Submission Number: 560891-00092
Received: 8/1/2012 12:00:53 PM
Commenter: Daniel Randall
Organization: Foothills Veterinary Hospital, PC
State: South Carolina
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Consumers have a right to be concerned about the rising cost of prescription medications for their pets. Veterinarians who operate pharmacies as part of their practice should be equally concerned as well. The driving force behind the escalation in cost is the pharmaceutical industry and not the veterinary profession. Pharmaceutical manufacturers, faced with stiff competition on the human side and rising costs of research and development in bringing new products to the human market, have turned to the veterinary market as new source of revenue. Over the past 15-20 years the industry has gradually ratcheted up the cost of drugs to gauge the pet owning public's willingness to pay ever increasing amounts for the medications they need for their pets. Veterinarians have become a pawn in this whole process as a result of previously sacred exclusive marketing agreements with many of the manufacturers. The escalation in cost has affected heartworm prevention, flea and tick medications, veterinary labeled non-steroidal anti-inflammatories, and veterinary labeled antibiotics most significantly. Veterinarians are caught in the middle - paying the ever increasing wholesale costs for the medications we rely on to care for our clients pet's while trying to defend our fee schedule to consumers who are reluctant or unable to pay for the medication their pet's need. This occurs despite the fact that our margins on the products continue to decline as the wholesale price increases. Years ago the pharmaceutical industry made a deliberate choice to prey upon the strength of the human-animal bond, and as a result, the entire veterinary industry and the pet owing public suffers.
Additionally, I don't believe that increased competition from online pharmacies and human discount pharmacies represents a real and permanent solution to the price concerns. It may make lower margins on these products possible due to more sales through large volume discount outlets, but it introduces an increased level of risk for the pet. Pharmacists that deal almost exclusively with human medications are not familiar with the physiologic differences in drug metabolism between domestic species. Therefore, they are not adequately prepared to counsel pet owners on the risks associated with most pet medications. This is especially true with non-steroidal medications. Even products as common and safe as heartworm prevention have significant risk if administered to heartworm positive animals or in conjunction with other medications. The prescriber - in this case the veterinarian - is the most accurate, most reliable, most informed source of information for the pet owner and the only resource in the event of adverse reaction. If real solutions to the increasing price of care are to be found the search needs to begin and end with the manufacturers and the FDA. Alterations in their business model and the drug approval process must change before progress will be made.