Submission Number: 560891-00735
Received: 10/31/2012 11:22:11 PM
Commenter: D Thompson
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I am a licensed veterinarian, who like many others, is concerned about rising health care costs, medication safety, and an increasingly hostile small business environment. A bill sponsored by big business and requiring written prescriptions for every medication is burdensome (some days I can average 30 - 50 medications. Note these would all be written by me, not my nurse practitioner as there isn't one, and take time from my patients, time from phone calls, time from medical care and charting). It is also redundant- the AVMA supports written prescriptions and many states insist on it when a client requests and it's appropriate.
Of greater concern is safety. Even if part of this bill could be modified to require pharmacists to receive training in veterinary pharmacology (how much is enough?) there is still a lack of familiarity with pet/ veterinary medications. I have had licensed pharmacists refuse to fill vital medications because they assumed dosages were wrong (species difference from people), tell clients to use certain medications that were potentially fatal in certain species, substitute drugs without checking if they were appropriate for the species, etc. I have had patients wind up in the emergency room with insulin overdosages because licensed pharmacists insisted that the prescription dosage was wrong. Last week a licensed pharmacist told my client "insulin is insulin" which is woefully simplistic even looking at only human diabetics and grossly wrong when it comes to other species physiology- this is not the first time a pharmacist has encouraged a client to change insulin (they are not interchangeable). Other pharmacists have changed one form of medication to another which then made it more difficult to successfully treat that patient- these are factors i have already considered when i write the prescription. Often I need to counsel owners after they have heard incorrect or misguided information from a pharmacist. Online pharmacies have filled medications without authorization (sometimes for a pet that I haven't seen)- even to the detriment of my patients. Frequently, their prices are no better than the in hospital cost. And, in a few cases where an online drug is listed as >50% cheaper than anywhere else I can only conclude that there is likely counterfeiting or other fraud involved- which understandably makes me reluctant to write a script, for which I am liable.
Like the rest of us, pet owners prefer to save time. Being able to dispense from the hospital ensures a patient gets necessary treatment immediately, and in our office often
the nurses give the first dose demonstrating how to administer the medication. In more unusual species, this is beyond the scope of the average pharmacist. Does it really make sense to have the pet owner hand back to me a written prescription when they decide to have the medication filled in the office instead of the big box pharmacy?
Like many vets, I already spend time discussing medication options with owners and owners are aware they can get prescriptions filled elsewhere if they prefer and -as is frequently discussed-if there is an appropriate drug available for the species and medical problem. Cost is part of that discussion and we do everything to help a family find what fits their budget and still will be effective.
Let's not place more burdens on overworked and inadequately trained (in veterinary pharmacology) pharmacists by supporting this bill. Likewise, let's not burden harried small business professionals by redundant legislation driven by big business interests masquerading as consumer advocates. And, let's not be disingenuous and believe that consumers are magically going to realize substantial cost savings. Medications can be pricey and they have a base cost- most are not going to vary much regardless of purchase point, nor will most veterinary drugs wind up on the free lists.
This is a poorly considered legislation and I encourage you to vote against it.