Submission Number: 560891-00679
Received: 10/24/2012 11:02:57 AM
Commenter: Robyn Limberg-Child
Organization: Riverview Veterinary Center
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Regarding the proposed Fairness to Pet Owner Act, as a new owner of a veterinary private practice, I am alarmed at the intent behind this law and strongly oppose this on numerous grounds. As a veterinarian, it is my ethical and legal responsibility to verify that treatments for my patients are followed as directed, and the most certain way to do that is to dispense medication that my research and study has deemed to be the best option for each pet. Part of that responsibility also says that if I am unable to provide the best medical option, I have a legal obligation to prescribe from an outside source an appropriate medication, again based on my knowledge and study of the available pharmaceuticals. As well, for clients who choose to price shop, I already have a legal obligation to offer them a written prescription to allow them to purchase prescription drugs elsewhere. Having to take the time to fill out a prescription for for each and every prescription that I fill--in a given day this might be as few as 10 or as many as 40 prescriptions--even if dispensed here from my pharmacy, would be not just a minor inconvenience, but would add an entire level of paperwork and time usage to our already busy days, as well as having to retain copies of prescription forms will tie up storage space that is at a premium in many practices. If each script takes a minute to write, by the end of a week I have wasted as much as 3 hours of my or staff time to fill out unnecessary paperwork--time that will end up costing my clients more as my in house pharmacy charges will have to be increased to take this lost/unbillable time into account. This act is redundant--pet owners already have the legal right to request a written script to price shop, and those clients who trust their veterinarians typically opt to purchase their scripts from our in-house pharmacies. this is not only more convenient, but it also allows for more timely commencement of necessary medical treatment. If a client opts for a written script, leaves my office, has to go home and drop off the pet, then go to a pharmacy, submit their script and wait for it to be filled (and hope that the pharmacy has the appropriate medication in an appropriate dose for a companion animal, most of which are considerably smaller than the average person). As well, if there is a problem with the medication, where does the owner go for help? To me, if I did not dispense the medication and cannot verify that the correct drug and dosage was dispensed? To the pharmacist, who is trained in HUMAN pharmacology, not veterinary services?
Another concern is that the additional time and expense of having to provide written scripts for all medications will mean that in turn, I will have to raise my pharmacy prices to cover the additional cost. In short, the clients who opt to purchase from me will be penalized because of the paperwork I or my staff have to complete. With current laws already allowing those few clients that wish to price shop to request written prescriptions, this law is unnecessary and redundant and does nothing to protect consumers but does add an unnecessary inconvenience and hardship to small business owners such as myself. I am strongly opposed to this proposal and hope that our lawmakers will fully consider the ramifications and prevent this from becoming law.