 ways:
1. The more staff and administrative time we have to take to write prescriptions, the more we will need to charge clients for each office visit.
2. Although many online pharmacies advertise lower prices, we find that our prescription prices are often significantly less than what internet pharmacies charge. Perhaps the FTC should investigate their claims of lower prices that they are aggressively marketing to an unknowing public.
3. We already write offer to our clients and write MANY prescriptions to outside pharmacies when a generic equivalent is available and medically indicated. We will continue to do so.
In closing, I do not believe that all veterinary practices and ultimately pet owners should be penalized for a problem that is only caused by a minority of veterinarians.
Scott McCall, DVM