Submission Number: 560891-00116
Received: 8/3/2012 6:03:29 PM
Commenter: Margie Garrett
Organization: ARK Veterinary Services, Inc.
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
For two major reasons, I would like to retain the use of a pharmacy without the force to send my clients to a human pharmacist and spend an inordinate amount of time filling out multiple sheets of paperwork when I am writing in my history what the animal requires for pharmaceuticals.
1) I keep a record of when that animal gets exactly what that animal gets. The pharmacy will not change the prescription and I will be able to provide the client what they need on the spot assuring better compliance. Human pharmacists are not forthcoming with those records for our records, and we do not have the insurance companies keeping records as happens in the human species field. I frequently have not been called back with historical records on refill compliance.
2) I will not be able to afford to provide a pharmacy to have the advantages of good record keeping, good compliance, and choice of medications without a pharmacist substituting another product.
Veterinarians have been required to maintain a good client/ patient/ doctor relationship and follow to the letter of the law that patients are seen prior to prescribing or suggesting medical care. Veterinarians are required to maintain good records and should be able to follow the medical and medication history. To keep all of this affordable, veterinarians must maintain the income stream to keep the staff and hospital in good working order. The health of our industry is important to the Federal Trade Commission, I am certain. We would need to significantly raise our exam fees to cover the extra paperwork and time involved to do this special order fee or limit the consumers' choices of where they get their health care for the animals because there would be no way that many practitioners could sustain a business. The law profession is charging for telephone consults, and hospitals are able to charge excessive amounts for supplies within their hospitals. Is this the direction that we are to go?
The human pharmacies that are privately owned are few and far between and corporations that dictate what their pharmacists can sell are routinely changing my prescriptions to medications that are "on the shelf" vs. special ordering for a client. I have had my signature sold by a commonly advertised "pet med" pharmacy to a state in which I am not licensed and only found out because a doctor called to ask why I had written a prescription for their client. I had not.
While I am aware that I will be forced to buy prescription pads that can be stolen and written for any product and I am aware that I must duplicate paperwork to comply with this corporately driven law, I ask if it is truly for the client that you would rule. Waiting to order or driving and waiting for a prescription is not inexpensive for the animal, the patient, or the client. It would work out for the client to have healthy veterinary practices to go to fo a longer period of time than to have only a few practices.