Submission Number: 560891-00220
Received: 8/30/2012 7:20:41 PM
Commenter: Krista Vernaleken
Organization: IVG, Inc.
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
This bill is both unnecessary and leaves veterinarians open to frivolous litigation from owners and large conglomerates like Walmart.
First, most state veterinary practice acts require or recommend that veterinarians provide prescriptions upon request. Owners can and frequently do purchase their pet meds from wherever they wish. Requiring that a written prescription is automatically written for every single prescription, even when the owner has declined transferring the prescription to an outside pharmacy, unfairly places demands on the professional time of veterinarians, and then bans them from charging appropriately for that time.
In addition, this bill singles out the veterinary field among medical fields. Human pharmacies are not required to give a person a copy of their prescription. Dentists provide products and don't offer a written prescription for the product. No other consumer industry is required to tell the consumer that they may be able to find the product cheaper elsewhere, or advertise for a competitor within their business.
Finally, frivolous lawsuits will most certainly ensue when a Walmart employee or pet owner misinterprets the law, which they most certainly will. If I examine a pet, determine the need for a prescription medication, and charge for said examination, the owner may interpret this as charging for a written prescription. Though this is specifically mentioned in the bill, the general public cannot understand the language of law.
The ultimate result of this law will be that veterinarians will need to increase prices for their time. Is that fair to consumers? Just because large box stores are able to provide medications at below the cost most smaller veterinarians pay for the medications does not mean vets are trying to "take advantage" of anyone.
I assure you, pet owners freely purchase their medications from any source they wish. A law that can create only problems for veterinarians and pet owners such as this one is absolutely unnecessary, and, quite frankly, offensive to all veterinarians.