Submission Number: 560891-00060
Received: 7/26/2012 8:55:28 PM
Commenter: Michael Trapani
Organization: Bodega Bay Veterinary Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
A legal requirement that veterinary practitioners provided a written prescription on all occasions that a prescription is made will do nothing to protect consumer rights. We are already required to provide these prescriptions upon request. We are also required to give a written notice to every client that they have a right to obtain a written prescription and to fill that prescription at any pharmacy they choose. We are also required to post signs in our offices advising clients of their right to obtain all medications from the pharmacy of their choice.
Should veterinarians be required to provided a written prescription in all cases, even when the client chooses to fill the prescription in our offices, the requirement will do nothing but create confusion. The client will quite reasonably believe that holding a written copy of the prescription means they have authorization to obtain a second prescription. Indeed, the written prescription, though already filled, will appear no different to a pharmacist than an original unfilled prescription.
This proposed regulation is poorly considered. It will create an unnecessary burden and expense on small, family-owned businesses while providing no legitimate benefit to consumers of animal health care services. Animals owners already have the right to a written prescription and are repeatedly advised of that right on every visit to the veterinarian's office. This regulation would serve only to increase the cost of providing animal health care; these costs will necessarily be transmitted to consumers, who will receive nothing to which they are not already entitled.