Submission Number: 560891-00135
Received: 8/13/2012 3:07:36 PM
Commenter: Jennifer Bull
Organization: Delmar Animal Hospital
State: New York
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
First of all, I am shocked that distribution, consumer choice and price competition is such a priority concern. While the last decade has brought many diverse retailers into the distribution of veterinary drugs, I have never found a client that was refused a written prescription or pressured to buy only veterinary products. As a matter of fact, we go out of our way to direct clients to the least cost, responsible supplier, when one is known. I am glad this is under discussion, because I have several concerns about the supply and cost of drugs hampering my ability to supply THE BEST MEDICINE.
I am waiting to find a human physician office that functions as conveniently as most veterinary offices manage. My clients can get an appointment for sick or well care in well less than a week's time, be seen by the doctor, have any lab work or imaging done at the same time and place, and be on their way with medicine or diet recommendations in less than an hour and at an average cost of $126. And we can take care of you no matter what your pet insurance or if you have none!
My first concern is why can human pharmacies supply human or veterinary medical products for veterinary patients, when I cannot? Several useful medications have come out with veterinary products, often priced well above the human counterpart. I can only legally buy and prescribe the veterinary product, but if I write a script I can send the client to buy a medically interchangable product at a much better price. Why can't I buy and resell these human generics and provide my clients with both a good price and convenience. The product that irks me the most is neomycin/polymyxin/dexamethasone eye ointment. The veterinary eye ointments have sky rocketed in cost over the last 3 years. I can only buy the veterinary generic product at a cost of $13.87 yet Walmart can sell the human generic product at $4. I cannot legally go to Walmart to buy the product and stock it for my client's convenience and I certainly cannot get it from human distrubution to sell for a competitive price. So 5 years ago, I could sell the veterinary product in my office for approximately the same cost as local pharmacies provided the human product, but now I have to send my clients on a 20 minute car trip, often with a patient that rarely enjoys car trips and should not sit in a hot car, to the pharmacy. The other product is meloxicam, a human arthritis drug that works well in large dogs. Many of the veterinary arthritis drugs are $50-75. For awhile, I could get and supply this generic for $15-20 month. There is now pressure from the producer to not sell to veterinary distributors. I can get the veterinary product, Metacam, for the smallest patients, but not carry the equivalent for the larger patients?
If I do supply a written prescription, it is up to the consumer to find "the best buy". Prices vary dramatically between online sources. Many online sources require a delay in starting the medication, because of shipping time. I have had two clients report back that online sources provided them with clearly counterfeit products. I have found the prices from reputable sources, whether the veterinarian, in town pharmacy or responsible online pharmacy, are often comparable.
My last concern is about human pharmacist safety. Xylitol, a sugar substitute used widely in diabetic and sugar free products, diabetic and childrens MEDICATIONS, is highly toxic to dogs. If I send a prescription and the client requests a flavored liquid, will the pharmacist recognize that xylitol is toxic?
I think veterinary medicine is doing a stellar job of providing their patients with safe, reliable products and their clients with the best combination of convenience and fair pricing, despite federal and state regulations, whims of big pharma/distributors, and recent appearance of retailers who want a market share, not a relationship with a pet owner to benefit the life and longevity of their pet.