Submission Number: 560891-00213
Received: 8/30/2012 2:38:20 PM
Commenter: Virginia Sinnott
Organization: Cape Cod Veterinary Specialists
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
Pet Medications Workshop, Project No. P12-1201
Veterinarians are regulated by state licensing boards that hold us to a legal and ethical standard generally higher and more broadly enforceable than any general penal law or code. While not every state practice act has an explicit code regarding providing written prescriptions, there are statues asking us to practice to a high ethical standard that is in the best interest of the patient and the client. These boards can thus hold the rare veterinarian that charges for a written prescription or doesn't offer the option of a written prescription accountable under these statues.
This bill will NOT create a novel avenue for holding veterinarians accountable for unethical prescription drug practices. What it will do is create needless paperwork for veterinarians and confusion for owners who often would rather get all their medications at the time of treatment. Veterinarians are already well regulated by the licensing boards and professional organizations, I urge the FTC workshop to consider that this bill serves more as a marketing tool for large corporations wishing to market veterinary drugs than an actual improvement in governance and oversight of veterinary prescription writing practices.
I am a practicing Emergency and Critical Care veterinarian and I provide written prescriptions whenever asked. I also volunteer any information I have on where to get a drug at the least cost, even if it is not at my hospital. Veterinarians make their living on their skills and expertise as well as by engendering trust with a client, not on prescriptions, but additional paperwork and "disclosures" that must be provided to clients in times of stress or crisis will only serve to drive a wedge between the veterinarian-client interaction. Discharge instructions are already infrequently completely read by owners, please don't pass a bill that will require more needless red-tape especially as it provides no novel avenue of enforcement. If Wal-Mart or another company feels a veterinarian is behaving unethically the can take it up with the licensing boards of the states. While this provides no avenue for them to be awarded monetary damages, it does offer them a way to censure or even strip a veterinarian of their license with repeat offenses and thus of their livelihood. This should be punishment enough. Realize this is not an epidemic: while most vets stock a full pharmacy (a practice that originated in the 1800's when vets were actually trained as pharmacists and chemists) almost all that do are happy to provide written prescriptions. We're an ethical bunch of people that have taken on $200,000+ of education debt to choose a career that is generally less lucrative that other professions (such as MDs)We're not a sinister, money-grubbing lot, and if we were, we'd not keep our medical licenses for very long. Thank you for considering these points.
Yours Sincerely, Virginia Sinnott.