Submission Number: 560891-00260
Received: 9/5/2012 2:14:32 PM
Commenter: Laurie Klein
Organization: VCA Westborough Animal Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
Attachments: No Attachments
I am a practicing veterinarian in Massachusetts. Under Massachusetts state law, veterinarians must provide a written prescription when requested by a pet owner. This is reasonable and manageable. However, the provisions of the federal law currently under consideration are onerous, with excessive paperwork requirements and a requirement that veterinarians actively work to undermine our own business in favor of the large corporate backers of this bill, such as Walmart. Loss of income for my business means that I either have to raise costs on other services to make up for lost revenue, or deny my staff raises or benefits, or cut hours due to lost revenue: none of these measures will result in any benefit to the pet owners who seek care at my hospital. In addition, we have noted problems with medications filled at pharmacies which are designed for human prescriptions: there are errors in filling prescriptions (such as unauthorized substitution of medications at the pharmacy for those prescribed), and a lack of understanding of the effects of these medications in species other than humans: pet owners and pet patients are ill-served in these cases, compared to the expert and knowledgeable advice they receive and support they receive when medications are dispensed directly from the veterinary hospital providing their other health care needs. I request that the Commission advise against adoption of this legislation.
Veterinary patients are currently suffering from many shortages of medications, some of which are veterinary specific (such as Interceptor and Clomicalm), and some of which are medications used in humans and veterinary patients both (such as injectable diazepam, injectable potassium chloride, levothyroxine, doxycycline and other essential and commonly-used medications for which there is no substitute). We are given to understand that these shortages are generally due to manufacturing problems, and that the low profit margin for drug manufacterers on these generic medications means it is not worth opening new manufacturing lines to ensure adequate supply. These chronic and worsening shortages significantly impact our ability to provide thorough, compassionate care to relieve the illness and suffering of our animal patients. Whatever actions can be taken to relieve these shortages would be very appreciated by the patients and by the people who own and care about them.