Submission Number: 560891-00690
Received: 10/25/2012 2:12:30 PM
Commenter: Ken Pawlowski
Organization: K & K Petcare dba Banfield Pet Hospital of Folsom and Lincoln
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
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I am in absolute opposition to H.R.1406. I own two veterinary hospitals and have serious concerns about both the business ramifications and more importantly the risks to pets’ health.
As a small business owner this bill would have a significant financial impact. In my busier hospital we see 50-60+ patients a day. While not every patient gets a prescription some may get five or six. If we assume that the average patient gets two prescriptions that is 120 a day. Even if it only takes thirty seconds to write out a prescription that means an hour of a doctors’ time that she is not able to see more patients. Seeing fewer patients affects the compensation for the doctor, the profitability of the pet hospital and the ability for sick pets to be seen in a timely manner.
While veterinarians do prescribe a variety of pills and other oral medications, many of the prescriptions are for ointments, shampoos, lotions, parasiticides and other topicals. These along with many of the oral medications are veterinary specific products that are not available at local pharmacies. The only other place to get these products is through on-line pharmacies. Even if it is the proper medication and it comes from a legitimate pharmacy the treatment would be delayed by at least days or even never started if the client does not take the medication with them at the time of their appointment slowing the healing process and prolonging the suffering of the pets. In addition to the delay there are major concerns about on-line pharmacies. There are only one or two legitimate pharmacies that obtain their medications directly from the manufactures, the rest obtain them through unethical “gray” markets, foreign labeled and/or even counterfeit products. The FDA even warns against using these pharmacies and produces literature to provide to clients (see attached pamplet) and the U.S. Justice Department has investigated Google for profiting from ads from illegal on-line pharmacies (see attached Washington Post article). Most people do not know, nor take the steps to determine, which pharmacies might actually be legitimate and likely make a purchase base strictly on price. One of the biggest flags of an illegitimate pharmacy or inappropriate medication is a significantly lower price (see FDA pamphlet).
In order to assure our patients receive timely and appropriate treatment veterinary hospitals maintain comprehensive in-house pharmacies at a cost of tens to over a hundred thousand dollars. Some of the items stocked are low use, but necessary, and will often expire on the shelves. Even a well-managed pharmacy will result in losing 5% or more to expired medications. As products are low profit margin items any loss significantly impacts the hospital. If a hospital loses sales to outside pharmacies this would likely result in increased losses from expired medications thereby necessitating increasing the price for other medications and services and potentially impacting pet owners by preventing them from seeking or providing appropriate care for their pets. In addition to this, veterinary hospitals would likely need to streamline their pharmacies to reduce this impact resulting in carrying fewer products, as well as, increasing the chance of medications being out of stock. Both of these situations would result in pets not being treated in the most appropriate or timely manner.
Unless we get legitimate, local pharmacies that can provide the specific, genuine medications that day so that a pet’s treatment can be started immediately, the best place for their owners to get their medications is from their veterinarian. California veterinarians already provide a written prescription at no cost if asked, and display a statement stating such.
This bill would have serious negative impacts on the health and suffering of pets, as well as, affecting the business of veterinary hospitals, most of which are small businesses that are having increasing difficult times.