Submission Number: 560891-00010
Received: 7/13/2012 3:41:31 PM
Commenter: Jeffrey Godwin
Organization: Animal Medical Clinic
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I understand that the FTC will be holding a public workshop this fall on the distribution of pet medications. I would like to comment on that subject.
Most medications that are developed for pets are done so by a handful of pharmaceutical companies that spend enormous sums of money researching, developing, and getting FDA approval for these products to help veterinarians and pet owners solve serious health issues. Once a drug is approved, the manufacturers then spend a lot more money educating veterinarians about the uses of the drug, as well as possible side-effects, contraindications, etc. Usually, this information is complex, and requires the kind of extensive education provided by a veterinary medical degree in order to interpret the research in light of the specific situation of an individual patient.
Historically these medications have been distributed through veterinary practices because pharmacists were not interested or educated in their use. Now that is changing. Corporate pharmacies are very interested in selling these products; however, my experience is that pharmacists are still not educated on the use of these drugs in animals.
Because of the history of the distribution of these drugs, the almost universal model of drug dispensing involves the veterinarian dispensing medications directly to the consumer. It is expected by the consumer, and is very convenient for them. We do see an increasing number of requests for prescriptions so that the drug may be purchased elsewhere, and we ALWAYS comply cheerfully with that request. If a client can get something elsewhere for less than I can sell it, I completely understand that. State law already requires us to give prescriptions if requested, so there is already a remedy in the event that some practitioner somewhere tried to force clients to purchase from him.
There are some pharmaceutical companies that limit the distribution of their products to veterinary practices in which there is a valid doctor-client-patient relationship. There is a very sound reason for this. As I mentioned before, the practice of medicine requires not only a broad knowledge base of the science of medicine, but also specific knowledge of the patient. When medications are dispensed by the veterinarian, that is the best assurance that the client will be adequately educated on what to expect from the medication, and what to watch out for. As more intermediaries are inserted into that relationship, the chances of communication breakdown and adverse events significantly increase.
Because of this easy access to prescriptions upon request, competition in the marketplace is alive and well. I regularly check the advertised prices of my competition, and make a point of staying competitive. It is definitely in my best interest to keep medication prices reasonable, because if clients think I am “ripping them off” on medications, they are going the think I am doing the same on the services I provide as well.
What I can’t understand, or support, is the proposal that veterinarians be required to write a prescription for EVERY drug we prescribe, even if the client is purchasing it from us. It takes a significant amount of time to write proper, legible prescriptions. Any regulation that would require us to write prescriptions, hand them to the client, then have the client hand it back to us in order to get the medication is absurd, and just the type of government overregulation that many of us in the business community complain about all the time. Regulations such as this decrease productivity, make this country less competitive, sap resources that could be used for salaries, benefits, or investment, and eventually lower the standard of living for all of us.
Thank you for the opportunity to comment on these issues.