Submission Number: 560891-00674
Received: 10/23/2012 6:15:23 PM
Commenter: Nicole Phillips
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
As a fairly recent graduate, I can understand the possible conflict of consumer freedom of dispensing veterinary medications only from a veterinary hospital. However, there are many factors to consider as large corporations enter the realm of veterinary pharmaceuticals.
1. The majority of pharmacists are NOT trained in comparative pharmacology. In my experience, pharmacists at local pharmacies have imparted INCORRECT information MANY times to clients regarding their pets. If pharmacists are to begin filling veterinary scripts, there MUST be some regulation as to certification or training in the veterinary field. There are a large number of nuances regarding dosages and appopriate formulations in domestic animals versus humans. I do not impart medical information to human clients as I am not trained in that field and it is illegal. I expect the same courtesy.
2. Veterinarians do not have National Provider Identifier numbers. A DEA number is not required for noncontrolled substances. On numerous occasions I have had trouble getting local pharmacists to fill my prescriptions using my state veterinary license - they insist on a NPI or DEA number, which I do not have.
3. There are many drugs that are used for humans and pets. I would argue there are a larger number that are veterinary specific that I use on a daily basis. These are not stocked at human pharmacies. Also, the dosages of a human drug I may require for a 200 gram avian patient are not available at a local pharmacy. So I am still supposed to provide a written prescription though I am the only local facility that can provide the medication appropriately and in a timely manner?
4. If pharmacists are appropriately trained, I have no problem providing a prescription and often give owners a verbal choice. However, I find it ridiculous to have to provide a written prescription for a medication even if I am filling it in house. This will enable clients to double fill a presciption.
In conclusion, our clinic has a good working relationship with some local pharmacists who have taken a special interest in the veterinary field and exhibit professional habits when filling medications and speaking with clients. Our clinic also uses compounding pharmacies frequently for unique needs. Unfortunately, this is not always the case at other establishments and I fear for my patients if appropriate training and certification is not implemented.