To Whom It May Concern: I am a practicing small animal veterinarian and small business owner who employs twelve citizens in Dayton, Ohio. Our practice currently offers clients prescription medications from our practice or a written script. A carbon copy of each written and authorized script is kept in each patient's record for the patient's well-being. A script is a confidential medical record between the client and the veterinary care provider that should not be shared, manipulated or duplicated. By issuing a written script to the client, the client is accepting responsibility for and supposed to mail in the script or hand deliver it to the pharmacy of choice. Our practice has also spent numerous hours on hold with local licensed pharmacies calling in medications on behalf of clients' pets. It is our position that a client has the right to fill medication for their pets at their discretion, but a veterinarian should not be held liable for medications filled outside of his/her office. Clients are also asked to sign a waiver each year and have their pet examined by a licensed veterinarian at least once every 12 months before a written script is issued. Receiving multiple phone calls from online, out-of-state and catalogue-order pharmacies harassing a veterinarian to authorize a script by phone, fax or email, where the script may be duplicated or altered multiple times without the veterinarian's knowledge or consent, is amoral and unethical. Our practice has also been contacted numerous times by online pharmacies, who fail to report to our staff that the client is listening to the conversation. When the client hears the script will be issued in writing for them to retrieve from the practice and not authorized by phone, some members of the public have become hostile, threatened legal action and switched medical records. In many cases, the online or out-of-state pharmacies are using a veterinarian's license and DEA number to justify the sale of a medication. Why does the FDA have a warning on their website about the dangers of online pharmacies using false, misleading or counterfeit, outdated, mislabeled, incorrectly formulated, or improperly made or stored medications http://www.fda.gov/animalveterinary/resourcesforyou/animalhealthliteracy... These same companies have caused irreparable harm and gravely disrupted the veterinarian-client-patient relationship. Some online and out-of-state pharmacies have issued medications without the necessary authorization from a veterinarian for the sake of profit. Many human pharmacists carrying veterinary prescriptions are not well-versed on the medications, appropriate application or side effects in pets. When used or filled improperly at pharmacies other than a veterinary practice, clients become upset with the veterinarian. Veterinarians should not be held accountable for educating clients and the public about the potential dangers of any medication ordered, used or filled outside of a veterinary clinic. "Caveat Emptor": Let the buyer beware! Until the federal government truly regulates and enforces stricter penalties against unscrupulous (pet) pharmacies who are using false, misleading or counterfeit, outdated, mislabeled, incorrectly formulated, or improperly made or stored medications, there is no way to fully protect the consumer, veterinarian or patient.
Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201 #560891-00049
Hills and Dales Veterinary Clinic
Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201