Submission Number: 560891-00654
Received: 10/19/2012 12:21:14 AM
Commenter: Cynthia Lunney
Organization: Portage Animal Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I am OPPOSED to a federal law (Fairness to Pet Owners Act) mandating that written prescriptions be provided to veterinary clients for each drug prescribed.
Most clients I see daily value convenience, trust in the products dispensed and the care that veterinarians provide in educating each family about these medications over the real or perceived cost savings of shopping around a written prescription. Those clients that don't, already ask for and graciously receive a written or called in prescription.
Veterinarians almost invariably serve their patients and families before themselves. Those that don't, find themselves with fewer patients and families to serve. As an example of this, my practice has already responded to consumer demand by lowering our prices on many pet medications regularly advertised by large retailers and price matching for medications whenever requested. This SELF DIRECTED action enables me to maintain the trust inherent to my doctor-client-patiet relationships. I do not believe the goverment needs to require this action, free-market reponse will weed out those providers that do not offer these options.
I also have significant concerns as an advocate for animal health. Veterinarians have very specialized education and experience that makes us uniquely suited to manage pet health. Pharmacists are also highly trained, but in human medicine, which can be markedly different than animal health. The burden of this understanding of animal health is not one that pharmacists outside of veterinary medicine are prepared to handle. In addition, comparing the distribution of most animal health medications to contact lenses is short-sighted in at least one significant area. Many medications prescribed for pets each day are for acute or emergency illness. As such, the need for medication is typically more immediate than the comparison contact lenses. Wasting the time required to fill a prescription at a second location or, even more, through a mail order pharmacy would clearly be detrimental to pet health.
Finally, as a small business owner in a service profession, it is imperative that I provide cost-effective and timely service to my clients and their pets. Requiring this burdensome procedure will adversely affect my doctor-client-patient relationship through increased time required and confusion for pet owners, leading to dissatisfaction and increased costs of care outside of prescription drug needs. The perceived benefit to the pet owner will likely be off-set by increased costs for other aspects of pet care and a loss of faith in veterinary care.
Cynthia Lunney, DVM