Submission Number: 560891-00694
Received: 10/25/2012 8:00:43 PM
Commenter: Alison Ladman
Organization: Wilmington 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 would just like to comment on how my hospital handles prescription drugs for pets. We provide 20 to 40 minute appointments for examination of a pet and consultation with the pet's owner. When deciding on a prescription medication, there are many factors taken into consideration: the pet's problem, laboratory results, owner compliance, ability to medicate the patient, past experience with the problem at hand, and also cost of the desired treatment. Sometimes I decide to prescribe a medication that we have available in our hospital's pharmacy. Many times I decide to prescribe something that we will call in to a pharmacy of our client's choice. Many times the client and I decide to utilize a compounding pharmacy to obtain more accurate dosing or better compliance. Where the prescription comes from is of little importance to me. Our doctors happily sign off on internet pharmacy prescription requests and will happily tell a client about the availability of free antibiotics from the local supermarket. Sometimes we use our knowledge and experience to determine that the medication sitting in our hospital pharmacy would be the best choice for a patient because the prescription can be started immediately (with our staff administering the first dose before the pet walks out the door), because we are certain that the client has purchased the recommended medication, because our staff and doctors have educated the client on the use and side effects of the prescribed medication, because we are familiar with the dosing of the medications available in our pharmacy, and because we readily know which dosage formulations are available in our pharmacy.
There are many pitfalls to writing a prescription for every medication we prescribe. Some of the concerns are: COMPLIANCE (Will the owner actually pick up and use the prescription?); AVAILABLE DOSAGES AND FORMULATIONS (Every pharmacy stocks different dosages and formulations of medications. It is impossible for us to know what is available at every local pharmacy and write the correct prescription. Human pharmacists are not trained to substitute or change dosing instructions for pets.); STAFFING ISSUES (With every prescription that is questioned by a pharmacist, we will need to have staff or doctors available to answer the pharmacists' questions. We will require more staff to record the prescriptions and the conversations in the medical records); TIME (Writing a prescription for every medication recommended will increase the time that is required in the exam room, thus increasing the fee that the client will have to pay for the doctor's time).
As things stand, we already focus our practice on the exam room, the consultation experience, the diagnostics, and the procedures. We have very little emphasis on our in-house pharmacy for revenue, but would like to continue to have the freedom to prescribe quickly and freely as we see fit for each patient. We would much rather generate our revenue from practicing medicine than filling prescriptions. We request that you not legislate how we provide service to our clients.