Submission Number: 560891-00692
Received: 10/25/2012 6:40:47 PM
Commenter: Jim DeBell
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
After attending the FTC Pet Medication Workshop I was able to better understand many of the concerns voiced by members of the pharmaceutical manufacturers industry, the on-line/catalog and retail pharmacies, the veterinarians and the consumer. Unfortunately many issues were not addressed and it became apparent to me that the controversies that exist are far more reaching than simply "pet medications". Even the introduction became a half-hour infomercial (pictures and quaint stories) about the Director's pet. Multiple other participants also took the opportunity to praise their personal pets and the humane organizations they have helped over the years. We all love and relish the time with our animals but this was to be a frank discussion about trade, consumerism and safety. The initial tone implied that it's a subhuman profession - not real medicine. We were only discussing Fluffy and Sparky and certainly these medications aren't different than the real drugs they use in the human field, are they?
My take :
Pet medications was never defined and after the second panel discussion I asked the moderator what we were discussing -her answer- anything for which you write a prescription. I mentioned drugs like alprazolam, phenobarbitol, and tricyclic antidepressants and suddenly her look changed from "what a silly question" to one of deep concern. These are real drugs with real consequences and this is why we have the FDA.
Veterinarians are in the middle of a battle between manufacturers and pharmacies. We are innocent bystanders being manipulated by both industries - one stroking our ego with "you are the most qualified" and we become walking/talking advertisers for their products (since it soley in our hands). And the pharmacies who imply that we are financially motivated by our drug selection and that we use coercive tactics to convince the owner to purcahse from us.
There was no aasurance that the big pharmacies will sign non-competitive agreements to carry only certain manufacturers line or one drug in a class of drugs. They may buy in such volume to limit the availablity to the veterinarian. The pharmacies would possibly "cherry pick" only the popular drugs so that we would have to carry drugs with less volume. If you want to play in the pet pharmacy realm you need to be able to provide all medications in the form and quantity that we prescribe.
Using the Fairness to Contact Lens Consumer Act as a guideline there was talk of passive verification which would allow a pharmacy to fill a prescription if it was not denied within 8 business hours. The ability of the consumer to ask for a medication on-line, the pharmacy to wait 8 business hours and then ship is quite concerning. Imagine what a field day a teenager would have if schedule 2,3 and 4 drugs were just a mouse click away.
The time dedicated to writing and documenting in the medical record all prescriptions, handling the volume of solicitations and verifying the legitimacy of the pharmacy would be extremely demanding on each veterinary practice. I'm sorry that they charge shipping for purchases under $39, but don't coerce me or ask me to change a prescription just to satisfy the client's or filling pharmacy's request. We can dispense three Heartgard at a time - why can't the pharmacy.
One of the biggest concerns is the possile inability of the prescriber to charge for a prescription. Is this not comparable to the "shipping & handling" fees that on line or catalog pharmacies
charge? Why not charge the pharmacy for this service - they are the ones using our staff's phone time/fax lines and they don't have to pay for the prescription pads/DEA licenses.
Finally, veterinary practices are not allowed to fill another vet's Rx yet a client can take that same written rx to any pharmacy to have it filled. Level the playing field and create a "restricted pharmacy license" to allow us to dispense to veterinary patients other than our own.