Submission Number: 560891-00151
Received: 8/21/2012 8:53:25 AM
Commenter: A. Mark Green
Organization: Mallard Creek Animal Hospital
State: North Carolina
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Summary: The net effect of the decrease or loss of prescription sales through animal hospitals is an increase in the cost of total animal care to the consumer.
A small business such as an animal hospital requires an average transaction fee (gross income divided by number of transactions) to keep its doors open as a business. In an animal hospital, that number is generated by professional services and sale of products including prescription drugs. At present, a client may buy their products from the animal hospital or get them from a retail source. Mass marketing including TV and print advertising promotes the retail option and North Carolina state law requires a veterinarian to write a written prescription when requested. The net effect of the loss of product sales, including prescription drugs, through animal hospitals is an increase in the cost of animal care to the consumer. The average transaction fee has to be met for the animal hospital to remain a viable business. If that fee can not be met by a combination of revenue from goods and services, but only services, the price of services will go up. The consumer is now paying more money to more places for the same amount of goods and services that in the past were provided for at one location...the animal hospital.
Comments to questions asked in July 9 notice:
How are medications distributed? By animal hospitals, retail pharmacies, Internet suppliers
Business retionales: From animal hospital perspective-compliance. We know that owner leaves with the medications.
Competition? As in any business, competition lowers prices and improves service or you loose the business. Consumers have more options so to remain a supplier, you have to be competively priced or offer a unique service.
Other issues: Advertising is not always truthful. Supply chains are often questionable when diverters and over seas suppliers are involved.
Prescription Portablilty: Prescriptions are very portable from a veterinarian to a licensed pharmacist. A concern is that written prescriptions may not be filled or filled in a timely manner once they leave the prescribing animal hospital. As state before, a loss of prescription revenue in animal hospitals will raise fees for service and thus total expense for animal care to a consumer. The free market competiton (Internet, big box stores, etc) has created a competiton in pricing. Passage of H.R. 1406 may stop animal hospitals from stocking prescription products for resale if it becomes non profitable or too much trouble to process paper work. Indirectly forcing animal hospitals out of product and prescroption sales may be the agenda of non aniaml hospital interested parties.