Submission Number: 560891-00142
Received: 8/15/2012 7:50:36 PM
Commenter: Chris Duke
Organization: Bienville Animal Medical Center
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
With regard to the discussion of any new rules governing dispensed medication to pets, as a group of practicing veterinarians, we at Bienville Animal Medical Center see no valid reason to change a direct eye-to-eye relationship we as veterinarians have with our clients. Our seven-member group we responds to clients as consumers all day every day, prescribing medications for the appropriate circumstance and thoroughly explaining these medications in each case. We DO service requests for our clients who wish to obtain these medications through other sources-whether these sources are from e-commerce, telephone marketing options or retail pharmacies. We are happy to oblige when clients ask for written prescriptions, telephone or fax approvals for these alternate market veterinary prescription sales. To go any further than current policies in effect (literally writing a prescription for each script for each pet for each transaction-even if it ends up as an inside sale to the veterinary clinic), is unnecessary duplication of effort and time. We understand that your position is to assure "fairness" to pet owners on the subject of where they purchase their pet medications. In our humble opinion, the current policy our practice abides by is fair and equitable to all pet owners, as we approve of the medium of sales they ask for as consumers when they ask. We DO NOT decline client requests, unless (1) there in no client/pet relationship with our clinic, (2) there is an inappropriate, unprecendented request (in which we call the clients to discuss the issue), or (3) in the case of heartworm prevention, siezure medication or thyroid medication, the pet(s) are due for testing. Perhaps a sytem like ours is the template that needs to be adopted nationally. In the interest of free enterprise, we strongly advocate that veterinarians remain the first point of purchase for veterinary prescriptions, since we posess the knowledge of how the medications work from our formal veterinary schools and continuing education. Therefore, please count our group as a veterinary clinic that opposes legislation to change the foundation of what makes our veterinary profession in America the best in the world: open client-patient-veterinarian relationships. Please do not create unnecessary steps that would be a disservice to our profession and only serve to bolster the bottom line of those outside our profession!