Submission Number: 560891-00180
Received: 8/27/2012 8:57:10 AM
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
As a long time veterinarian and practice owner, I have seen the expansion of veterinary medicine from neighborhood based small businesses to now include mega-practices and corporations. Still and all, the profession is mainly small businesses. These businesses operate from the passion of veterinarians and their staffs to serve the animal owning public to the best of their abilities. The focused intent of giving clients and their animals the best care we can provide has always included writing prescriptions. HR 1406 is both unnecessary and potentially dangerous for the animal owning public.
No one enters into veterinary medicine to become rich. Often, veterinarians find themselves in the position of lowering fees or outright gifting services to clients in the interest of animals’ welfare. This despite the costs of employing staff, maintaining facilities and the educational investment each veterinarian makes to become a veterinarian. Originally, veterinarians had to concoct their own medications. Then, commercially available medications allowed better quality control, but still the veterinarian was the dispenser of the medication. Veterinarians were the dispensers because they were in the unique capacity of being willing to buy and maintain pharmaceuticals for animals and knowing how to safely and accurately use the medications in animals. Animals are not little people and all medications which animals use cannot safely be interchanged between species. HR 1406 has very little to do with animal welfare or consumer protection and quite a bit to do with corporate greed. This bill looks to impose added expenses on veterinary practices while taking safety out of the use of veterinary prescription medications.
Telephone lines, staff, facility maintenance, education, professional time, none of these things are free. Physicians for humans are not forbidden from charging for writing prescriptions. Unless corporations want to neutralize competition from veterinarians and absorb all pharmaceutical profits themselves, why would prescriptions not be allowed to be charged for by the veterinarian for the real costs involved in producing a written prescription. In-clinic pharmacies are part of the bottom line for every veterinary practice; these pharmacies provide convenience for the animal owning public and a safe source of species appropriate medications. Pharmacists for humans do not receive the essential veterinary pharmacologic information necessary to safely dispense animal medications. If the argument being made is that the veterinarian is responsible for getting the correct information on a prescription, then what safeguards the veterinarian against an incorrectly filled medication? In this last year, I personally have had four incidents of animal medication being filled incorrectly. Three of those animal patients became very sick and one died. The extent of the pharmacists’ liability seemed to be reimbursement for the wrong medicine and replacement cost of the animal. What replacement cost do you think a client who owns an animal that is a fifteen year long companion that came from a shelter and is neutered receives? Does twenty-five dollars seem about right?
Pharmacies for humans that also stock veterinary medicines do not maintain all veterinary medicines. The medications which they maintain are the most frequently prescribed and medications which will most quickly be sold. If these corporations are allowed to by fiat restrict veterinarians from competition, the consumers would be the losers. Veterinarians will be in less of an economic position to maintain the medications which the human pharmaceutical dispensers do not want to keep. Being small businesses, veterinarians are not able to buy in the same bulk to receive discounts or promotions from major manufacturers. So the field is not starting out level anyway. The corporations that are seeing a profit center in veterinary pharmaceuticals are national corporations. It is interesting that these corporations are trying to bring federal action for their advantage with the adversary being the corner veterinarian.
If HR 1406 were to become law, the cost of veterinary care for the consumer would rise as veterinarians were forced to shift their costs and profit centers. The consumer would be inconvenienced in their ability to obtain animal medications. And, the safety of administering medications to their animals would be compromised as those medications were being dispensed by pharmacists for humans uneducated in veterinary pharmacology.