Submission Number: 560891-00149
Received: 8/19/2012 1:51:41 PM
Commenter: Rachel Francis
Organization: Marion Animal Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
The cost and source of pet medications is an important issue. Here are the important points as I see them;
1. Labeled versus off-label use of medications.
2. The diverse pharmacokinetics among the various species, (and even in the breeds within the species!) of veterinary patients.
3. The transparency of manufacture, purchase, shipping, and storage of medications.
4. The issue of pet health insurance.
When my first daughter was 3 months old she had a low grade fever, about 102. I thought this was low grade as most of my patients run about 101-103. When she hit 103 she started trembling and we rushed to the emergency room. The neonatologist treated her with injectible medications in the emergency room, and then prescribed human medication for me to pick up at a local pharmacy. She did not offer to write me a prescription for a lower cost veterinary medication in order to save me money, nor did she advise me to try to get the nebulizer my daughter needed at the local pet store, where it might be cheaper.
While pets are not children, many similarities are present. Our national assocation, the American Veterinary Medical Association, requires vets to prescribe drugs labeled for animals. Off label prescriptions are allowed only if deemed absolutely necessary.
I would never even consider dispensing medication to people from my hospital; it is illegal in the state I practice in for the very good reason that special training is required to understand how different medicines interact in humans. Veterinarians are uniquely trained in veterinary pharmacology and in chemicals human pharmacists could not be familiar with including topical and oral pesticides. I know exactly what result I should be expecting in a patient and if the owner must refill their prescription with me I have a chance to discuss how the patient is doing before refilling it. A human pharmacist cannot be trained in all the pertinent questions for each medication. This helps the pet and insures compliance. I can also try to make sure the medication is going to the pet, and not being taken by the client. Providing pet owners with alternative sources of medications opens a dangerous can of worms for pet owners without health insurance, who may take their pets medication for their own ailments.
We all have been told pharmaceutical companies do not sell certain pet medications to internet pharmacies or to department stores. I have had many clients tell me the internet pharmacies and pet stores have told them the opposite. While it is easy for me to see where my medications come from via the trail of shipping labels and packing slips, and I can show these to my employees and clients, how can we see where other medications come from? Requiring transparency of all distributors and retailers of pet medications will only help the consumer, as well as the pets.
Most of my clients (certainly not all) have health insurance, which covers part or all of their own medications. Pet insurance is relatively new, but crucial to taking care of pets. Many pet insurances will not cover medications not purchased from the veterinarian because of the lack of oversight. If a labeled medication is recommended but declined by the client for a cheaper, off labeled medication the insurance company may not be able to cover the care after the off label medication is administered. In this situation a client is deemed "not following medical recommendations" and the expensive insurance they have been paying for is useless. Would pharmacies, or other companies selling pet medications pick up the tab for the pets medical care, if a medication they sold a client voided their insurance claim?
Thank you for considering my thoughts on this issue. I deeply love my profession, my patients and the clients I serve. I hope the Trade Commission will vote to keep the care of the veterinary patient in the hands of the veterinarian.
Sincerely, Rachel Francis