Submission Number: 560891-00002
Received: 7/2/2012 9:10:26 PM
Commenter: Scott Emch
Organization: Well Pets
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
To whom it may concern,
The biggest concern I have about the government "mandating" that veterinarians "have to give a client a prescription" is that it takes a tremendous amount of the oversight ability/responsibility away from the veterinarian. Currently most veterinarians stock many of the prescription medications that they prescribe to their clients. The veterinarian is aware of the source of those meds, how they have been handled and has a relationship with the ditributors and the manufacturers of those medications. We are responsible for educating the client, and act in many ways as both pharmacist and doctor.
Many of my clients have had online pharmacies send us requests for medications. A large number of these requests are from pharmacies offering "really low prices" and upon further examination, many of these pharmacies are not licenced to do business in our state, and several are selling foreign labeled products that should not be legally sold in the U.S. I have always honored requests from legitimate pharmacies, but it takes staff and doctor time to review the records and fill out the forms these pharmacies send us. This is not time we can give away for free, so we charge a "records review and processing fee" to compensate for the cost involved in filling these prescriptions. If I had just given the clients a paper prescription, many of them would have purchased product from pharmacies that were acting illegally and I suspect might be getting product that had been tampered with or improperly handled.
Repeatedly I have asked internet pharmacies to divulge their sources for their products. Almost universally, they can't tell me where they get their medications but assure me that they are "legitimate sources". Now, if any of my clients ask me where I get my medications, I can site the date of purchase, the distributor, and any other information they may request. If these pharmacies have "legitimate sources", then why can't they tell me who they are? If a pharmacy can't or will not tell me where they are obtaining their medications, is it inappropriate for me to decline authorizing a prescription request?
Until the FTC comes up with some form of reliable licensure for internet pharmacies and aggressively prosecutes fraudulent pharmacies (neither of which I have seen them do), they should not be telling veterinarians how to act in the best interest of their clients. There is also the law of unintended consequences - a principle that comes up time and again when government tries to "regulate" businesses in order to "create savings". Veternary hospitals must make a profit in order to stay in business. Many veterinarians utilize the profits made from the sales of medications to keep the cost of basic services lower. If you remove or minimize the profits from medicine sales by forcing veterinarians to give that business to other vendors (who have no stake in the patient's welfare, only a stake in taking the profits), then those profits will need to be generated by increasing the costs of office visits, procedures, etc.... Therefore, the clients will merely pay more for those services, or worse yet, end up declining to get them - ultimately compromising pet welfare.
I ask that as you deliberate these issues, you take a broader view of the pet health industry than just taking knee jerk actions in order to satisfy businesses with large lobbying bases. I do not believe that 1-800 Pet Meds and WalMart have the best interest of pets in mind, they are looking at potential sources of profit - period. Veterinarians work incredibly hard and have enough difficulty being economically successful without government mandating that we institute business practices that are financially harmful to us.
Dr. Scott Emch