Submission Number: 560891-00099
Received: 8/1/2012 5:30:22 PM
Commenter: Kristen Christian
Organization: Columbus Countryside Veterinary Clinic
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I have several concerns about possibly making it mandatory to provide a written prescription to all clients for pet prescription medications:
Veterinarians are the best ones to actually dispense pet medications, and they and their staff can best explain the medications compared to a human pharmacist.
While any pharmacist can actually sell medication, they may not have a specific brand name that a vet clinic carries(sometimes brand name drugs work better than generics)that may have benefits for pet use (coated tablets, chewable tablet options, etc.). Sometimes generic drugs are a viable option and should be considered at the time of each prescribing. But a generic drug should NOT be automatically substituted instead of a brand name if a veterinarian specifies as such, as happens frequently in the human market.
I have a problem with veterinarians losing more revenue to on-line pharmacies (many of which have low ethical standards when dispensing medications) or even to Walmart/Walgreens. I understand that the economy is tough, but the real problem is that each veterinarian sets their own pricing--some have huge mark-ups, and then others have reasonable mark-ups. It seems more reasonable that the veterinary community should get together on what an acceptable mark-up is regardless of a clinic's location.
Veterinarians are not allowed to fill prescriptions for humans because of the knowledge that the human pharmacists add to the equation (of the human medications). Human pharmacies should not be allowed to fill animal prescriptions either for the same reasons.